To:
Áron Boros, Commissioner
Division of Health Care Finance & Policy
From: Michael Weekes, President/CEO
Providers’ Council
CC:
Catherine Mick, Chief Administrative Officer
Executive Office of Health and Human Services
Re:
Testimony on 114.4 CMR 13.00 – Payments for Youth Intermediate-Term Stabilization Services
Date: February 21, 2012
Commissioner Boros and members of the Division of Health Care Finance and Policy, thank you for this
opportunity to submit testimony on 114.4 CMR 13.00, Payments for Youth Intermediate-Term
Stabilization Services. The Providers' Council is a statewide association of home- and community-based
caregivers that contract with state purchasing agencies to deliver a wide array of human and social
services.
On behalf of the Providers’ Council, thank you for your work on the development of these rates as
proposed in the amendment to 114.4 CMR 13.00. We particularly appreciate the transparency of the
Division of Health Care Finance & Policy’s methodology, as presented in its written documents, oral
presentations and supporting documentation, as this will support the development of an improved
system of care for this population. That said, it is incumbent upon us to share our primary concern: the
proposed rates are inadequate and fail to remedy what has become a chronic situation of underfunded
programs designed to serve some of the Commonwealth’s most vulnerable residents. It is imperative
that the quality system we envision is not only designed correctly, but also is implemented effectively
with adequate rates. To do less would thwart the intent of this major system redesign.
Historical Context
Concerns about underfunding with inadequate rates are hardly new. In 2007, the Executive Office of
Health and Human Services (EOHHS) commissioned a report on the Financial Health of Providers in the
Massachusetts Human Services System that “confirmed that, in many areas, the financial health of
human service providers in the Commonwealth is suffering, and Commonwealth policies have some
association with financial health outcomes. The sample of approximately 615 providers at the core of
this analysis shows subpar and at times precarious results on three important aspects of financial health:
profitability, solvency, and liquidity. The majority of providers in the sample report deficits on
Commonwealth activities each year, and even more, about 60%, show cumulative deficits on their
Commonwealth activities since 1993.”
Providers’ Council
Testimony on 114.4 CMR 13.00
February 21, 2012
The report acknowledges that staff salaries and fringe benefits do not appear to keep pace with
increases in the overall cost of living, and that the relatively low wages that provider organizations are
able to offer employees limit the level of experience and qualification for many direct care workers,
while also contributing to rapid staff turnover and increased replacement costs. Our entire provider
community has made improving our workers’ compensation and benefits a central theme of our
agenda. Further, the report notes the precarious financial conditions in which providers are working:
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Fifty-six percent of providers report deficits on Commonwealth activities each year
About 60 percent of providers have cumulative deficits on their Commonwealth activities
since 1993
Almost half of providers do not generate sufficient cash to pay for operations
One-third of providers have over 45 days of unpaid receivables
This report was a catalyst for legislative action and the passage of Chapter 257 of the Acts of 2008,
which amends Section 2A of chapter 118G such that the rates for social service programs are required to
be “reasonable and adequate to meet the costs which are incurred by efficiently and economically
operated social service program providers in providing social service programs in conformity with
federal and state law, regulations, and quality and safety standards.”
Chapter 257 is a legal mandate for the Commonwealth to reimburse providers at rates that are
adequate and implemented correctly, reflecting true market costs and enabling the purchasing agencies
and their provider partners to construct a high quality community-based system of care. What follows is
a more detailed discussion of our concerns with the proposed amendment.
Acuity
Most provider organizations agree that the acuity of clients using residential services has risen steadily
over the past decade. This is not surprising given the shared vision of developing a community-based
system of care; state agencies, providers, clients and families all appreciate services delivered in the
least restrictive settings.
Clients that used to be hospitalized in institutions are now being served in the more intensive levels of
community residential care such as IRTPs, while clients that used to be served in these more intensive
levels are now being served in community-based Group Homes. Some clients that were previously
deemed eligible and appropriate for Group Home models are now being served in less intensive settings
in the community. While we applaud treating clients at less restrictive levels of care than they
previously received, there must be a recognition that more appropriate resources are required as each
level of care is asked to take on more challenging clients.
