The Providers’ Council submitted testimony to the Executive Office of Health and Human Services (EOHHS) on 101 CMR 418.00, addressing rates for Youth Short-Term Stabilization and Emergency Placement Services. Representing over 220 community-based human services organizations in Massachusetts, the Council highlighted the urgent need for equitable reimbursement rates to address workforce challenges and sustain critical services.
Key Recommendations:
- Maintain Bureau of Labor Statistics Benchmarks at the 75th Percentile: Urging EOHHS to adopt no less than the 75th percentile of Bureau of Labor Statistics benchmarks to ensure competitive wages and reduce workforce turnover and staff shortages.
- Increase the Cost Adjustment Factor (CAF): Recommending an increase in the proposed CAF of 1.97% to 3.85%, based on realistic economic projections, to account for market realities and rising costs.
- Enhance Tax, Fringe, and Administrative Allocations: Advocating for a total tax and fringe rate of 30.07%, inclusive of a 5.1% retirement benefit, and raising the administrative allocation from 12% to a range of 15-18% to better reflect operational costs.
- Adjust for New Overtime Regulations: Highlighting the financial implications of recent Department of Labor overtime rules, which significantly increased salary thresholds for exemption, and urging EOHHS to account for these added costs in rate calculations.
The testimony also emphasized the equity impact of these measures, noting the sector’s workforce is predominantly women (80%) and people of color (36%). Adequate funding would ensure fair pay, support recruitment and retention, and secure essential services for residents of the Commonwealth.
Contact Caroline O’Neill with any questions regarding these hearings.