On June 13, the Providers’ Council submitted testimony to the Executive Office of Health and Human Services (EOHHS) in response to proposed amendments to five regulations under Chapter 257, including 101 CMR 413.00, 414.00, 415.00, 429.00 and 432.00. These proposed rate adjustments affect a wide range of critical community-based services such as Youth Intermediate-Term Stabilization Services, Family Stabilization Services, Community-Based Day Support, Sexual and Domestic Violence Services, and Lead Agency Services.
Representing nearly 220 member organizations and a workforce of more than 160,000 individuals, the Council’s testimony centered on how the proposed rates would impact the human services workforce—especially in light of persistent recruitment and retention challenges that are limiting program capacity and access to services.
The council’s testimony can be found here. It asks EOHHS to:
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Use the BLS 75th percentile, at a minimum, to set fair and comparable salary levels using an adequate blend of BLS job classifications. For instance, EOHHS built this rate using a benchmark salary of $24.22 an hour for DC I. Also, use the updated May 2024 OEWS in subsequent rate hearings.
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Continue to use the baseline scenario data moving forward when creating the CAF.
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Include 5.1% for retirement in the tax and fringe rate, setting the overall rate at 32.48%
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Set an administrative allocation between 15 and 18%
Clarifying Youth Service Rates to Avoid Decreases
The Providers’ Council also called on EOHHS to review and clarify the proposed Community Service Network (CSN) rates for youth services under 101 CMR 413.00, noting that each regional model (Central, Metro Boston, Northeast, Southeast and West) reflects a proposed decrease from current rates. Maintaining consistent or improved rates year-over-year is essential to prevent disruptions in youth stabilization services across the state.
Advocating for Equity and Stability
The Providers’ Council’s testimony underscored the human impact behind these figures. With a workforce that is 80 percent women and 36 percent people of color—well above statewide averages—the Council urged EOHHS to view rate decisions through a racial and gender equity lens.
The Council concluded its testimony by thanking EOHHS and the Healey Administration for continued collaboration and urged the agency to adopt its recommendations in order to stabilize the workforce and expand access to life-changing services.
For questions regarding this hearing, please contact Caroline O’Neill.