Providers describe several differences in the clinical presentation for children entering Group Homes.
They are now seeing many youth with lower cognitive functioning, as well as youth on the Autism
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Providers’ Council
Testimony on 114.4 CMR 13.00
February 21, 2012
Spectrum. Additionally, they are seeing an increase in medically involved youth who have medical
conditions such as diabetes, fragile bones, eating disorders, digestive difficulties, sleep disorders and
occasionally require the use of brain stents. These youth require extremely close monitoring and
attention and have multiple hospital and doctors’ visits, often needing specialized visits to Boston which
requires an entire day of staff time and attention.
At the same time many or most of the youth in Group Homes are also taking one or more psychotropic
medications. The need for the clinician, the child, the family, the direct care and medical staff to work
closely with the Child Psychiatrist is critical for treatment success. Medication monitoring, closely
watching for side effects or improvements, and ensuring the Group Home has enough access to a highly
experienced Child Psychiatrist are tasks that require strong management and coordination within the
Group Homes.
Our providers also report a steady increase in the number of youth requiring 1 to 1 attention, and the
need for very specialized treatment. For example, a youth on the Autism Spectrum may have a great
deal of difficulty forming relationships with staff and other residents. It may be particularly difficult for
them to have a roommate or to tolerate the thought of someone touching their belongings or expecting
them to hold a conversation or participate in a psychoeducational group.
These children require much more 1 to 1 time, quiet, predictable interactions and structure that is highly
consistent. If at the same time the Group Home has a cognitively delayed child that does not respond to
talk therapy, has poor boundaries, is highly aggressive and loud, and requires physical interventions, it
may cause havoc to the child on the Autism Spectrum, which again will require much more 1 to 1 time
and creative interventions.
Sufficient staffing is essential in residential care. In a 12-bed Group Home with four staff on a shift, if
one child needs physical restraint, at least two staff are required to assist with the intervention, leaving
only two other staff members to deal with eleven remaining children. Some of these children will be
frightened by the other child’s restraint, some of whom will need 1 to 1 attention, and some of whom
will be disappointed because their planned activity is delayed because the remaining staff cannot leave
the building if a restraint is going on.
The residential programs also continue to have high functioning youth who may range from conduct
disordered and aggressive, to highly motivated and preparing for the next step to foster care or
independent living or return to a kinship/family member. These youth need very different approaches
including Dialectal Behavioral Treatment, cognitive behavioral therapy, community service projects, high
level recreational opportunities and employment experience. The range of service needs and clinical
presentations in most Group Homes is clearly vast and sometimes overwhelming. The hard work and
clinical expertise needed to operate a successful Group Home will require many more resources in order
to continue to effectively address these clinical needs.
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Providers’ Council
Testimony on 114.4 CMR 13.00
February 21, 2012
An important dynamic impacting virtually all residential providers has been the decline in the numbers
of youth in the residential systems has decreased the number of treatment milieus. It becomes a matter
of economic survival for Group Homes to take a wider range of youth in ages, clinical diagnoses, and
levels of aggression as the options are limited. Thus, clinical and direct care staff in the residential
setting must be highly skilled in dealing with latency children, older adolescents, aggressive children,
withdrawn traumatized children, high functioning children, severely cognitively delayed children,
children with family involvement, and children with no viable family, all under the same roof, with the
same staff at the same time.
Additionally, clinical staff members are being challenged to do more effective family work. It is an
appropriate objective for this population. Clients on a clinician’s caseload, however, include high
functioning motivated parents, low functioning parents involved in Care and Protection petitions,
parents with histories of substance abuse, and parents who are eager for the return of their child, but
are highly overwhelmed by their child’s behaviors and clinical needs. This requires a well trained and
consistent staff. The family work must be flexible, creative, in the parents’ home where appropriate,
and be provided when the family is available to effectively participate in treatment.
