As a provider of Medicaid-funded residential services, Hope House Foundation supports meaningful choice, increased service capacity, and the growth of high-quality providers to meet the needs of adults with developmental disabilities. We welcome innovation and actively collaborate with other providers to expand individualized, community-based supports across Virginia. We also recognize the urgent need for safe, stable, affordable housing and understand that Vanguard Landing was developed in response to a genuine and longstanding gap in available housing and support options. 

Over many years, we have seen individuals with developmental disabilities thrive when they receive person-centered, individualized support in integrated community settings. Families' concerns about safety, isolation, and the future are real and deserve thoughtful solutions. However, people should not have to give up integrated, community life in order to receive reliable support. Expanding options for individuals and families is important, but all Medicaid-funded Home and Community-Based Services (HCBS) settings must meet the same federal standards for individual rights, autonomy, choice, and community inclusion. The availability of a service or housing model does not exempt it from compliance with the HCBS Settings Rule. 

The responsibility for enforcing HCBS Settings Rule compliance standards does not rest with providers, families, or advocates. This responsibility rests with DMAS, DBHDS, and CMS. They are charged with ensuring that Medicaid-funded services meet federal HCBS requirements initially upon provider application and that those requirements are applied consistently across every setting seeking public funding through Medicaid waiver reimbursement. HCBS standards are not merely aspirational or optional. Virginia is required to comply. 

The Vanguard Landing review raises important questions about why longstanding HCBS  and programmatic deficiencies were not addressed earlier by the Commonwealth to include resolution. Providers seeking to deliver Medicaid-funded services should demonstrate full compliance with fundamental provider and HCBS requirements before services begin. Allowing deficiencies to persist through multiple stages of provider approval creates uncertainty for individuals and families, undermines confidence in the oversight process, and places all stakeholders in the difficult position of debating compliance after substantial public and private investment has already occurred. 

The Vanguard Landing Heightened Scrutiny Review identifies deficiencies involving core HCBS requirements, not merely technical standards. The review describes a disability-specific model in which housing, supports, transportation, meals, activities, and social opportunities are organized within a single setting. These features limit opportunities for full-community integration, relationships with people who do not receive disability services, spontaneous participation in community life, and the exercise of individual choice and autonomy. Based on the findings presented in the review, Vanguard Landing has not demonstrated that it meets the fundamental HCBS requirements.  

Virginia has spent decades and invested significant public resources advancing the goals of the Americans with Disabilities Act, Olmstead, and the Commonwealth's settlement agreement with the U.S. Department of Justice by moving away from segregated models and toward individualized, integrated community supports. Consistent enforcement of HCBS standards by DMAS, DBHDS, and CMS is essential to protecting individual rights, preserving the integrity of Virginia's waiver system, and ensuring that Medicaid-funded services continue to support individuals to live, work, build relationships, and participate as full members of their broader communities. 

Hope House Foundation supports innovative service models when they promote inclusion, self-determination, and full participation in community life. However, a setting should not be considered HCBS compliant simply because it fills a need for more providers or is preferred by some families. Based on the findings contained in the Heightened Scrutiny Review, we do not believe Vanguard Landing currently demonstrates compliance with HCBS requirements, and approving this type of isolated, disability-specific model as a Medicaid-funded HCBS would weaken the enforcement of the consistent standard all providers in Virginia are expected to meet. 

Hope House Foundation's goal is not to limit housing options or discourage new providers. Virginia's shortage of affordable housing and support options is real, but the solution should be to build more individualized, inclusive supports, not to lower the standard for what qualifies as community under HCBS. We hope that through the heightened scrutiny process, Vanguard Landing will make the changes necessary to ensure individuals experience the genuine autonomy, choice, community membership, and inclusion required under the HCBS Settings Rule. 

For these reasons, Hope House Foundation does not support a determination that Vanguard Landing is HCBS-compliant based on the current record. We encourage DMAS, DBHDS, and CMS to apply HCBS standards consistently and require unmistakable evidence that individuals experience genuine self-determination, autonomy, integrated housing, community membership, and meaningful participation in the broader community before approving the setting for Medicaid-funded HCBS services.