Submission to the Government of Canada on the Canada Disability Benefit Draft Regulations

September 23, 2024

Gavel resting on a blockMarch of Dimes Canada (MODC) has responded to the Government of Canada’s consultation on the Canada Disability Benefit (CDB) draft regulations. 

We also asked the government to keep its promise of involving people with disabilities in policy decisions and to stay true to the principle "nothing about us without us."

To inform our submission, we gathered feedback from:
  • Our report with Prosper Canada called “Benefit Without Barriers
  • Our Disability Advocacy Network
  • Four online focus groups in August 2024 with 24 participants, including people with disabilities, allies, and family members
Listed below are the top challenges we identified that people with disabilities will face in getting the CDB. We also shared recommendations on how to address each challenge.


1.  Barriers to accessing the benefit
Many people with disabilities don’t have the Disability Tax Credit (DTC), which is currently required to get the CDB. 
Reasons for not having the DTC include high application costs, low awareness of the credit, and lack of access to knowledgeable healthcare providers who are either capable or willing to fill out the necessary forms.

Recommendations:
  • Make the DTC application easier to access and provide better resources for healthcare providers.
  • Explore other methods to verify disability status, like provincial and territorial disability benefits.

2.  Need for CDB awareness and outreach
Many people with disabilities don’t know about the CDB, such as people who are homeless, people with intellectual disabilities, and people who face language barriers.

Recommendations:
  • Launch a national campaign and partner with community organizations to raise awareness about the CDB.
  • Create resources on how to apply for the CDB using simple language and share with community groups and social services.

3.  Benefit amount too low
The proposed benefit amount of a maximum of $200 a month isn’t enough to lift people with disabilities out of poverty. People shared how living on a low income affects their ability to afford basic needs, such as food, medical care, and housing.

Recommendations:
  • Increase the benefit amount to help cover the current cost of living and the extra expenses of living with a disability.

4.  Income assessment problems
The proposed CDB considers the combined income of people with disabilities and their partners. This discourages relationships and can lead to financial dependence or abuse.

Recommendations:
  • Base income eligibility on individual income – not household income – to allow people with disabilities more financial independence.
  • Consider the unique challenges women with disabilities still face today.

5.  Income thresholds and working income exemptions are too low
The income limits for receiving the full CDB are too low. This means many people who need the benefit may not qualify. Also, people will lose the benefit quickly if they start working because the working exemption amounts are too low.

Recommendations:
  • Raise income thresholds and working income exemptions to reflect the current cost of living and the extra expenses of having a disability.

6.  Feeling unheard
Participants in the focus groups felt that the Government of Canada isn’t listening to their feedback and applying it to their decisions. They believe the draft regulations don’t reflect the feedback they provided to the government.

Recommendations:
  • The government should take the disability community’s input seriously and make real changes based on their feedback.

Click here to read March of Dimes Canada's full submission to the Government of Canada, on the CDB draft regulations.