The clinicians require a great deal of support, supervision, and teamwork to address multiple complex
needs from such complex clinical cases. Finding and retaining strong, experienced clinical staff able and
willing to work in the complex and sometimes high-risk circumstances that Group Homes face on a daily
basis are challenges to be recognized and addressed by the overall system in this procurement process.
Utilization
As noted above, residential service providers have experienced a significant decline in utilization of
services in the past several years, creating financial pressures to accept referrals that stretch their
program models. The Children’s League of Massachusetts, the Association of Behavioral Healthcare and
the Providers’ Council conducted a brief survey of its residential providers regarding actual billing for
state contracts in FY’10 and FY’11. The results, presented in the table below, show that actual utilization
for the past two fiscal years was roughly 70 percent.
Type of Program
Group Home 1:3
Group Home 1:4
STARR**
Total Capacity
(Number of Beds) in
state FY2010
120
111
70
Utilization %
FY2010
63.07%
72.57%
77.66%
Total Capacity
(Number of Beds)
in state FY2011
108
99
70
Table 1: Actual Utilization in youth residential programs for FY ’10 and FY ’11.
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Utilization %
FY2011
68.05%
69.36%
79.86%
Providers’ Council
Testimony on 114.4 CMR 13.00
February 21, 2012
Recommendations:
 With actual utilization at these levels, we would urge the Division to reconsider its methodology
for developing class rates.
 The approach for setting rates for Group Home and STARR programs would be to adopt the
scaled utilization factor methodology that DHCFP used in setting the proposed Adjudicated
Youth Residential Treatment base rates, with utilization factors ranging from 50 percent to 90
percent by increments of 5 percent. This approach creates a payment mechanism whereby
providers are reimbursed for their sunk costs regardless of the number of beds filled. We would
like to see the Division use this same methodology across all service types.
** Note: Because STARR is currently a cost reimbursement model, there has been a strong incentive for
the Commonwealth to fill these beds. Even with this, the STARR program utilization has not met the
90% standard in the proposed rates.
Program Models/Benchmark FTEs
We greatly appreciate the presentation of model budgets which allow for an open assessment of
program design. Generally speaking, DHCFP and the purchasing agencies have portrayed respectable
staffing patterns across the different residential and community-based service types. We do, however,
have a few concerns:
 Direct care staff - The numbers of FTE allocated for GH Intensive 1:3 and for GH 1:4 are very
tight. In the case of the 12-bed GH 1:3, to have four staff per each primary shift and only two
staff per overnight shift requires 10 staff shifts per day, or 70 staff shifts per week. 15 FTE
working five days/week generate 75 staff shifts per week. In the meantime, the trend in youth
programming is toward greater community integration, which has resulted in greater demand
for residential staff to accompany kids off site. The need to transport youth is especially
demanding in STARR programs when transportation to the child’s home public school has not
yet been arranged. This averages five to 10 days of transportation by program staff, generally
to multiple different public schools. At the same time, many youth are unable to attend school
or alternative day programming for extended periods of time, putting additional pressure on
staff ratios. This issue is particularly acute in the summer months.
 Nursing - The assumption that a .25 FTE Nurse is adequate to care for 12 youths in a group
home (48:1 ratio) is puzzling, particularly given the rise in medically complex cases, coupled with
the fact that virtually all kids in residential are taking one or more psychotropic medications.
While we might expect much of the responsibility for psychotropic medication administration
will eventually be transferred to direct care staff with the implementation of new MAP
requirements, the registered nurse will still be in charge of the training, supervising and
monitoring of the medication component of the program.
 Teachers - Teachers have been an integral component of many STARR programs; the absence of
this position in the model budget is a step backwards. Not many kids entering a STARR program
have their educational situation functioning smoothly. The teacher can conduct diagnostic
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Providers’ Council
Testimony on 114.4 CMR 13.00
February 21, 2012

screenings and begin the child working on age and grade appropriate educational materials.
The STARR Teacher obtains school work from the child’s school and provides direct instruction
on the same curriculum the child was working on, in order to prevent further loss of credits.
This also helps the child transition back to school with less pressure and fear of ongoing failure
because they did not fall further behind their school peers.
