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3. There is no apparent calculation of the costs to meet state and federal regulations as required
by Chapter 257.
4. While a cost inflation factor is used, it is based on depressed data. At the minimum, it is not
sufficient to remedy the issues raised in the report by EOHHS – Financial Health of
Providers in the Massachusetts Human Service System issued in October 2001
6. The highly abbreviated methodology formulas do not indicate if any consideration has been
given to quality and safety.
7. Frequently the state and providers compete in “the market” for people with similar skills and
credentials. It is not unusual for the state to recruit our workers because it can pay market
rates. This differentiation in many salary categories essentially creates two standards of care.
This is not fair nor reasonable.
8. The methodologies provided by the Division of Health Care Policy and Finance are highly
abbreviated. Full transparency is not offered by the materials sent in response to our requests.
In Summary
We respectfully request that you withdraw your rate calculations and revise them to incorporate the
directives of Chapter 257 to provide proper funding. The reliance on the Uniform Financial Report
(UFR) – a document which is widely recognized as flawed – shortchanges people the state wishes to
serve - and their service providers. Further, the rates being set are designed to further the state’s budget
goals, not to meet the needs of the people being served, provide an adequate salary for their caregivers
or adequately fund the operational needs of providers. I look forward to seeing any revisions you might
make in response to the testimony you receive here today.
Providers’ Council
Testimony on: CMR 114.4 CMR 14.00
March 9, 2011 – Page 2