On December 12, 2025, the Providers’ Council submitted testimony to the Executive Office of Health and Human Services (EOHHS) on the proposed rates for 101 CMR 416:00: Rates for Clubhouse Services. Representing over 220 community-based human services organizations across Massachusetts, the Council addressed Secretary Kiame Mahaniah and the Healey Administration, emphasizing that insufficient rates depress workforce salaries, worsen the sector’s recruitment crisis, and result in residents on wait lists due to programs unable to run at full capacity.
The Council’s testimony can be found here.
Key Recommendations:
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Salary Benchmark: Urge EOHHS to use no less than the 75th percentile of BLS when setting benchmark salaries for all positions. For example, this would set the benchmark wage for Direct Care I workers at $26.03/hour (based on May 2024 BLS data).
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Cost Adjustment Factor (CAF): Thank EOHHS for adopting the baseline scenario data (a compromise) in the proposed 2.53 percent CAF, but request continued evaluation to ensure sufficiency relative to market conditions.
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Tax & Fringe Rate: Ask EOHHS to hold the tax and fringe rate harmless from the prior year’s rate of 27.38 percent and include an additional 5.1 percent for retirement benefits. This would set the total rate at 32.48 percent.
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Administrative Allocation: Increase the administrative allocation from the current 12 percent to a range of 15–18 percent, noting that the current allocation is inadequate to cover true operational costs.
Advocating for Equity and Stability
The Council stressed that inadequate reimbursement rates for human services promote racial and gender inequity, as the sector’s workforce is 80 percent women and has a higher proportion of people of color (36 percent) compared to all other industries in the state.
The Council thanked EOHHS for the significant progress made to increase salaries and for the commitment to improving staff recruitment and retention. The testimony concluded by encouraging EOHHS to adopt the full set of recommendations to provide providers with the best opportunity to deliver quality and available services from a stable and essential workforce.
For questions regarding this testimony, please contact Caroline O’Neill.