I am submitting this comment as an employee of a VARR-accredited recovery residence who works directly with individuals building lives in recovery.

I strongly support standards that protect residents from exploitation, unsafe housing, resident brokering, deceptive practices, and other misconduct. My concern is that the proposed Chapter 260 regulations risk moving Virginia’s recovery residences away from the community-based Social Model of Recovery and toward a regulatory structure resembling licensed residential treatment.

That distinction matters. Recovery residences provide housing and recovery support, not clinical treatment. ASAM Level 3.1 programs, by contrast, provide clinically managed residential treatment. Recovery residences should not gradually be required to operate like treatment facilities without being treatment facilities.

VARR-accredited residences already operate under NARR standards and an established accreditation process. Chapter 260 adds state applications, documentation, reporting, investigations, corrective-action plans, inspections, policies, recordkeeping, and other compliance responsibilities. While large organizations may have dedicated compliance staff to manage these requirements, many recovery residences are small community organizations with limited administrative resources.

The cumulative burden matters. Time spent satisfying duplicative requirements is time not spent helping residents find employment, attend recovery meetings, rebuild relationships, develop life skills, and connect with community resources.

I encourage DBHDS to rely on recognized credentialing entities such as VARR wherever possible and focus direct state oversight on areas where governmental intervention provides a clear additional protection, including health and safety concerns, fraud, exploitation, resident brokering, serious misconduct, repeated substantiated complaints, or loss of accreditation.

DBHDS should also consider the effect these requirements may have on recovery-housing capacity. Compliance carries real costs through staffing, training, documentation systems, inspections, legal consultation, and administrative management. Those costs must ultimately be absorbed by providers, passed to residents, subsidized through public funding, or may cause some residences to stop operating altogether.

Oversight should also be proportionate to demonstrated risk. A VARR-accredited residence in good standing should not necessarily face the same level of regulatory intervention as a residence with serious or repeated compliance concerns.

Finally, Virginia should preserve the workforce that makes the Social Model effective. Recovery residences create meaningful employment opportunities for people with lived experience. Lived experience does not replace training or accountability, but it is an extraordinary asset. We should avoid professionalizing recovery housing to the point that capable people in recovery are pushed out because their jobs increasingly require navigating a clinical-style regulatory system.

Accountability and the Social Model are not competing principles. I respectfully encourage DBHDS to reduce duplication with VARR/NARR accreditation, clearly distinguish recovery housing from ASAM 3.1 treatment, consider the cumulative administrative and economic burden, and ensure additional state oversight is proportionate to demonstrated risk.

Virginia can protect residents without transforming recovery residences into treatment programs they were never intended to be.