Support Staff - This is low for some of the program types. At .25 FTE for Group Home 1:2 and
1:4 and at .50 FTE for STARR, the proposed level of administrative support is insufficient to fulfill
all reporting requirements including CANS, input into the Virtual Gateway, and additional
anticipated reporting requirements in the RFR. Additionally, a number of providers have
Program Support positions (UFR code 138), and we hope an add-on rate can be set for this
category at an appropriate salary.
Recommendations:
 Allocate 16 FTE direct care staff for both GH 1:3 and GH 1:4. Based on the previous discussion
about acuity, referrals to either level have been similar and have become more acute. Staffing
at these levels will significantly improve the programs’ ability to meet performance
specifications.
 Allocate at least .5 FTE Nurse for the GH 1:3 and the GH 1:4 programs.
 Allocate 1 FTE teacher’s position for STARR at a salary of $44,500 which is consistent with DYS
pay for a certified teacher.
 Double the allocation of Support Staff to .5 FTE for GH 1:3 and 1:4, and to 1.0 FTE for STARR.
We also ask that an add-on rate be created for providers who have Program Support positions
that are not accounted for elsewhere.
Program Models/Benchmark Salaries
The growing personnel crisis confronting the human services provider community has been well
documented over the past decade. In its 2006 report, Help Wanted: The Future of the Human Services
Workforce in Massachusetts, the Donahue Institute at the University of Massachusetts concluded that
as employers, providers “can expect to find it increasingly difficult to find workers willing to provide
essential services to vulnerable populations in a highly demanding work environment for relatively low
wages. They can also expect increasing competition for both skilled and unskilled workers from
healthcare and other service sectors that are also expected to grow but which presently provide their
employees with comparatively higher wages, training and support.” The wage gap between human
service workers and those in similar positions in the healthcare industry has been found to average over
15 percent.
As we reviewed the benchmark salaries with our providers, a number of issues were identified. First and
foremost was the concern that 2009 UFR data codifies the low payments that result from budgets set six
to seven years ago that have not seen increases during the ensuing years. Providers are hard pressed to
recruit and retain qualified staff with such low salaries.
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Providers’ Council
Testimony on 114.4 CMR 13.00
February 21, 2012
Specific concerns include:
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7
The cost of Psychiatrist, whether salaried or on a consultancy basis, is approximately $200,000
annually in most regions. This level is recognized for the IRTP and CIRT budgets, but not for
Group Homes, STARR, or the Continuum. The figure should be at the same $200,000-level for all
groups. The Bureau of Labor Statistics puts the average annual salary for Psychiatrists at
$184,000 in 2010, but this does not recognize the higher cost for a child-certified Psychiatrist.
The budgeted salary for an LICSW is $49,100 for IRTP and CIRT, but only $42,200 for STARR and
$46,600 for all others. Even at the $49,100 level competition for LICSWs is extremely difficult as
the vast majority of clinicians, licensed or not, prefer to work in the community, not residential
settings. At the same time, the implementation of the Children’s Behavioral Health Initiative
(CBHI) has created a dramatic need for clinical positions. Indeed.com, a search engine for job
listings, has 150 postings for licensed clinical positions with salary ranges from $57,000 $63,000. Further, while a typical clinician works 9 a.m. to 5 p.m., five days a week, clinicians in
DCF/DMH residential settings are expected to work evenings and weekends. Finally, in many
instance the same LICSW spends time in different programs. Variability in salary depending
upon program type for the same function is not supported and should be changed.
Our providers report that a salary of $42,189 is inadequate for a Masters level Clinical Care
Manager. At this salary, recruitment and retention of Master’s level clinicians will be extremely
difficult as 1) the vast majority of clinicians, licensed or not, prefer to work in the community,
not residential settings; and 2) the implementation of the Children’s Behavioral Health Initiative
(CBHI) has created a dramatic need for clinical positions. It is projected that CBHI has resulted in
about 250 new clinical positions. Further while a typical clinician works 9 a.m. to 5 p.m., five
days a week, clinicians in DCF/DMH residential settings are expected to work evenings and
weekends.
