On November 14, the Providers’ Council testified at the Executive Office of Health and Human Services (EOHHS) hearing on proposed amendments to 101 CMR 349.00: Rates for Early Intervention Program Services. Representing nearly 220 community-based human services organizations across Massachusetts, the Council stressed that the current workforce crisis and rising costs demand rate structures that support livable wages, staffing stability, and high‐quality services.
The Council’s testimony can be found here.
Key Recommendations:
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Use the Bureau of Labor Statistics (BLS) 75th percentile (rather than median) to set salary benchmarks—e.g., raising the Direct Care I benchmark from $22.52/hour to $26.03/hour.
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Continue using the baseline scenario when calculating the Cost Adjustment Factor (CAF) instead of the previously used “optimistic” economic data.
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Restore the tax & fringe rate to the FY ’24 level of 27.38 percent, add 5.1 percent for retirement contributions, and set the total at 32.48 percent.
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Increase the administrative allocation from the current 12 percent to a range of 15-18 percent to reflect true operational costs.
Advocating for Equity and Stability
The sector’s workforce is 80 percent women and 36 percent people of color—well above statewide averages—and the Council urged EOHHS to apply a racial and gender equity lens to all rate-setting decisions. Adequate rates, the Council emphasized, are critical to recruitment, retention, and maintaining timely access to services.
The Council concluded its testimony by thanking EOHHS and the Healey Administration for their ongoing collaboration and encouraged the agency to adopt the full set of recommendations to stabilize the workforce and preserve service access.
For questions regarding this hearing, please contact Caroline O’Neill.