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.
Supporting Fair Wages with Higher Benchmarks
The Providers’ Council emphasized the need for EOHHS to use no less than the 75th percentile of Bureau of Labor Statistics (BLS) wage data when setting benchmark salaries. While the proposed Direct Care I rate is benchmarked at the 53rd percentile of BLS data—$20.79/hour—the Council pointed out this is a decrease from last year’s percentile despite wage increases overall. A 75th percentile benchmark would set the rate closer to $24.22/hour and help ensure livable wages, especially as the sector continues to face unprecedented staffing shortages.
The Council also urged EOHHS to incorporate the most recent May 2024 BLS data into future rate hearings to ensure wages reflect current labor market conditions.
CAF and Fringe Adjustments More Accurately Reflect Economic Conditions
The Council thanked EOHHS for adopting the baseline scenario—rather than the previously used optimistic scenario—when calculating the Cost Adjustment Factor (CAF), and expressed appreciation for the proposed 3.25 percent increase. The Council encouraged continued monitoring of economic trends to ensure the CAF remains adequate.
However, concerns were raised regarding the proposed reduction in the tax and fringe rate from 27.38 percent in FY ’24 to 24.97 percent in FY ’25. Members are facing double-digit increases in health insurance costs, which the Council said are not captured in the new figure. The Council requested EOHHS maintain last year’s fringe rate and add an additional 5.1 percent to reflect retirement benefits, setting the rate at 32.48 percent.
The Council also reiterated its support for raising the administrative cost allocation from 12 percent to a more realistic 15 to 18 percent range.
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.
To review the full testimony, please click here.
For questions regarding this hearing, please contact Caroline O’Neill.
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