I urge DBHDS to revise the proposed Certified Recovery Residences Regulations so they do not impose staffing requirements on Oxford Houses. An Oxford House is self-governed and unstaffed by design. That is not a gap in the model. It is the model.

I came to Oxford House a broken man. It saved my life and gave me the ability to lead when I could not yet see that ability in myself. I trained to become a peer recovery specialist while living in an Oxford House. I later chaired the Region 5 Recovery Advisory Council, and I currently chair the Oxford House Alumni Association. Those opportunities grew out of living with peers who expected me to take responsibility, contribute, and hold myself and others accountable.

Research supports taking this model seriously. In a randomized study of 150 people leaving substance use treatment, those assigned to Oxford House reported substance use at less than half the rate of those assigned to usual aftercare at the two-year follow-up: 31.3% compared with 64.8%. They also had higher employment and lower incarceration rates. A separate study of Oxford House residents found that 63% mentored others in recovery and 44% helped run support groups. Peer leadership is a measurable part of what these houses produce, not just a slogan. (Jason et al., American Journal of Public Health, 2006, doi:10.2105/AJPH.2005.070839; Jason, Schober & Olson, The Australian Community Psychologist, 2008.)

I support strong safeguards, fair complaint procedures, and direct access to DBHDS when residents face harm. But proposed sections 12VAC35-260-140, -160, and -190 assume every residence has staff to handle complaints, serve as a community liaison, or answer handbook questions. Virginia Code § 37.2-431.1 expressly describes Oxford Houses as self-governed and unstaffed. The draft must account for that distinction.

Please revise these sections to recognize elected house officers, the Oxford House network, and outreach workers in roles appropriate to the Oxford House model. Make clear that certification does not require an Oxford House to hire or place staff in each home. Preserve an independent route for residents to report serious concerns directly to DBHDS.

DBHDS cannot champion peer recovery while adopting rules that would make peer-run housing unworkable. I am living evidence of what happens when people in recovery are trusted to lead. Please protect residents and protect the model that gave me my life back.