The Commonwealth of Massachusetts
Executive Office of Health and Human Services
Department of Public Health
250 Washington Street, Boston, MA 02108-4619
MAURA T. HEALEY KATHLEEN E. WALSH
Governor Secretary
KIMBERLEY DRISCOLL ROBERT GOLDSTEIN, MD, PhD
Lieutenant Governor Commissioner
Tel: 617-624-6000
www.mass.gov/dph
December 2, 2024
Maura Healey, Governor
Massachusetts State House, Office of the Governor
Boston, MA 02133
Michael D. Hurley, Clerk
Massachusetts State House, Room 335
Boston, MA 02133
Steven T. James, Clerk
Massachusetts State House, Room 145
Boston, MA 02133
RE: Community Violence Prevention Task Force
Dear Governor Healey, Clerk James, and Clerk Hurley,
On behalf of the Community Violence Prevention Task Force (Task Force), established under Section
151 of Chapter 135 of the Acts of 2024, An Act Modernizing Firearm Laws, I am pleased to provide the
following letter summarizing the Task Force’s recommendations. Please accept this letter as the Task
Force’s report.
The Community Violence Prevention Task Force was responsible for reviewing the availability of federal
funding to support community violence prevention (CVP) programs and making recommendations to
maximize federal funding in an equitable manner that supports CVP service delivery across the
Commonwealth. Included in its charge was the requirement that the Task Force consider three distinct
topics related to supporting CVP programming through federal funding:
i. whether federal funds may be applied equitably to CVP programs, in clinical and nonclinical
settings, across geographic regions;
ii. the ability of existing CVP and intervention programs to implement any federal requirements
to be eligible for funding; and
iii. any impact federal funding may have on the service delivery model of violence prevention
services in the Commonwealth.
The Task Force was given until December 2, 2024 to submit its recommendations to the Governor and the
Clerks of the House of Representatives and Senate. Chapter 135 noted that should the Task Force
recommend that the Secretary of Health and Human Services pursue an amendment to the Medicaid state
plan and seek any federal approval necessary to access federal funds to support equitable access to CVP
services, then the Secretary shall pursue such an amendment and shall seek any such federal approval in
accordance with the recommendations and findings of the Task Force.
At this time, after extensive deliberations, the Task Force is not able to recommend that the Secretary of
Health and Human Services pursue an amendment to the Medicaid state plan due to the following
implications related to cost, program model design, and equity:
1. Potential Cost Implications to Providers
Based on guidance from MassHealth and the EOHHS Office of Federal Finance and Revenue, it is
anticipated that development and implementation of a Medicaid reimbursement system would require
significant up-front costs for CVP providers, for which the current state budget does not provide funding.
Some of these costs may be significant and ongoing, including:
• Development or licensing of information technology systems that can verify Medicaid eligibility,
and track and report Medicaid claims-related activity.
• Recruitment, hiring, and training of staff and the development and implementation of processes
to:
o Confirm individuals’ MassHealth eligibility;
o Validate and document that allowable services have been provided;
o Utilize covered codes of payment; and
o Submit claims using covered codes for payment.
• Participating in state and federal audits, as required, which may include additional auditing and
fiscal oversight costs.
In addition, in its deliberations, the Task Force received and reviewed testimony regarding the
experiences of the eight states that have pursued Medicaid programs for CVP work – California,
Colorado, Connecticut, Illinois, Maryland, New York, North Carolina, and Oregon. Despite several years
of effort and cost, these states have received only minimal revenue from Medicaid.
2. Program Model Design Implications
CVP providers have voiced concerns that shifting payment for these services into a Medicaid construct,
thereby requiring providers to submit claims for payment to MassHealth, could substantially alter the
nature of CVP work, requiring significantly more administrative duties and paperwork and potentially
leading to less contact with clients. Utilization of Medicaid rates, instead of existing grant funds to
perform the above referenced tasks may require significant restructuring of existing program plans and
budgets to account for more administrative capacity.
Many existing models for CVP work are evidence-based and deemed effective. Changing how providers
do their work in order to comply with Medicaid requirements could impact the manner in which agencies
operate, potentially impacting the effectiveness of services.
