September 29, 2021
The Government of Canada is developing the first-ever Disability Inclusion Action Plan to advance equity and inclusion for people with disabilities across the country. The Action Plan will focus on reducing poverty, employment access, creating a barrier-free Canada, making it easier to access federal programs and services, and fostering a culture of inclusion. In September 2021, the Government was seeking public feedback to help develop the Action Plan.
As a leading national charity committed to championing equity, empowering ability, and creating real change, March of Dimes Canada submitted the following response to inform the development of the Disability Inclusion Action Plan.
Recommendations for the Disability Inclusion Action Plan
Background
March of Dimes of Canada (MODC) is pleased to provide input on the development of the Government of Canada’s Disability Inclusion Action Plan (DIAP). We agree that broad-based, concerted action is required to address systemic inequalities for people with disabilities in Canada and welcomes the first federal action plan focused on this issue. In developing the DIAP, we applaud Employment and Social Development Canada (ESDC)’s commitment to consult broadly with individuals with lived experience of disability and the organizations that serve them.
This submission was developed in consultation with staff from across our organization, who provided expertise based on their experiences delivering community-based programs and services to people with disabilities across Canada.
Pillar 1: Financial Security
For far too long, living with a disability in Canada has meant living in poverty for thousands of Canadians. MODC is very optimistic about the potential for the proposed Canada Disability Benefit to lift Canadians with disabilities out of poverty, if designed and implemented well. We commend ESDC’s work to move this pillar of the DIAP forward. MODC is undertaking a key stakeholder role in the design and implementation of the application and administration of the Canada Disability Benefit.
Beyond the Canada Disability Benefit, priority actions that could most improve the financial security of people with disability include:
- Better access to existing government supports and services: Canada’s disjointed, fragmented system of disability supports and programs results in low levels of awareness about what is available and perpetuates barriers to access. Streamlining and simplifying access – or making access automatic based on a specific trigger or single application – would not only improve the user experience for people with disabilities but also increase the uptake of existing programs.
- Measures to help address costs associated with living with a disability: The cost of living for people with disabilities is significantly higher than for able-bodied Canadians. While programs exist to address disability-specific costs like assistive and mobility devices or home and vehicle modifications, in many cases, individuals need to pay upfront first, or must pay out-of-pocket for a portion of the expense. Funding for programs that cover these costs in full is needed. In addition, person-directed funding is available in some regions of the country, but not all, and is an important intervention to alleviate the true cost of living with a disability.
- Funding for community organizations: One of the barriers to accessing existing programs and supports is long wait times due to the capacity of community-based organizations. At the minimum, funding for these organizations should increase in line with inflation, enabling them to continue offering the same level of services and programs year over year. While typically under provincial/territorial jurisdiction, federal funds could be allocated to support the operations of community-based organizations, through Budget allocation/appropriation mechanisms such as direct grants, e.g. the CDB stakeholder engagement funds or through funding bodies such as foundations, societies and associations.
When designing actions to improve financial security, it is important to consider:
- Person-centred supports: Interventions should be tailored to the person’s needs and consider their unique barriers and the true costs of living with their disability in their community.
- Ability to work and receive financial support: People with disabilities should not be penalized for pursuing full-time work or careers in a certain income bracket. These punitive measures do not only include reduced access to financial supports, but also social services and resources. This leads to people with disabilities being back at square one, living below or at the poverty line.
- Broad eligibility and a simple way to self-assess eligibility: Detailed more in the “Pillar 4: A Modern Approach to Disability” section below, it is important to adopt a social model of disability in eligibility and assessments.
Pillar 2: Employment
MODC has a proud history as a leader in employment services for Canadians with disabilities across the country. Based on our deep experience in this area, we believe that the most important actions to help Canadians with disabilities find and maintain employment include:
- Skills and training: It is important to focus on enabling people with disabilities to build their skills in innovative fields, so they are equipped to succeed in the future of work – for example, with greater investment in digital skills for youth and young adults with disabilities. Students with disabilities should be recruited for Work Integrated Learning programs to gain on-the-job experience with innovative employers. This not only benefits young people with disabilities but contributes to Canada’s innovation sector by increasing the diversity of minds working on solutions to the problems of tomorrow.
- Support for obtaining workplace adaptations: It is crucial to ensure that there are enough subsidies and resources available to address any access needs that an employee with a disability may have. The financial cost of accommodating an employee with a disability must not be a barrier for employers. This also includes consideration for enabling attendant care in the workplace through the design of workplaces.
