chapter 257 Council Submits First Ch.257 Testimony of the New Year

Date

Jan. 6 2025

The Providers’ Council submitted testimony to the Executive Office of Health and Human Services (EOHHS) on 101 CMR 414.00, addressing rates for Family Stabilization Services. Representing over 220 community-based human services organizations in Massachusetts, the Council underscored the need for equitable reimbursement rates to address workforce challenges and ensure service delivery. 

Key Recommendations: 

  1. Maintain Bureau of Labor Statistics Benchmarks at the 75th Percentile: Urging EOHHS to adopt no less than the 75th percentile of BLS benchmarks to ensure competitive wages. Reductions in benchmark percentiles for Direct Care I workers move further away from livable wages, exacerbating workforce shortages and turnover. 
  2. Increase the Cost Adjustment Factor (CAF): Recommending an increase in the proposed CAF of 2.02% to 3.85%, based on realistic economic projections, to reflect market realities and rising costs. 
  3. Enhance Tax, Fringe, and Administrative Allocations : Calling for the inclusion of a 5.1% retirement benefit in the tax and fringe rate and urging EOHHS to hold the rate steady at last year’s level (27.38%), setting it at 32.48% with the addition of retirement benefits. The Council also advocated for raising the administrative allocation from 12% to a range of 15-18%. 

The testimony highlighted the significant gender and racial equity implications of these proposals, noting the sector’s workforce is predominantly women (80%) and people of color (36%). Adequate funding would ensure fair wages, support recruitment and retention, and secure essential services for the Commonwealth’s residents. 

Contact Caroline O’Neill with any questions regarding these hearings.