I am the Executive Director of InStill Mindfulness, a nonprofit in Pulaski, Virginia providing peer recovery support, mindfulness-based programming, and mental health services throughout the New River Valley. Our staff and peer recovery specialists regularly work alongside residents of Oxford Houses in our region, and we've seen firsthand how the self-governing, self-supporting model contributes to sustained recovery.

The democratic, peer-run structure of Oxford House is not incidental to its success — it is the mechanism. Residents who take on responsibility for running their own household, managing shared finances, and holding one another accountable build exactly the skills that support long-term recovery. This is why Oxford House remains the only recovery housing model on SAMHSA's National Registry of Evidence-Based Programs and Practices.

The current draft regulations, by treating all recovery residences as uniform commercial operations requiring paid staff, business insurance, and State Corporation Commission registration, would make it impossible for Oxford Houses — which have no staff and are unincorporated associations of their members — to become certified. Since certification will be required to operate, this would force the closure of Virginia's 186 Oxford Houses, eliminating a model with a strong evidence base at a time when our region urgently needs more recovery housing capacity, not less.

I ask DBHDS to:

1. Revise staffing-dependent requirements so self-governing homes can reasonably comply.
2. Clarify whether Oxford House members collectively constitute the "operator" for purposes of these rules.
3. Avoid applying commercial-business requirements (insurance, SCC registration) to homes that are unincorporated peer associations, not businesses.

We fully support strong oversight of recovery housing and share the state's goal of protecting people in early recovery from exploitation. We simply ask that the rules be written to fit how a genuinely self-governing model like Oxford House actually operates, rather than assuming every recovery residence is a staffed commercial business.

Jamie Reygle
Executive Director, InStill Mindfulness