Our providers report that a salary of $36,500 is inadequate for a Case Worker Manager. At this
salary, recruitment and retention of case managers will be extremely difficult as outlined in the
previous point. Further, as they are providing services to a broader cultural/linguistic
population, it will make it difficult to recruit scarce employees who have similar capabilities
without adequate salaries.
Salaries for Direct Care range from a high of $35,000 for the Continuum to $28,500 for GH.
STARR is pegged at $29,200 while IRTP and CIRT at $30,400 respectively. We suspect that the
direct care benchmark was derived from a weighted average of supervisors, DC I and DC II. The
figure, which appears reasonable for the lower levels, is inadequate if we are to recruit and
retain supervisory level DC staff. Provider salaries for direct care have been woefully
inadequate, resulting in difficulty in recruitment and retention of qualified staff who are the
front-line workers providing care to DCF and DMH children, youth and families. Supervisory and
direct care staff turnover, due to non-competitive salaries, remains a significant issue.
Providers’ Council
Testimony on 114.4 CMR 13.00
February 21, 2012
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The budgeted annual salary for Occupational Therapists is pegged at $61,700, but most
providers pay by the hour ($75/hr). At 20 hours/week, the cost to the provider is in excess of
$75,000 which far outstrips the budgeted $30,900, even with the application of fringe benefits.
DMH and DCF clients need OTs with specialized skills. In a competitive field, this is a seller’s
market.
Recommendations we support with an annual cost of inflation adjustment added:
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The Division using the $200,000 level for Psychiatrist across program types.
Salaries for LICSWs being set at $60,000 in order to recruit and retain qualified clinicians.
Salaries for MA-level Clinical Care Managers being set at $50,000.
Salaries for Case Worker Managers being set at $45,000.
An average salary of $35,500 being set for supervisory level staff and $32,000 being set for
direct care staff, which will allow a reasonable separation in salaries between supervisory staff
and the direct care workers they supervise.
The Division recognizing the true cost of OT services and budget it as a contract position
(without fringe) at $75/hour.
The Division considering adjustments for scarce cultural/linguistic capabilities and regional
adjustment factors across all salaries for all position and that salaries are funded with annual
adjustments included.
Non-Personnel Expenses (Relief, Occupancy, Travel, Tax & Fringe)
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Relief - In addition to vacations, holidays and sick time, the relief line in the budget is the catchall category that covers staff overtime costs, staff turnover, and additional demands. We note
that DYS used a more reasonable formula resulting in a 19.6 percent per FTE relief allowance.
The 15 percent per FTE formula used by the Division fails to address coverage needed for
summer programming, as well as the increasing instances where kids do not attend school/day
programs and thus require on site coverage. It is unclear why DCF and DMH receive less
vacation, sick/personal, holiday and training time than DYS. Additionally, we believe an
additional 1.4 percent per FTE relief allowance should be added in to account for expanded
requirements associated with MAP. Finally the training piece is too low: providers report
needing to spend closer to 10 days/year on staff training given the greater acuity of the
populations served, which is double the allocated five days/year.
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Medication Administration Program (MAP) - With the recently announced requirements that
child/adolescent providers will be required to implement the MAP program, we can anticipate
significant additions to the time allocated for staff training. We assume that the program for
children/adolescents will mirror the structure the existing MAP for adults in the DMH system
which requires a curriculum of at least 16 hours, to be taught by a licensed Nurse. We expect
Providers’ Council
Testimony on 114.4 CMR 13.00
February 21, 2012
conservatively that at least another three to four days per year per FTE of training will need to
be added to get staff prepared for, and able to actually sit for, the MAP examination. While we
expect that the addition of MAP-certified direct care staff will, in the long run, reduce the
responsibility of the program Nurse in terms of direct medication administration, he/she will
have additional training and supervisory responsibilities.

