August 10, 2023
The House of Commons Standing Committee on Finance invited individuals and organizations to participate in its annual pre-budget consultations process in summer 2023. The Committee will table a report on these consultations in advance of the 2024 federal budget.
As a contracted agency and key stakeholder in delivering an array of services for people living with disabilities and their families, March of Dimes Canada was pleased to present its Pre-Budget Submission for fiscal year 2024-25.
Recommendations:
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Recommendation 1: That the federal government undertake an inclusive, well-funded co-creation process to develop Bill C-22 regulations, resulting in the policy and infrastructure for a barrier-free Canada Disability Benefit.
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Recommendation 2: That the federal government invest in equitable, accessible employment opportunities for people with disabilities by increasing federal funding for employment services.
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Recommendation 3: That the federal government develop a program which provides people with disabilities the means to modify their homes and/or vehicles to facilitate independence and community-dwelling.
Recommendation 1: Co-Creating a Barrier-Free Canada Disability Benefit
People with disabilities are twice as likely than those without disabilities to live in poverty and make up 41% of low-income earners.1 With the goal of ending disability poverty in Canada, March of Dimes Canada applauds the recent passage of Bill C-22, the Canada Disability Benefit Act. If designed and implemented according to principles of equity, accessibility and inclusion, the Canada Disability Benefit (CDB) will make a major contribution to lifting people with disabilities out of poverty and toward true financial security and independence.
a) CDB Regulatory Process
With the CDB’s framework legislation now solidified in law,
it is crucial that the federal government, with leadership from the Minister of Diversity, Inclusion, and Persons with Disabilities, invests in a robust co-creation process, living up to the commitment as required in the legislation to co-create the CDB regulations with people with disabilities.
In 2022, March of Dimes Canada partnered with Prosper Canada to host a co-creation workshop with individuals, allies and stakeholders (alongside federal government observers from Employment and Social Development Canada, the Canada Revenue Agency (CRA) and Department of Finance) to co-develop principles to guide the creation of a barrier-free CDB. We further validated and refined the findings through focus groups with 70 individuals with lived and professional expertise. The resulting Benefit without Barriers report delivers advice from the disability community to build a model for delivering benefits to a world-class standard of accessibility.2
When accessing current disability benefits, we found that applicants feel mistrusted and disrespected as they struggle with intersecting barriers and onerous processes. These challenges are further substantiated by the CRA’s Disability Advisory Committee and the Standing Senate Committee on Social Affairs, Science and Technology regarding the Disability Tax Credit and Registered Disability Savings Plan.3
To avoid replicating the shortcomings of existing disability benefits, the principle of “Nothing About Us Without Us” must guide the CDB regulatory process, with people with disabilities engaged each step of the way. The plan released on July 24, 2023, does not reflect the commitment to co-creation. Instead, it merely outlines the bare minimum requirements for regulations from the Cabinet Regulations Directive and the Treasury Board Directive. It is our expectation that a true co-creation process will:
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Be clearly communicated to the disability community to ensure a broad range of individuals learn how to participate;
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Be executed in a barrier-free way, enabling participation from people with varying lived experiences of disability, keeping intersectionality at the forefront, and ensuring diverse and hard-to-reach communities have been meaningfully included before concluding the process; and
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Go beyond merely consulting with stakeholders to truly co-create the regulations, with people with disabilities at the decision-making table.
Not implementing these principles will put at risk our collective ability to confirm that the CDB regulations have been co-created with people with disabilities. Per the enabling legislation, Parliament must ensure that the Minister’s six-month report on co-creation progress is completed in spring 2024.Further, through the regulatory process, it is essential that investments are made to ensure that there are no barriers for CDB applicants and recipients, as required under section 11(1)(f) of the enabling legislation.
We recommend that the Minister ensure that the regulations guiding the CDB application and administration are designed according to person-centred accessibility standards.
In addition to “Nothing About Us Without Us,” guiding principles should include:
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Do No Harm: The government must assess all design and administrative options for potential risks to applicants and beneficiaries.
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Ensure Equitable Access: The CDB must be designed for those who are hardest to reach, and offer multiple formats and channels of communication, application, and support for people with diverse disabilities.
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Foster Dignity: Communication about the CDB should centre the positive contributions people with disabilities can make to society with the right supports in place.
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Minimize Burden: To maximize CDB uptake and retention, the government must simplify processes and ensure support is available to those who need it at each step along the way.
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Foster Trust and Agency: All administrative processes should be fully accessible and all program personnel should be trained to meet the highest standard for accessibility in how they communicate, interact with, and support program applicants and recipients.
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Be Timely and Responsive: The CDB must be launched as soon as possible and the government must build in responsiveness for recipients’ changing circumstances.
