My name is Tim Adkins, and I am the General Manager of Endurance Properties and Endurance Development. We are a property owner and landlord that currently hosts 16 Oxford Houses throughout Northern and Tidewater Virginia.

We purposefully chose to partner with Oxford House specifically because of the program’s long-standing, proven success—both here in Virginia and across the country—as the gold standard for evidence-based recovery housing. We have seen firsthand that their model, which is democratically self-governing and self-supporting, provides a stable and highly effective recovery environment precisely because it functions as an unincorporated association rather than a commercial business with paid staff.

As currently drafted, the proposed DBHDS regulations would effectively force these 16 homes to close. The requirements for paid staff to handle complaints, mandatory business insurance, and registration with the State Corporation Commission are fundamentally incompatible with the peer-run, democratically governed model that Oxford Houses have utilized successfully for decades.

We fully support the state’s efforts to ensure safety and oversight in recovery housing, but regulations must be tailored to the actual operating structure of the homes they govern. To avoid the closure of these essential residences, I respectfully request that the Department:

1.  Change the rules that require paid staff so that self-governing, peer-run houses can remain compliant.

2.  Clearly define that members of an Oxford House are not considered the "operator" under these rules.

3.  Stop treating every recovery home as a commercial business by removing requirements for business insurance and State Corporation Commission registration for unincorporated associations.

Thank you for your time and for considering these necessary adjustments to protect the availability of effective, evidence-based recovery housing in our state.

Sincerely,

Tim Adkins

General Manager, Endurance Properties