I have read the public comments in support of Vanguard Landing, and I am genuinely happy that there are families who have found a home and services for the individuals they love. Every model of service is not appropriate for every person, and Vanguard Landing is an exceptional alternative for individuals and families who are seeking this type of intentional community.

However, the question before us is not whether Vanguard Landing provides quality services or whether families value the community. The question is whether the setting meets Home and Community-Based Services (HCBS) standards and, therefore, qualifies for Medicaid funding. I respectfully assert that it does not.

Families who have the financial means to pursue private-pay, non-Waiver options have every right to do so. There are other programs in our area, including the Ability Center and Special Persons Mailing, that have chosen not to utilize DD Waiver funding while continuing to provide valuable services to the community. Vanguard Landing should likewise be able to exist and serve families who choose and can afford this model without relying on Medicaid funding.

Vanguard Landing was established as a nonprofit organization and has relied substantially on private payments and donations from community members to sustain its development. Through that support, it has secured land, developed its community, hired staff, and begun operations. I find those accomplishments commendable, and I believe Vanguard Landing should continue to exist and serve the families who choose it.

My concern is specifically with the use of Medicaid HCBS funding.

HCBS is a federal framework intended to ensure that individuals with disabilities have opportunities to receive services in community-based settings that promote individual choice, independence, integration, and meaningful participation in the broader community. Simply locating services outside of an institutional building does not, by itself, make a setting integrated.

Vanguard Landing is designed as a 128-person campus and is planning to provide its own day and employment programs on site. In my view, this creates a setting in which individuals with disabilities live, receive services, participate in programming, and potentially work within the same planned community. That model raises significant concerns about whether the setting meets the HCBS requirements for integration and access to the broader community.

The fact that Vanguard Landing describes itself as an "intentional community" does not resolve those concerns. Intentional community and HCBS-compliant community are not necessarily the same thing. A setting can be intentional, supportive, and highly valued by the families who live there while still failing to meet the federal standards required for Medicaid-funded HCBS.

I also agree with many of the concerns raised by families here regarding the DD Waiver system. There is a need for more accessible housing, better compensation for direct support professionals, greater consistency across providers, and improved systems for documentation and information sharing. Establishing standardized documentation requirements, consistent electronic health record systems, and appropriate data-sharing mechanisms across Community Services Boards could improve the system significantly. These are important issues that Virginia should address.

Those shortcomings, however, do not change the HCBS requirements that Medicaid-funded programs must meet. DD Waiver services are intended to be financially accessible to the individuals who qualify for them, and providers are required to operate within established regulations, including requirements related to health, safety, choice, integration and discharge.

I am also concerned that the HCBS questions surrounding Vanguard Landing before it even opened appear to never have been addressed.  Proceeding with the development of the community despite those concerns does not demonstrate compliance with HCBS requirements. If anything, it makes it more important that the setting be evaluated objectively against the applicable standards.  It appears that the very foundation of the program was not futuristic but intentional disregard for the processes they knew were in place. 

Vanguard Landing can and should exist. Families should have the freedom to choose it. But the existence of a valued service option does not mean that it should automatically qualify for Medicaid funding.

I respectfully support Vanguard Landing as a private, community-supported option for families who choose and can afford this model. I do not support the use of federal Medicaid HCBS funding for a setting that I believe does not meet the applicable HCBS requirements.

I commend DMAS for applying these standards consistently, regardless of financial resources, political influence, or the understandable passion of families advocating for their loved ones. This issue is bigger than any one organization or group of families. It concerns the future of disability services and the principles that Medicaid HCBS funding is intended to protect.

The disability community is small, but it is strong and powerful. We should be advocating for services that promote equality, choice, independence, and genuine access to the broader community. I am concerned that, in focusing understandably on the immediate benefits Vanguard Landing provides to some families, we may overlook the dangerous precedent created if Medicaid funding is permitted for a setting that remains unaffordable to many of the individuals the Waiver is intended to serve and does not provide meaningful integration into the broader community. Approving such a model could signal that a provider may receive Waiver funding while creating a service environment that is financially inaccessible and physically or socially separate from the communities in which people live. That would fundamentally undermine the purpose of HCBS and could influence the development of future Waiver services in ways that move us away from, rather than toward, inclusion, choice, and community integration.

My position is not that Vanguard Landing should not exist. My position is that Medicaid funding should follow the HCBS standards established to protect community integration, choice, and independence for people with disabilities. Those standards should apply equally to every provider, regardless of the resources, influence, or circumstances surrounding the program.