3. Equity Implications
As referenced above, providers may be required to invest significant up-front and continuing costs to
become a Medicaid provider. While larger, more-established organizations may be able to adapt more
easily to the additional administrative and cost requirements, smaller, grass-roots organizations currently
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focusing on CVP work may not have sufficient administrative and staffing resources to meet these
requirements, creating a barrier to their ability to access Medicaid reimbursements. The potential inability
for smaller, grass-roots organizations to commit the resources necessary to become Medicaid providers,
could reduce total CVP resources for the people, neighborhoods, and communities where they are needed
most.
4. Other Considerations
The Task Force further discussed that the Commonwealth of Massachusetts has been a leader in the
nation in this area, often taking advantage of innovative models of service delivery, and should remain
committed to continuously evaluating Medicaid funding for CVP. The Task Force noted that the decision
to pursue Medicaid reimbursement for CVP could be made at any point in the future.
Development of an implementation plan that mitigates the risks listed above, including consideration of
additional funding for upfront and administrative costs, would be necessary in any future exploration of
the use of federal funding for CVP work.
On behalf of the members of the Task Force, we are grateful to the Governor and Legislature for the
opportunity to consider this topic and offer our recommendations.
I would be more than happy to make myself available to offer additional details on the Task Force’s work
and answer any questions you may have.
Sincerely,
Robbie Goldstein, MD, PhD
Commissioner, Department of Public Health
Chair of the Community Violence Prevention Task Force, acting as Secretary Walsh’s designee
Cc: Kathleen E. Walsh, Secretary, Executive Office of Health and Human Services
Karen E. Spilka, Senate President
Ronald J. Mariano, House Speaker
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 Community Violence Prevention Task Force
Legal Authority: Chapter 135 of the Acts of 2024
Section 151
(a) Notwithstanding any general or special law to the contrary, the executive office of health and human
services shall establish a task force to review the availability of federal funding to support community
violence prevention programs and to make recommendations to maximize federal funding in an equitable
manner that supports community violence prevention service delivery across the commonwealth.
The task force shall consist of: the secretary of health and human services or a designee, who shall serve
as chair; the commissioner of public health or a designee; the director of Medicaid or a designee; and 9
persons to be appointed by the secretary of health and human services, 2 of whom shall represent
organizations that have received a grant through the Safe and Successful Youth Initiative, 2 of whom
shall represent recipients of the gun violence prevention grant through the department of public health, 2
of whom shall have lived experience with the impacts of community violence of which at least 1 shall
have received services from a community violence intervention or prevention program, 1 of whom
represents a hospital that currently operates a hospital-based violence prevention program in the
commonwealth, 1 of whom represents a hospital in the commonwealth that does not currently operate a
hospital-based violence prevention program and 1 of whom represents behavioral health care clinicians
with experience providing trauma informed care.
(b) The task force shall consider: (i) whether federal funds may be applied equitably to community
violence prevention programs, in clinical and nonclinical settings, across geographic regions; (ii) the
ability of existing community violence prevention and intervention programs to implement any federal
requirements to be eligible for funding; and (iii) any impact federal funding may have on the service
delivery model of violence prevention services in the commonwealth.
(c) The task force shall submit its recommendations to the governor and the clerks of the house of
representatives and senate not later than December 2, 2024.
(d) If the task force recommends that the secretary of health and human services pursue an amendment to
the Medicaid state plan and seek any federal approval necessary to access federal funds to support
equitable access to community violence prevention services, then the secretary shall pursue such an
amendment and shall seek any such federal approval in accordance with the recommendations and
findings of the task force.