Tax & Fringe - For some reason there is a fluctuation between models: the tax & fringe rate for
IRTP is set at 26 percent, while it is fixed at 23.42 percent for all other models. (At the same
time we note that DHCFP proposed 28.29 percent for tax & fringe for 114 CMR 18.00 to cover
health insurance and other fringe benefits for DYS Youth Short-Term Stabilization and
Emergency Placement Services published on November 11, 2011). Health insurance consumes
almost every dollar of the fringe allocation, putting providers at a competitive disadvantage in
attracting employees. It must be noted that the cost to providers for health insurance is based
upon the number of FTEs, not the total payroll. The calculation of fringe benefits as a
percentage of payroll dollars understates the true costs. This methodology in effect creates a
lower per FTE weighted average which is compounded by the greater amount of employees or
FTEs in lower paid positions taking health insurance.
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Travel - As programming is increasingly geared toward supporting greater community
integration, staff travel increases. One has only to look at the price of gas to know that travel
costs have increased. The IRS currently allows reimbursement for mileage expenses at 55
cents/mile, an increase of over 37% since 2006. In addition, distances needing to be traveled
vary considerably by region and Chapter 257 calls for these regional allowances to be
considered when setting rates. Programs in the western part of the state have greater
geographical areas to cover providing services to clients. Mass transportation options are sparse
and infrequent.
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Occupancy - As utilization of residential beds decreases, the youth being sent to residential
programs present with more dangerous behaviors. To serve them effectively and safely, many
providers have constructed new facilities or upgraded existing ones. The proposed occupancy
rates do not recognized amortized capital costs as part of the operating costs for these
improved facilities.
Another issue lies in the fact that the 12-bed model is not always indicated or is not preferred, as the
industry moves toward smaller, more home-like units in community-based settings. Locating a 12-bed
program at two or three different physical sites means the provider enjoys less economy of scale. The
current rates, based upon historic UFR data, do not appear to anticipate this trend.
Finally we know that there are significant differences in the cost of real estate when we compare prices
inside Route 128 as compared to west of it. Taking an average of all group home occupancy costs from
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Providers’ Council
Testimony on 114.4 CMR 13.00
February 21, 2012
around the state penalizes programs in “high rent areas” and rewards programs in “low rent areas.”
Chapter 257 requires that the Commonwealth consider costs differences based on geography and as
such, the proposed rates must include an adjustment for regional differences.
Recommendations that we support include:
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The Division using a 21 percent per FTE relief allowance. Originally, we had requested a 19.6
percent per FTE relief allowance seen in the DYS programs, and with the expanded
requirements associated with MAP, we would request another 1.4 percent per FTE allowance.
This formula will better support existing training and coverage needs.
The Division setting the tax & fringe rate at 28.29 percent (same as that proposed by DHCFP in
rates for 114 CMR 18.00, to cover health insurance and other fringe benefits for DYS Youth
Short-Term Stabilization and Emergency Placement Services published on November 11, 2011).
We also recommend changing the methodology so that computing fringe is tied to the number
of FTEs in the contract rather than to total payroll.
The Division increasing the travel expense line to reflect inflation.
The Division creating an adjustment/add on factor that recognizes new construction.
Finally, we are recommending the Division create an adjustment factor that recognizes regional
differences for travel and occupancy.
Cost Adjustment Factor
DHCFP chose the most optimistic of assumptions for inflation trends. Using the same trending
methodology that resulted in the optimistic 5.39 percent CAF, we found that the baseline trend would
yield a 6.53 percent CAF, while the pessimistic trend would yield a 7.24 percent CAF.
Recommendation:

Use the baseline trend resulting in a 6.53 percent CAF across program types.
Continuum Model
The Continuum is a new model which was introduced at a June 3, 2011 Provider Information and
Dialogue Session. While the presentation provided a high level overview of the model, specific details as
to standards and program expectations was not made available which makes it difficult to determine if
the resources supporting the proposed rates are sufficient to deliver the service.
At this point in time the proposed new Continuum Program is only defined as “an integrated and
intensive array of services”…that “includes an option for residential treatment in addition to
community-based care.” The proposed amendment goes on to state that the purchasing agencies will
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Providers’ Council
Testimony on 114.4 CMR 13.00
February 21, 2012
determine the per diem rate for a Continuum program and describes the formulaic basis for such
determinations.
