The Providers’ Council submitted testimony to the Executive Office of Health and Human Services (EOHHS) on 101 CMR 346.00, addressing rates for Certain Substance-Related and Addictive Disorders Programs. Representing over 220 community-based human services organizations in Massachusetts, the Council emphasized the urgent need for equitable reimbursement rates to address workforce challenges and maintain critical services.
Key Recommendations:
- Maintain Bureau of Labor Statistics Benchmarks at the 75th Percentile: Urging EOHHS to set salaries at or above the 75th percentile to ensure competitive wages for human services workers and address high turnover and staff shortages.
- Increase the Cost Adjustment Factor (CAF): Advocating for an increase in the proposed CAF of 2.58% to 4.26%, based on realistic economic projections, to better reflect market realities and rising costs.
- 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 set the total rate at 32.48%. The Council also recommended raising the administrative allocation from 12% to a range of 15-18%.
- Adjust for New Overtime Regulations: Highlighting the financial implications of recent Department of Labor overtime regulations, which increased salary thresholds for exemption, and urging EOHHS to account for these additional costs when setting rates.
The testimony emphasized the equity implications of these proposals, noting the sector’s predominantly female (80%) and racially diverse workforce (36% people of color). Adequate funding would ensure fair pay, support recruitment and retention, and secure vital services for the Commonwealth’s residents.
Contact Caroline O’Neill with any questions regarding these hearings.