The CDB, as previously budgeted, will not be implemented according to principles of inclusion, equity and accessibility, nor will it provide people with disabilities a basic income to access the benefits of living in Canadian society. The Office of Disability Issues, in a response to a HUMA inquiryiv, reports that at currently funding levels, the CDB will only lift 25,000 people with disabilities in Canada out of poverty – out of over 1.2 million people. This is not to be celebrated.
Time is of the essence, as millions of people with disabilities continue to struggle to afford the necessities, especially as inflation creates additional financial pressures. With current federal, provincial, and territorial disability income supports languishing well below the poverty line, the CDB is an essential benefit. In our 2024-25 Pre-Budget Submissionv, March of Dimes Canada requested that the CDB be funded in accordance with the following formula, widely accepted in the disability community:
Current Incomevi + CDB = Canada’s Official Poverty Linevii + 30 per cent Cost of disability
When determining income level, the government, in draft regulations, is acting within existing ableist structures in basing CDB eligibility on household income instead of individual income – despite broad calls from stakeholders and people with disabilities to choose the latter, and Canada’s commitments under the UN Convention on the Rights of Persons with Disabilities to ensure the dignity and autonomy of any person with a disability. Choosing a spousal income-base elevates dependency and removes choices because the CDB will begin to phase out if a spouse has a relatively higher (yet still low) income of over $32,500. With already immorally-low CPP-D and provincial/territorial disability income support maximums that keep people with disabilities living in entrenched poverty, removing access to the CDB at any spousal income level is unacceptable, perpetuating a charity model of disability and runs contrary to Canada’s international commitments and obligations.
Further, March of Dimes Canada encourages the Minister and Cabinet to ensure provincial and territorial programs are successfully harmonized with the CDB, and that employment is not disincentivized for people who rely on income support programs as they transition back to work. In addition, the CDB must be categorized as non-taxable income (like the Canada Child Benefit), mitigating impacts on recipients’ eligibility for existing programs and other downstream impacts. March of Dimes Canada welcomed the announcement made in the 2024 fall economic statement that the federal government did plan to exclude the CDB as income under the Income Tax Act. However, with the proroguing of parliament earlier this year, this has not yet been legislated. We strongly recommend that the Minister and Cabinet make the same commitment when parliament resumes.
Optimized Infrastructure and Interface Processes for Federal Disability Benefits
Accompanying the design of this new federal benefit, it is crucial that investments are made to ensure that there are no barriers to access for eligible recipients. During the course of decades of work with people with disabilities, and in results from our Fall 2020 survey and our Benefit Without Barriers report, March of Dimes Canada has learned that recipients continue to face barriers in accessing the federal disability benefits for which they are eligible.
The barriers to federal disability benefits are well documented, as detailed by the Canada Revenue Agency’s Disability Advisory Committee regarding the Disability Tax Credit (DTC) and Registered Disability Savings Plan (RDSP).viii For example, it is estimated that only 40 per cent of eligible recipients utilize the DTC.ix
March of Dimes Canada applauds the federal government’s commitment to providing a highest standard of service delivery and access for all government programs, services and benefits, through “undertaking a comprehensive review of access to federal disability programs.”x March of Dimes Canada encourages the Minister of Employment & Workforce Development, the Minister of National Revenue, and the Minister of Citizen Services to consult broadly with stakeholders to determine a path forward.
We recommend the Ministers endeavour to ensure the administration, user access point, and interface for the new CDB is rooted in a simplified, one window approach with a world-class standard of accessibility. This approach would meaningfully and positively impact how people with disabilities interact with the system that provides their income, eliminating what is currently a significant stress for a community that needs their government to act as a compassionate and helpful facilitator.
At minimum, if the DTC remains the gateway for people to apply for and access the CDB, we recommend that the Ministers ensure that health care providers who complete the necessary documentation to support DTC applications are compensated directly by the government (rather than passing costs on to applicants). We applaud the government for allocating funds for this purpose in the 2024-25 Budget; however, the proroguing of parliament has hampered the implementation of the associated program. We recommend that this item is prioritized when parliament resumes to ensure broad take-up of the DTC and, in turn, the Canada Disability Benefit and other important financial security programs for people with disabilities.