As a case manager who frequently works with individuals in recovery and helps connect them with safe, stable housing, I have seen firsthand how important Oxford House can be during the recovery process. For many of the individuals I work with, finding a safe and supportive place to live is one of the most important steps toward maintaining recovery and rebuilding their lives.

I have referred individuals to Oxford Houses because the model provides something that traditional housing often cannot: a community of peers who understand recovery and hold one another accountable. The fact that the residents themselves operate the house is an important part of that model. Residents learn to take responsibility for their living environment, manage finances, resolve conflicts, follow house expectations, and support one another. Those are meaningful recovery skills that extend well beyond the house.

From my perspective as a case manager, treating Oxford Houses exactly like staffed, commercial recovery residences does not reflect the way these homes actually operate. I support appropriate oversight and standards that protect people in recovery, but regulations should recognize the meaningful differences between a self-governing peer residence and a commercially operated facility with paid staff.

I am particularly concerned about requirements that assume every recovery home has staff, operates as a business, or has an individual who can simply be designated as the "operator." Those requirements could create barriers for Oxford Houses even though their self-governing structure is central to how they function.

I respectfully ask DBHDS to consider the following:

• Modify requirements involving paid staff so that self-governing peer residences can comply without fundamentally changing their model.

• Clearly define who is considered the "operator" of an Oxford House and how the regulations apply to its resident members.

• Avoid imposing business insurance or State Corporation Commission registration requirements on Oxford Houses that are organized and operated as unincorporated associations rather than commercial businesses.

The individuals I serve need recovery housing that is safe, stable, accountable, and appropriate to their circumstances. Oxford House has been an important housing option for many people I have worked with, particularly because it gives residents responsibility and ownership of their recovery environment.

I encourage DBHDS to maintain appropriate standards while ensuring that those standards recognize the differences among recovery housing models. Rules designed for staffed commercial residences should not unintentionally prevent a self-governing peer model from continuing to operate.

Thank you for considering the perspective of professionals who work directly with individuals seeking recovery housing.