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Providers’ Council submits comments on compliance, reporting regs

The Providers' Council, using feedback from members, has submitted comments to the state's Operational Services Division and Executive Office of Administration and Finance regarding proposed amendments to the state regulation for nonprofit compliance, reporting and auditing.

State regulation 808 CMR 1.00 Compliance, Reporting and Auditing for Human and Social Services addresses surplus revenue, non-reimbursable costs, UFRs and Ready Payments.

The proposal will make signifcant positive changes to Surplus Revenue Retention, something the Council has sought on behalf of community-based providers, lifting the lifetime cap on revenue retention for organizations and raising the annual cap to 20 percent.

The Council, in its letter to OSD and ANF, addresses three areas of concern:

  •  The addition of language reading "investigations or" in the section addressing Non-reimbursable Costs/Litigation Costs. The comments note investigations are sometimes a cost of doing business to ensure proper service to clients/consumers.
  • The continued use of UFRs in the rate-setting process. The Council maintains that the UFR fails to capture the true market costs that providers incur in the business of providing services and does not adequately predict the cost of continuing to recruit, develop and retain talent.
  • That Ready Payments remain codified in Mass. regulations. The Council notes that for some organizations, Ready Payments are critical to providing essential services without interuption as many providers have a limited amount of cash on hand.

The Council's letter to OSD and ANF may be downloaded here. If you have questions about 808 CMR 1.00: Compliance, Reporting and Auditing for Human and Social Services, please contact Bill Yelenak.