Submission to Minister Piruzza on
Ontario’s Next Five-Year Poverty Reduction Strategy
October 4, 2013
Income Security Advocacy Centre
425 Adelaide Street West, 5th Floor
Toronto, ON M5V 3C1
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The Income Security Advocacy Centre
The Income Security Advocacy Centre (ISAC) is a community legal clinic funded by Legal
Aid Ontario. We have a provincial mandate to improve the income security of people
living in Ontario through test case litigation, policy development, advocacy and
community organizing.
We are governed by an elected Board of Directors that includes members of the lowincome community from across the province, as well as academics, legal experts and
service providers. We work closely with sixty local legal clinics who work every day with
the challenges faced by low-income people relying on Ontario’s income security
programs. We also work in coalition with such advocacy groups and organizations as
Campaign 2000, the ODSP Action Coalition and a range of policy organizations.
Since ISAC opened its doors in 2001, we have advocated for improvements to the
incomes of low-income Ontarians through rate increases to income security programs,
improvements to minimum wages and employment standards, and reform of programs
and benefits systems.
Endorsement of the 25in5 Network for Poverty Reduction’s Submission
ISAC was a founding member of the 25in5 Network for Poverty Reduction and we
continue to support its efforts. We fully endorse the Network’s Five Priorities for Ontario’s
Next Poverty Reduction Strategy (see http://25in5.ca/five-priorities-for-ontarios-nextpoverty-reduction-strategy/).
As a legal clinic with a mandate specific to advance the income security interests of lowincome communities in Ontario, this submission will primarily expand on social
assistance transformation and the issue of secure and livable incomes.
Social Assistance Reform as a “Cornerstone” of Poverty Reduction
We are pleased that the 2013 budget announced that social assistance reform is seen as
a priority for the next poverty reduction strategy. Indeed it was announced as a
“cornerstone”. Income security is a critical aspect of poverty reduction, and social
assistance reform is critical to improving Ontario’s income security programs.
But if the poverty of the people who rely on these programs is to be substantially
addressed, social assistance cannot be reformed in isolation from surrounding programs
or from other critical government services and strategies. An in-depth understanding of
program, service and strategic interactions across ministries is critical. For example:

Spending in social assistance often increases when the income supports available
through surrounding programs are eroded. For example, the relationship between
the erosion of other disability programs, like WSIB and CPP-D, and the growth of
ODSP has been documented by John Stapleton in numerous papers and
presentations that can be shared with government.

Alternatively, spending in social assistance may increase as a result of the success
of other government strategies. For example, successful mental health diversion
programs in the criminal justice system require the availability of adequate income
support and housing. Reducing the incarceration rate of persons with mental health
disabilities is an important objective in which access to ODSP plays a critical role.

