My name is Whitney Dear-Reyes. I am the sibling of an adult with an intellectual disability, a speech-language pathologist, longtime Vanguard Landing volunteer and supporter, and now the Development and Resource Director working onsite at Vanguard Landing.
For me, this is both personal and professional. My sister is someone who could benefit from a community like Vanguard Landing. This determination affects whether people like her will have meaningful choices about where they live, who surrounds them, what relationships they develop, how they spend their time, and what kind of adult life they build—and whether those choices remain available if they need Medicaid to fund their supports.
I respectfully ask DMAS and CMS to evaluate Vanguard Landing by what individuals actually experience here, not by assumptions about what an intentional community might produce.
I am onsite during ordinary days—not simply during tours or regulatory visits. I see adults coming and going, making plans, declining activities, spending time alone, gathering with friends, leaving with family, taking Uber rides, attending appointments, pursuing jobs, going to gyms and restaurants, shopping, ordering food, participating in activities, and changing their minds.
One resident's recent day illustrates this better than any policy statement could. He asked to go to his preferred community gym and worked out for two hours. Back at VGL, he chose to participate in karaoke. He declined a later grocery outing because he wanted to go home, shower and relax. Later, he returned to socialize and proudly shared that he had gotten a job following a recent interview. That evening, he ordered the dinner he wanted and went home to watch a movie.
In one ordinary day: choice, community access, employment, relationships, control over schedule, the right to decline, food choice, privacy and autonomy.
That is not segregation. That is adult life.
The same principle applies to the onsite café and activities. Their existence does not make them institutional. A resident may cook breakfast at home, walk to the café, eat lunch in the cottage, order dinner from a local restaurant, participate in an activity, decline it, leave the property, spend time with family, or simply go home.
The relevant question is not what opportunities exist onsite. It is whether people are free to choose among them and the broader community.
Just looking at our pre-scheduled outings offered in August 2026:
One individual attended 3 of these outings and another attended 9. The individuals who choose to live at VGL are on their own paths, they pick what they like, try new things, and change their minds. Some will never miss an opportunity for arts and crafts, while others are launching new clubs to help host and meet new people.
These same individuals also had their own plans throughout the week - doctor’s appointments, family visits, job interview that were not tracked as “outings.”
At least every other day a resident or two are catching a ride to their preferred gym or ordering food for delivery. They also have frequent visitors.
Physical proximity does not automatically create inclusion. Someone can live in an ordinary apartment or house and still experience profound loneliness or isolation. Conversely, living near other people with disabilities does not automatically create segregation.
Institutional practices can occur anywhere. Genuine community can exist in many physical forms.
A setting's characteristics may appropriately trigger heightened scrutiny, but a presumption should be the beginning of an evidence-based review—not its conclusion.
Vanguard Landing is operating now. There is no longer a need to speculate about what life here might be like. Come observe it. Talk to residents. Ask where they went yesterday, what they chose not to do, where they eat and work, who their friends are, when they see family, and what they would change.
Witness their actual lives. No fear-mongering, no speculation, and no broad statements.
Poor care does not become community-based simply because it occurs in a conventional residence. Likewise, strong relationships, meaningful choice, individualized support and genuine community participation do not become institutional simply because they occur within a thoughtfully designed neighborhood.
Vanguard Landing should be scrutinized. Every Medicaid provider should be. Examine whether people have privacy, autonomy, individualized supports, community access, control over schedules and meals, meaningful relationships, and freedom from unnecessary restrictions.
But the same standards should not mean the same model.
Vanguard Landing does not claim to be right for everyone. Some adults may prefer an apartment, traditional group home, family home or another arrangement. Others may affirmatively choose an intentional neighborhood offering nearby friendships and opportunities while maintaining access to the broader community.
One model does not have to disappear for another to exist.
Choice is not meaningful when the system decides in advance which choices a person is permitted to make.
This is also why I struggle with the possibility that Vanguard Landing could remain available to someone who can privately fund services but unavailable to an otherwise eligible person who relies upon Medicaid. If a setting satisfies the substantive requirements of HCBS, dependence upon Medicaid should not make that person's informed choice less legitimate.
My sister should not someday be told, in effect, “You may choose that life, but only if you can afford it without Medicaid.”
“Advocates” and established providers can't be expected to speak for all adults with disabilities. Their philosophical opposition to intentional communities should not outweigh firsthand resident experiences, documented practices and actual outcomes. Advocacy should expand safe, lawful choices—not substitute someone else's preferred housing philosophy for the informed choice of an adult with a disability.
So please scrutinize Vanguard Landing. Hold us accountable. Ask difficult questions. Require evidence. Require improvement where improvement is needed. But then follow the evidence wherever it leads.
Most importantly, listen to the adults whose lives will actually be affected by this determination.
The HCBS Settings Rule should protect people's rights within the homes and communities they freely choose.
It should not decide for them which kind of community they are allowed to choose.
Respectfully submitted,
Whitney Dear-Reyes