Founded over 70 years ago, March of Dimes Canada (MODC) is a national charity committed to championing equity, empowering ability, and creating real change that will help people living with disabilities across the country unlock the richness of their lives. As a leading service provider, resource, and advocate, we are paving the way for people living with disabilities to experience full and meaningful lives in an inclusive world.
The realization of the CDB remains a top priority and its urgency persists especially with the increasing cost of living. MODC remains committed to helping advance the CDB to the finish line and ensure that the design of the benefit is deeply informed by voices of the very people who will receive it.
Recommendation 1: More community engagement to help inform the Canada Disability Benefit regulations.
The 2023-24 federal budget allocated $21.5 million for Employment and Social Development Canada (ESDC) to continue work on the future delivery of the CDB, including engagement with the disability community and provinces and territories on the regulatory process1. However, it is unclear how much funding was devoted to public engagement beyond several roundtables and an online engagement in late 2023. During the legislative process, the disability community supported Bill C-222 as a framework legislation on the basis that a meaningful collaborative process would follow.
Our first recommendation echoes the need to ensure that people with disabilities are deeply and widely involved in informing the design and details of the CDB. We ask that the following funding is set aside for the Office of Disability Issues to coordinate and execute:
a. $350,000 to help organize up to 70 in-person micro-engagement sessions with 8-10 participants each.
This proposal provides up to $3,000 of funding per session (up to $210,000 in total) for participant honoraria, staffing support, accommodations, refreshments, and child care as needed, in a process modeled on the current micro-grants included in the Community Volunteer Income Tax Program (CVITP). Remaining funds (up to $140,000) would support community efforts to identify and help organize community engagement sessions, collect feedback and perform analysis, and the preparation of a report summarizing the themes shared. We propose that the micro engagements occur after draft CDB regulations are published in Part I of the Canada Gazette.
The purpose of the micro-engagements is to reach the hardest-to-reach who are not engaged in the current traditional consultative process. Based on a common discussion guide developed by the disability community, the micro-engagement sessions would resemble a roundtable or focus group and would be hosted by community organizations with their respective clients or services users.
Notably, these sessions would focus on collecting feedback including cost of disability, legal capacity issues, accessibility processes and appeals, and further explore intersectionality issues among people living with disabilities. The micro-engagements are an opportunity to raise awareness - particularly among hard-to-reach communities- about the forthcoming CDB, the Disability Tax Credit (DTC), the RDSP, and the importance of tax filing.
b. $200,000 to help fund a community-organized 3-day CDB Summit to bring the disability community and government together to create an Action Plan to support people with disabilities and prepare them to receive the CDB upon implementation.
Proposed to occur concurrently with micro-engagements, the CDB Summit is an opportunity for the disability community (organizations, non-profit and grassroots, as well as advocates and people with disabilities) to come together with government to create an Action Plan that ensures the success of the CDB on “day one”. The CDB Summit would focus on how the community and government can work together to raise awareness, prepare, and support people with disabilities to receive the CDB once implemented.
We believe that investing in these engagements will enable more people with disabilities to voice their thoughts and concerns and result in valuable feedback for the federal government to consider as they design the forthcoming CDB. It will also demonstrate government’s commitment to “Nothing about us, without us”.
Recommendation 2: Fund the Canada Disability Benefit and begin delivery by January 1, 2025.
MODC is aligned with the disability community on the urgent need to include funding in the 2024-25 federal budget that begins delivery of the CDB no later than January 1, 2025. The amount of the CDB must lift recipients out of poverty and address the cost of disability:
Current Income3 + CDB = Canada’s Official Poverty Line4 + 30% Cost of disability
By funding the CDB in the upcoming budget, the federal government will acknowledge the financial hardship faced by working-age people with disabilities. Waiting any longer to introduce funding for monthly cash payments and/or only making the DTC refundable is not acceptable for people with disabilities living in financial crisis. There must be a light at the end of the tunnel.
CDB program funding must include the means to establish administrative systems that put the needs of people with disabilities first and training for front-line service staff to ensure positive obligation and person-centered service delivery. Person-centred service delivery includes ensuring that applicants for statutory entitlements, such as the DTC and CDB, are not required to pay out-of-pocket to complete documents required to be eligible for respective benefits. At the same time, we understand that the most expedient method for accessing the CDB will be to a) be in receipt of the DTC, and b) file a most recent tax return. While programs such as the CVITP are in place to support free tax filing, regulated health professionals often charge patients a fee to complete DTC applications. We therefore recommend that the federal government reimburse relevant regulated health professionals5 up to $150 to complete DTC-related forms.
Private insurance providers currently often reduce payable disability benefits by the amount of federal supplemental benefits which the insurer has determined as payable to beneficiaries – regardless of whether the beneficiary is in receipt of the federal benefit to not. To avoid private insurance clawing back the CDB, we ask the federal government enter a Memorandum of Understanding (MoU) with the Canadian Life & Health Insurance Association (CLHIA) requiring all private insurance providers in Canada categorize the CDB as a supplemental benefit, therefore with no impact on the insurance providers' determination of the eligible applicant's private insurance income benefits.
It is imperative that the federal government fulfills its commitment to categorizing the CDB as supplemental income in regulations, much like the Canada Child Benefit (CCB) and the Canada Workers Benefit (CWB). This impact of this categorization means that the CDB will not negatively affect, or reduce, recipients’ existing social benefits. To achieve this, we urge the federal government to continue its work with provincial and territorial governments in 2024 to ensure there are no claw backs from other benefits such as dental or prescription drug coverage, housing and transportation supports, and other funded benefits, programs, and services once the CDB is implemented. We encourage the federal government to require all levels of government to add the CDB to policy directives on exempt income for benefit determination, much like the CCB, CWB and interim Canada Dental Benefit (CDP).