- Supporting youth to transition to employment: The transition from school to work is an important area of focus, but so is access to employment before graduation. Unlike their able-bodied peers, youth with disabilities do not often get the experience of student jobs or summer employment as teens and young adults. As a result, they miss crucial opportunities to build soft skills, and may graduate from postsecondary education without ever working. This creates added barriers to obtaining and succeeding in their first job. Youth with disabilities are also often discouraged from working because they may lose their existing benefits and supports, as discussed under “Pillar 1: Financial Security”.
In addition to the actions identified above, MODC suggests adding some additional actions to support people with disabilities in the workforce:
- Broadening the focus to include entrepreneurship: Beyond employment, fostering and investing in people with disabilities’ entrepreneurship is an important component of building financial independence for the disability community.
- Mentorship: Given their limited employment opportunities, access to mentors contributes to the success of people with disabilities in the workforce. Creating opportunities for people with disabilities to be mentored, particularly by others with disabilities, could be an impactful activity.
- Representation in leadership: As is true for other historically marginalized and underrepresented groups, entry into the workforce or into a particular sector is not enough on its own. To address barriers for people with disabilities at work, we also need to address underrepresentation in board rooms and organizational leadership. Change often starts at the top.
The most important ways to help employers hire and keep persons with disabilities employed include:
- Supports to create inclusive and accessible workplaces: Employers need access to support and training to create and maintain accessible workplaces for people with disabilities. This includes awareness of:
- Equitable recruitment and employment practices
- Offering flexibility in working hours and sick time for employees with disabilities
- How inclusive design in the workplace benefits all employees
- Co-creating inclusive workplaces with persons with disabilities
- Providing workplace accommodations without the onus being on employees with disabilities to disclose detailed personal health information
- Incentives for employers: To spur employers to action, incentives can be created for them to hire more people with disabilities and to make their workplaces and employment practices more equitable. These incentives should be available in every job sector, thus giving people with disabilities options to pursue careers in their desired fields, rather than limiting them to the most readily accessible options. An example could include a financial benefit or tax credit for employers to offer paid sick leave, enabling employees to address any concerns related to their disability without fear of loss of income or employment.
- Awareness of employees with disabilities’ unique value in the workplace: People with disabilities bring unique skillsets, strengths and perspectives to the workplace. In developing supports for employers, it is important to build their awareness that employees with disabilities are incredible assets to their organizations and represent a largely untapped labour market.
Pillar 3: Disability-inclusive Spaces
At MODC, many of our community-based and outreach programs are focused on increasing community participation for the people with disabilities we serve. Too often, there are barriers for people living with disability to be active and engaged members of their communities. It is important to note that the concept of “public spaces” should also include digital spaces, given that so much of our social and professional lives take place online.
The most important actions to help Canadians with disabilities fully participate in their community and workplaces include:
- Creation of more accessible spaces in the community: The minimum standards are often not enough for someone to be a full participant in their community. It is important to incentivize the creation of spaces that use inclusive design principles to prioritize everyone’s ability to fully participate in the space. For example, there may be an accessible washroom stall, but is there space to receive attendant care? Are aisles wide enough to manoeuvre a powerchair, with items on shelved within reach for someone using a seated mobility device? Is additional customer service support provided to enable someone with a disability to shop at a store or to eat at a restaurant?
- Access to technology to work and socialize: With the right assistive technology or devices, many people with disabilities can participate independently in their communities or in the workplace. Unfortunately, both the cost of the technology and access to support in identifying and learning to use the technology can be prohibitive barriers. Additional investment is needed to enable people with disabilities to access the technology they need to work, socialize and engage fully in their communities.
- Increasing public awareness: Inclusive design principles and multiple participation formats must increasingly become the default for public spaces and community activities. This means increasing public awareness of accessibility and inclusivity, and the value of co-creating solutions with persons with disabilities.
Also worth adding under this pillar is the need for investment in more accessible transit options. In order to participate in the community, people need to be able to travel to their destination and back home. The lack of quality, convenient and affordable accessible transportation is a major barrier for people with disabilities across the country. It can prevent them from getting out in the community or getting to school or work on time. We need to look for options to leverage our existing transportation infrastructure (including private solutions like rideshare companies) to better serve people with disabilities, while also investing in new transportation projects to meet their needs.