We wholeheartedly endorse the concept of an integrated and intensive array of services being provided
in a flexible manner to support the unique and changing needs of children and families. The provider
community has been willing and proud collaborators with the purchasing agencies over the past four
decades in developing a strong and responsive community-based system of care. We look forward to
working together to continuously improve the purchase-of-service system moving forward.
That said, we have a number of concerns, absent more complete program specifications, about how this
Continuum model will be operated and financed. The concerns we have expressed above regarding
staffing ratios, benchmark salaries, tax and fringe, and the relief formula are also relevant for the
Continuum model. With the blended rate concept, it appears that the Continuum model may ask a
provider to function, conceptually, as a managed care organization. Several questions with financial
implications arise:
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Will a Continuum provider have to directly provide all 6 services included in the sample
blended rates? Or can they sub-contract to/partner with other providers?
How will blended rates be set? When will they be set? For what time period will these rates
be in place? How will they be adjusted?
Who will have case management authority to move clients from one level within the
continuum to another?
Will providers have the ability to refuse referrals they deem inappropriate for the program?
Said slightly differently: how will the insurance risk, defined as the cost of care associated with the client
over time, irrespective of services utilized, be managed? We understand that there is no single rate or
set of rates being proposed for this new service. Instead the Division is advancing a formulaic approach
for developing unique rates based upon case mix. Without answers to the questions above, it is not
possible to fully evaluate the adequacy of the proposed rate development formula at this time.
That being said, we do want to make a few recommendations based on our conjectures:
a. Benchmark salaries for Community Warp, GH1 Skinny, and GH2 Skinny:
 Management (UFR Codes 101, 102 and 103) – Same recommendation as made for
Group Home and STARR.
 Social Worker LICSW (UFR Code 108) – Same recommendation as made for Group
Home and STARR
 Clinical Care Manager (MA) (UFR Code 131) – Same recommendation as made for
Group Home and STARR
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Providers’ Council
Testimony on 114.4 CMR 13.00
February 21, 2012

Direct Care Staff (UFR Codes 133, 134, 135 and 136) – For GH1 Skinny and GH2
Skinny - Same recommendation as made for Group Home and STARR.
b.
Relief Assumptions: Same recommendation as made for Group Home and STARR.
c.
Fringe and Taxes rate of 23.42 percent. Same recommendation as made for Group Home
and STARR.
d.
Staffing/Ratios/Positions: We strongly recommend not reducing the Direct Care Staff from
the FTEs proposed for Group Home Intensive 1:3 and Group Home 1:4. The sample
blended rate shows 12 youth in a Group Home placement. The same staffing pattern is
needed, for example, for 10 youth as for 12 youth. Further, we previously described the
significant change in the treatment challenges presented by youth referred to Group
Homes. Our recommendation for direct care staff is the same we made for Group Home
and STARRs: that is, 16.8 for GH1 Skinny and GH2 Skinny.
Conclusion
We realize in this major system transformation that there may be issues that are overlooked or
confusing. Our intent in this testimony is provide you a more detailed analysis to help minimize harm to
our clients and to the provider network, while building the system the Commonwealth’s residents
deserve. We are convinced that all of the essential stakeholders are driven toward developing the best
system for meeting our objectives. It is from that perspective that we respectfully urge your
consideration of our recommendations and reexamine these rates before adopting your proposal for
Payments for Youth Intermediate-Term Stabilization Services. We feel the issues raised by our testimony
and by other associations and community provider organizations must be successfully resolved.
In the interim, we urge you to prepare revised rates that incorporate the directives of Chapter 257 to
provide proper funding for programs that is reasonable and adequate. There is also a need to provide
proper funding to ensure programs meet safety and quality standards, and we would like to see this
explicitly factored into the proposed rate.
We also support the testimony provided to you by our partners, the Association of Behavioral
Healthcare and the Children’s League of Massachusetts. We share many of these organizations
thoughtful questions and concerns. We thank you for your time, and we appreciate your thoughtful
consideration of our testimony.
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