An approach to CDB administration rooted in these principles would be meaningful and positive step forward in planning how people with disabilities interact with the system that provides their income.
b) Community Action Planning
The federal government cannot achieve the CDB’s ambitious goal of ending disability poverty alone. The involvement of intermediaries, such as community organizations, service providers and advocacy groups, will be critical in reaching the most barriered people with disabilities. A true partnership between people with disabilities, government, and the stakeholder community is needed.
To this end, March of Dimes Canada recommends that, with the leadership of the Minister of Diversity, Inclusion, and Persons with Disabilities, a $200,000 investment is made in a Summit event in 2024, to bring together stakeholders and government to action plan for CDB success.
Convened by March of Dimes Canada and partners, and deeply informed by the experience of people with disabilities, this Summit would aim to achieve consensus on common goals and develop an Action Plan to co-create policy and systems related to CDB implementation.
Timed to align with Bill C-22 regulations development processes, the Summit will produce immediately actionable solutions and commitments on key goals, including preparing eligible people with disabilities to qualify to receive the CDB, maximizing equitable access to the CDB, providing timely and relevant financial literacy/empowerment services, and considering a potential framework for a national benefit uptake strategy.
c) Funding the CDB
As underscored by the principle of “Be timely and responsive” above, time is of the essence. People with disabilities in Canada continue to struggle to afford the necessities. With the regulatory process unfolding over 18 months, CDB payments are expected to begin flowing in late 2024 or early 2025. Any further delay in implementation would be unconscionable.
March of Dimes Canada requests that the federal government, with leadership from the Minister of Finance and the Minister of Diversity, Inclusion, and Persons with Disabilities, budget to begin CDB payments in fiscal year 2024-25.
While further details about amount and eligibility must be determined through the co-created regulations, generally, payments must be adequate to ensure that recipients are lifted above the poverty line and can address the increased cost of living with a disability.
Further, as the regulations are developed, March of Dimes Canada requests the Minister and Cabinet work in partnership with their provincial and territorial counterparts to ensure all relevant federal, provincial and territorial programs are successfully harmonized with the CDB. In addition, the CDB must be exempt income (like the Canada Child Benefit) to ensure no impact on recipients’ eligibility for existing programs.
Prior to CDB implementation, one measure that could have immediate and meaningful impact for low-income people with disabilities is the transformation of the Canada Workers Benefit into the Canada Working-Age Supplement, as recommended by Community Food Centres Canada. Removing the requirement for attachment to the labour market, as well as removing the minimum earnings requirement for people with disabilities, would greatly increase the impact of this federal tax credit.4
Recommendation 2: Employment services for people with disabilities
An important piece of the financial security puzzle for many people with disabilities is access to inclusive, accessible and meaningful employment. Yet only 59 per cent of working-aged people with disabilities are employed, compared to 80 per cent of those without disabilities.5
March of Dimes Canada recommends that the federal government, with leadership from the Minister of Diversity, Inclusion, and Persons with Disabilities, and support from the Minister of Labour and Seniors,
build upon recent investments in federally funded employment services for people with disabilities to ensure equitable, inclusive access to employment.
Investments in employment programs for people with disabilities should be diversified, offering multiple types of support for jobseekers to find employment based on their unique, individualized needs. For example, at March of Dimes Canada, we increasingly see the need for specialized employment supports for jobseekers with disabilities to access employment in a tech-enabled economy. Supporting jobseekers to succeed in tech-enabled roles requires a specialized approach that diverges from traditional job readiness programs. Access to devices, internet and transportation can all pose barriers for jobseekers with disabilities and must be addressed via employment programs.
Recommendation 3: Accessible home and vehicle modifications
March of Dimes Canada understands the challenges people face every day in trying to remain safe and independent in their own homes and communities. A 2021 survey found that while 78 per cent of Canadians want to age in their current homes, just 26 per cent predict they’ll be able to do so.6
For this reason, March of Dimes Canada recommends that the federal government, with leadership from the Minister of Labour and Seniors and supported by the Minister of Diversity, Inclusion, and Persons with Disabilities and the Minister of Families, Children and Social Development,
invest in the development of a program which provides people with disabilities of all ages with grants to modify their homes and/or vehicles.
A federal home and vehicle modifications program would make an immediate and escalating impact in ensuring people with disabilities of all ages can be independent, participate meaningfully in their communities, and age in place. March of Dimes Canada has more than twenty years’ experience partnering with the government of Ontario on the successful Home and Vehicle Modification Program.
We propose that piloting a similar program in lesser-served jurisdictions would support the Minister of Labour and Seniors’ mandate to work with community-based organizations to help provide practical support to low-income and otherwise vulnerable seniors.7
