I'm submitting this comment in strong opposition to the draft certification standards as currently written, because they would force the closure of Virginia's most effective recovery housing model.
Oxford House is the only recovery housing model included on SAMHSA's National Registry of Evidence-Based Programs and Practices, and it's been studied in over 100 peer-reviewed publications. Multiple studies show residents achieve substantially higher abstinence rates than comparable individuals in usual aftercare: one randomized trial found 69% abstinence in Oxford House versus 35% in the control group, and a national sample found 81.5% of residents reported no substance use in the year after leaving. Virginia's own 2019 law recognized this by naming Oxford House, Inc. as a distinct credentialing entity, separate from staffed, commercial homes, specifically because the two models operate differently and pose different risks.
The draft standards abandon that distinction. They assume every recovery residence has paid staff and a formal business structure, requiring things like a designated staff member to handle complaints, business insurance, and State Corporation Commission registration. Each Oxford House is an unincorporated association of its members, not a business. There is no staff, no owner, and nothing to insure or register in a corporate sense. These are not minor compliance gaps; they are requirements the model cannot structurally meet.
Because certification is now required to operate and to receive state or court referrals, failing these standards means losing the ability to operate at all. Virginia currently has 186 Oxford Houses that would be at risk of closure under this draft, despite having caused none of the problems the certification law was meant to address.
I ask the Board to revise the draft regulations to:
Virginia should regulate based on actual risk, not a one-size-fits-all template that penalizes the model with the strongest evidence behind it.