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 Community Violence Prevention Task Force Membership
Member Seat
Robbie Goldstein (Chair) Secretary of Health and Human Services or a
Commissioner, Department of Public Health (DPH) designee
Kevan Barton Representative of behavioral health care
Executive Director, YouthConnect Program, clinicians with experience providing trauma
Boys & Girls Clubs of Boston informed care
Paul Brennan Representative of a hospital in the
Director of EMS and Public Safety, Lawrence Commonwealth that does not currently operate
General Hospital a hospital-based violence prevention program
Clementina Chéry Individual #1 with lived experience with the
Founder, President and CEO, Louis D. Brown Peace impacts of community violence
Institute
Gregg Croteau Representative #1 from an organization that has
CEO, United Teen Equality Center (UTEC) received a grant through the Safe and Successful
Youth Initiative (SSYI)
Thea James Representative of a hospital that currently
Director, Violence Intervention Advocacy Program operates a hospital-based violence prevention
(VIAP), Boston Medical Center program in the Commonwealth
Keesha LaTulippe DPH Commissioner or a designee
Deputy Director, Bureau of Community Health and
Prevention, DPH
Dwight Robson Representative #2 from an organization that has
Executive Vice President of Operations, Roca received a grant through the Safe and Successful
Youth Initiative (SSYI)
Monalisa Smith Individual #2 with lived experience with the
Founder, President, CEO, Mother’s for Justice and impacts of community violence and has
Equality received services from a community violence
intervention or prevention program
Laxmi Tierney Assistant Secretary of Medicaid or a designee
Director of Federal Finance, MassHealth
Danayjah Yassen Representative #1 of recipient of gun violence
Safe Corners, Old Colony YMCA prevention grant through DPH
Vacant Representative #2 of recipient of gun violence
(member stepped down after 2nd meeting) prevention grant through DPH
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 Summary of Task Force Meetings
October 10, 2024
Summary: Oath of office, overview of Open Meeting Law, Conflict of Interest regulations, and
discussion of the Task Force’s charge and future priorities for its work
Members were sworn in and briefed regarding the state’s Open Meeting Law (OML), Conflict of Interest,
and Ethics laws and regulations. After reviewing the Task Force’s enabling legislation included within the
Acts of 2024, members discussed their goals, expectations, and priorities for the Task Force’s work.
October 25, 2024
Summary: Presentation on Medicaid for reimbursement for community violence intervention
programming from the Health Alliance for Violence Intervention (HAVI)
Staff from the Health Alliance for Violence Intervention (HAVI), provided a detailed overview of
utilizing Medicaid reimbursement funding to support community violence prevention (CVP)
programming, summarizing the experiences of the eight states – California, Colorado, Connecticut,
Illinois, Maryland, New York, North Carolina, and Oregon – that have implemented such initiatives.
Members discussed various aspects of the federal funding opportunity and how it might be implemented
in Massachusetts. In their deliberations, members raised various topics, including, rate-setting, equity,
stakeholder engagement, payment mechanisms, documentation, reimbursement timing, state Medicaid
interagency coordination, social determinants of health, and upstream services. It was noted that since the
efforts by other states began in 2021, only minimal, if any, revenue or federal financial participation
(FFP) has been generated to date, despite significant investments and effort on behalf of the states and
implementing partners.
November 1, 2024
Summary: Presentation from MassHealth and the EOHHS Office of Federal Finance and Revenue on
Medicaid reimbursement requirements and potential impacts of utilizing Medicaid funding to support
CVP services in Massachusetts
Representatives from MassHealth and the EOHHS Office of Federal Finance and Revenue provided an
overview of Medicaid reimbursement requirements and the potential impact that utilizing Medicaid
funding to support CVP services might have on programming in Massachusetts. Among the topics
discussed were the process for the state to obtain legal authority for adding CVP as a new Medicaid
service, drawing the distinction between State Plan Amendments (SPA) and 1115 Demonstration
“Waivers;” as well as the process for organizations to enroll as MassHealth providers and the
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requirements that must be met for enrollment. The use of “certified public expenditures” was discussed as
a potential claiming strategy. The experiences of other states were also discussed.
November 8, 2024
Summary: Continued discussion of the federal funding opportunity, as well as the potential impact on
the Safe and Successful Youth Initiative structure
Members continued discussion of the Medicaid funding opportunity, as well as the potential impact on
existing CVP programs such as the Safe and Successful Youth Initiative (SSYI), a youth violence
intervention program serving nearly 2,000 youth annually, operating in 14 Massachusetts cities with the
highest crime and homicide numbers/rates. Members also discussed some of the up-front costs providers
may need to invest to meet Medicaid requirements, including increased staff support, purchase of case
management systems, and potential costs associated with audits.
November 22, 2024
Summary: Review of the draft report and recommendations
Members reviewed a draft of the report, which had been shared prior to the meeting. During the
discussion, members cited multiple factors which influenced their thinking, including the ambiguity about
the federal landscape and specifically the priorities of the incoming federal administration. While a vote
was not taken on the report’s overall recommendation, members noted that there was consensus that it
accurately captured the deliberations of the Task Force and reflected the perspectives of its members.
Note: For additional details on the work of the Task Force, including copies of presentations, resources
reviewed, and approved meeting minutes, please visit the Task Force’s Mass.gov webpage:
https://www.mass.gov/info-details/community-violence-prevention-task-force-meeting-materials
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 Written Comments Received from Members Regarding the Draft