Pillar 4: A Modern Approach to Disability
At MODC, we recognize that access to sufficient benefits is not the only barrier; too often, the process of navigating and applying for benefits for which one is eligible is often a barrier in and of itself. Accordingly, we welcome the focus on modernizing the definition of disability and simplifying processes for people with disabilities to qualify for Government of Canada disability programs and services.
In developing a new approach to assessing disability, we believe the top priorities should include:
- Moving toward a single-window approach: Repeatedly applying for various government programs, providing the same information over and over, is a significant time and energy drain on people with disabilities and their caregivers, and perpetuates additional barriers to them accessing the supports they are entitled to. The fragmented system also means that many people are not aware of the various supports and benefits available. Moving to a single-window approach, with one application for all federal programs, would be a significant improvement to the user experience for people with disabilities and could mitigate many of the current barriers.
- Less reliance on medical documentation and using the social model of disability: Documentation requirements should be simple, and as much as possible, integrate with the individual’s existing government records. Rather than relying exclusively on medical diagnoses that frame disability as an individualized problem, the social model of disability should be employed to refocus on the barriers a person is experiencing in their life, and what interventions can empower them to succeed. Not only is this a more empowering and person-centred approach, but this approach will remove barriers for people in the “grey zone” who may not have official medical diagnoses, who have poorly understood or invisible disabilities, or who do not fit traditional definitions of disability, but who are experiencing disability-related barriers and would benefit significantly from federal programs.
Importantly, adopting the single-window approach and social model could reconfigure the role of the federal government in relation to people from disabilities, from that of eligibility gatekeeper to that of support provider and service navigator. This modernized approach should mean that benefits are automatically provided if an individual qualifies based on their single application, rather than having them prove their eligibility for each individual program. The focus should not be on reaching a bar of eligibility, but instead on understanding what an individual needs to be successful in their life. This approach is a strategic priority for March of Dimes Canada; we will work closely with the federal government, stakeholders and Canadians with disabilities to work toward an optimal single-window access system.
Speaking to disability assessments specifically, these can be simplified significantly through greater integration and interoperability between various levels of government. For those with medical diagnoses, their provincial or territorial health records already prove their disability and accessibility needs. For others, they may already have records proving their eligibility for disability-related programs through other provincial, territorial or federal ministries. Leveraging the data government already has about an individual is crucial to a modern approach to disability that places the person at the centre.
Overall Feedback
Prioritizing the themes
Reflecting on the four themes, it is clear that all four are crucial to increasing equity and inclusion for people with disabilities across Canada. However, recognizing that the Government of Canada has the stated goal of developing an ambitious plan to improve the lives of people with disabilities, MODC recommends that A Modern Approach to Disability is broadened and prioritized.
Specifically, adopting a true modern approach to disability could go beyond the administration of federal disability programs to include a government-wide adoption of the social model of disability, applying an inclusive design lens to all government policies and programs, and fundamentally reframing the relationship between the federal government and people with disabilities through refocusing on integration between systems rather than eligibility gatekeeping.
In addition, we might consider how Canada’s investments in innovation and technology can complement a modern approach to disability. The Government of Canada is fostering an ecosystem of innovation through investment in the Superclusters. How might Canadian innovations in artificial intelligence, big data and machine learning help the federal government design better supports and programs for people with disabilities and capture longitudinal data on interventions that work?
By adopting a truly modern approach to disability, the DIAP could cement Canada as a global leader in disability rights.
Addressing gaps
While the themes outlined are quite comprehensive, there are a few gaps to be considered. MODC recommends that the following topics are included in the DIAP:
- Transition planning and children and youth with disabilities: While MODC appreciates that the DIAP is focused on working-age adults to address current gaps for this population, we hope that a complementary plan focused on children and youth with disabilities is forthcoming. A better start for children and youth with disabilities sets them up for success and, to some extent, reduces the demand for services and supports as they age into adulthood. Planning for life stage transitions is an important component of building a person with disabilities’ independence. The DIAP should include consideration for the supports people with disabilities need as they transition between life stages, particularly as it relates to their access to various government programs and supports.
- Support for families and caregivers: While people with disabilities should be placed at the centre, it is important to consider their broader support network, including families and caregivers. In recognition of the significance of unpaid care work, each pillar of the DIAP should include consideration of the needs of caregivers. For example, caregivers may need specific financial supports or employment accommodations due to their responsibilities providing
