I am a researcher who has conducted evaluations of recovery housing and assessments of recovery housing needs. From that perspective, I support strong standards for safety, accountability, and quality, but those standards should recognize that recovery residences operate through different models.

The current draft regulations appear to apply requirements designed for staffed or commercially operated residences to self-governing, peer-operated homes such as Oxford House. This is a significant concern because the defining feature of the Oxford House model is that residents themselves govern and sustain the home without paid staff. Virginia's regulations should not inadvertently make that evidence-informed model unable to operate.

I recommend that DBHDS revise the draft to: (1) provide equivalent, workable requirements for self-governing residences where a rule currently requires paid staff; (2) clearly define who is considered the "operator" when the residence is governed collectively by its members; and (3) distinguish between commercial businesses and unincorporated, self-governing associations when requirements such as business insurance or State Corporation Commission registration are applied.

Research and needs assessments consistently demonstrate the importance of having recovery housing options that are accessible, sustainable, and matched to different populations and needs. Regulations should protect residents without eliminating an effective model of recovery housing through requirements that do not fit how that model actually operates. I respectfully ask DBHDS to revise the draft so that uniform standards mean consistent protections and outcomes, rather than identical requirements that effectively exclude self-governing recovery residences.