Recommendation 3: Support a benefit take-up strategy to ensure all who are eligible receive the benefits they are entitled to.
Services provided by community-led organizations are fundamental to raise awareness of government benefits and help with application processes. MODC’s front-line staff report that benefit take-up is worsening, with few resources to refer to. Currently, our services users are referred to person-centred organizations such as Disability Alliance BC6 - one of the few such resources in Canada. Although there are currently services in the community that support benefit form filling and tax filling, increasing waitlists, fees for support, and limited no-cost resources are making it more difficult to access statutory entitlements in a timely manner – or at all.
This recommendation emphasizes the need to address benefit accessibility issues by funding community organizations across Canada to develop or expand their capacity to support those in need, including people with disabilities, in accessing statutory entitlements available to them. Scotland’s Social Security Act is an example that enshrines the principle to support all who are eligible to take-up the financial support available to them7. With the introduction of the CDB, we are concerned with the current capacity of community organizations to offer free support and raise awareness of statutory entitlements and support people with disabilities through the application process.
The Disability Tax Credit (DTC), for example, has a low take-up with an estimated utilisation at around 40 per cent of working-age adults with qualifying disabilities8. We acknowledge and support the Canada Revenue Agency’s work to make DTC take-up easier-to-access for both applicants and health professionals. However, ongoing challenges such as lack of access to doctors and qualified health professionals, additional fees for form-filling (see Recommendation 2), and the misconception that not paying taxes due to low income renders the DTC as irrelevant.
Certainly, low take-up of the DTC results in low take-up of the Registered Disability Savings Plans (RDSP)9, which also suffers from low awareness and misconceptions. Tax filing is another area of concern. As we know, tax filling is essential even if the main source of income is under the tax threshold, i.e. public disability income support. Up to 12 per cent of people in Canada do not complete tax returns, most of whom have low-incomes, therefore missing cash benefits for which they are eligible10. The need for more community support is on the rise and it is essential to support organizations to expand their services. A national benefit take-up strategy would address this issue and be part of the overall solution to ending poverty in Canada.
Recommendation 4: Fund more Skills for Success programs for people with disabilities.
This recommendation focusses on growing the Skills for Success and Sectoral Workforce Solutions programs to support people with disabilities in accessing digital skills programs to increase participation in tech and tech-enabled employment. The empowerment that such programs provide for people with disabilities is invaluable.
At MODC, we have witnessed this firsthand our
SkillingUp program. The success of the program resulted in attracting funding through corporate and government partnerships to provide more than 1,100 people with disabilities with in-demand digital skills. There is certainly room to grow and expand programs that offer digital skills for people with disabilities and increase their opportunities to obtain future-proof employment – like SkillingUp.
When announcing the government of Canada’s investment in SkillingUp through DIGITAL, Hon. Kamal Khera noted, “Digital talent is needed now more than ever. With this project and the support of over $600,000 from the government of Canada, March of Dimes Canada is helping persons with disabilities access the necessary training and support that enhance digital skills through skills training, mentorship, and career development”11.
Recommendation 5: Fund Home & Vehicle Modification programs across Canada to support people with disabilities and the aging population remain in their homes and communities, promote independence, and reduce housing pressures.
This recommendation highlights the need for federal investment in direct grants for Home and Vehicle Modifications programs to support people with disabilities and seniors to remain independent and in their own homes. We thank the government of Canada for last year’s federal refundable Multigenerational Home Renovation Tax Credit, which provides up to $7,500 in support for constructing a secondary suite for a senior or an adult with a disability12. However, this is a tax credit that will support people with upfront financial means to renovate or construct a home addition and to wait up to a year to receive a tax credit.
Our recommendation focuses on people with disabilities and or seniors who do not have the upfront financial means to cover such projects, but who nonetheless require modifications to return to or remain in their own homes and communities, regain or maintain independence and ensure quality of life. These types of inexpensive modifications can bring people home from costly institutional care, facilitate employment and full participation in family and community life, and reduce growing pressures on healthcare systems, long-term care systems, and housing in Canada.
MODC has administered Ontario’s Home & Vehicle Modification Program (HVMP) in Ontario since 199113, with growing success. With just $15M in direct grants to Ontarians in 2022-23, our program has served over 1,500 people with disabilities and seniors in the province. This is an 84 per cent increase in people served with a 50 per cent increase in funding. In 2023, the Manitoba government announced that MODC will administer a $1.5M home modifications program for seniors. Demand continues to grow, and we urge that the federal government consider investing in a federal program to support home and vehicle modifications for low-income people with disabilities of all ages across Canada.
3 Current income must be defined as line 15000 income, excluding non-taxable federal, provincial or territorial income such as the Climate Action Incentive Payment, the Canada Child Benefit, Canada Workers Benefit, etc.
4 For a single person, as defined by Opportunity for All – Canada’s First Poverty Reduction Strategy.
5 Physicians and Nurse Practitioners are permitted to certify all impairments eligible for the DTC.
Other regulated health professionals including Optometrists, Audiologists, Occupational Therapists, Physiotherapists, Psychologists, and Speech-Language Pathologists are permitted to certify only those impairments for which they are able to provide treatment.