Reforms to social assistance that may cause program spending to increase slightly
could create savings in other ministries and advance other policy objectives. For
example, exempting at least 50% of child and spousal support payments would
provide a positive incentive to seeking support rather a coercive one. This could
reduce the pressure on Family Courts and Legal Aid systems, in addition to
reducing conflict between separating or separated parents. Increased cooperation
between separated parents may even mean that MCSS spending does not increase
substantially. Most importantly, children would the benefit from increased incomes.
These are but a few examples that point to the importance of a comprehensive, interministerial approach to social assistance reform. We support the budget announcement
that the reform process be led by the Poverty Reduction Cabinet Committee for this
reason. Leadership from the Cabinet Committee would also reinforce poverty reduction
as a framework and a lens for social assistance reform – in other words, poverty
reduction would become the cornerstone of social assistance reform.
Social Assistance Reform since 2008
ISAC has been advocating for the transformation of social assistance since Ontario
developed its 2008 Poverty Reduction Strategy. We noted then that the current programs
were the legacy of a punitive approach to poverty, and that in their current form would
continue to undermine the success of any poverty reduction strategy. We were pleased
that social assistance reform was included in the 2008 Strategy, but progress on reform
has been limited – and, in fact, several changes have been made to OW and ODSP that
have made the lives of people who rely on these programs more difficult.
Having participated in the Social Assistance Review Advisory Council’s (SARAC) work to
develop terms of reference for a full review, we continue to support its recommendations,
and in particular the need to examine the range of and interactions between income
security programs, and to take a broader, more comprehensive approach to income
supports than a focus on a “welfare model” approach allows.
The final report of the Commission for the Review of Social Assistance in Ontario
contained many important recommendations for improving Ontario Works, but many of its
recommendations on ODSP are highly problematic and indefensible. We believe that this
is at least in part a function of focusing too narrowly on reform within the social
assistance system and not looking for solutions outside of the programs themselves.
The Commission’s work must be understood as one step in the development of
recommendations for change, but not the blueprint for reform.
Rule Changes in Budget 2013
Ontario’s 2013 budget took modest but critical steps towards improving the Ontario
Works program by implementing some of the Commission’s recommendations. The
increase in asset exemptions, the $200 employment income exemption, allowing
$6000/year in gifts, and the additional increase for singles on Ontario Works were
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important steps. They were a signal that government understands where many of the
problems in social assistance lie.
But it is important to recognize that these changes represent long-standing
recommendations from the low-income community and from policy experts; in other
words, they represent a consensus among stakeholders. Indeed, most of the budget
changes were recommended by SARAC in 2010 as short-term rule changes that could
be made prior to reform. They are important improvements, but are not transformative.
Primarily, they help to mitigate the deep poverty that has been a prerequisite to
accessing and remaining eligible for Ontario Works.
However, of deep concern was the differential application of this year’s 1% rate increase
to families receiving ODSP benefits. Unlike Ontario Works recipients, recipients of ODSP
received the extremely modest increase only to the portion of the benefit attributable to
the person with a disability and not his/her spouse or children.
This change appears to stem from the Commission’s recommendation that the spouses
and children of persons with disabilities should not receive benefits greater than those for
dependents of persons on OW. But embedded in this recommendation lie assumptions
that are highly contested and have never been the subject of consultation or supported
by empirical research. Worse still, this recommendation appears to have been
implemented without explicit announcement.
There needs to be a clear understanding – by not only those working on social
assistance reform but also those preparing the next poverty reduction strategy for Ontario
– that the reforms made in the late 1990’s reduced OW benefit rates to punishingly low
and unsafe amounts. The differential in benefit rates between OW and ODSP must be
understood in this context, not in one that implies that ODSP rates have risen beyond
what is needed. Indeed, despite rate increases, ODSP rates have not kept pace with
inflation. No one can afford to be “red-circled” in future rate increases. And it should go
without saying that a poverty reduction framework should ensure that no further cuts be
made to a system, and to Ontarians, that have been starved for decades.
Future Reform Processes
It is critical that further steps on social assistance reform take place in a transparent
manner. Government needs to be clear about the direction it is heading. We have
received mixed messages about government’s response to the Commission’s report – in
one instance government announced an intention to implement the report, while in other
announcements the report has been described as simply a starting point.
If it is the intention of government to use the Commission’s report as a guide or blueprint
for reform, this needs to be stated publicly, and broad public discussion must take place.
The Commission’s review process, while broadly consultative, was focused around two
discussion papers and did not provide the public an opportunity to respond to draft
recommendations. The recommendations, particularly with respect to ODSP, are
sufficiently controversial that they should not proceed without broad public discussion
and, critically, clarification about what their implementation could actually mean for the
people who depend on these programs.
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Approaches to Disability Income Support
The controversy surrounding the Commission’s recommendations for ODSP is not that
they are “right but unpopular”. Instead, the controversy stems from very different and
conflicting approaches to disability income support. As such, thoughtful debate and
discussion are required. And the research that supports the Commission’s
recommendations should be made public. We are aware of research that challenges
assumptions made by the Commissioners that we would be pleased to share with
government.
The Commission’s recommendations with respect to ODSP are transformative, but not
the transformation that was hoped for. We share the Commission’s objective of focusing
on ability instead of disability, but don’t believe that implementation of the Commission’s
recommendations will achieve that objective. Merging OW and ODSP is not the answer.
The Commission’s proposed benefit structure and the route to achieving it will actually
lead to benefit rate cuts for many persons with disabilities. Social inclusion and access to
the labour market are not achieved through putting the incomes of people with disabilities
at risk through conditionality.
We support the rights-based approach of disability advocacy groups that demands
access to the labour market. But the barriers to the labour market run deep, and there are
multiple barriers to competing successfully in the labour market: discrimination from
employers, the absence of necessary accommodations, and the nature of the disability
that may mean less than full-time employment or periods of unemployment. All of these
barriers to earning a living wage in the labour market mean a potential life-long need for
some disability income supports. This requires a specialized approach to the delivery of a
disability income support program.
The Commission’s report does not address the concern most frequently raised by those
with experience of ODSP – the barriers to getting onto the program. These barriers
include the application process and adjudication processes, the demands for medical
evidence that applicants are expected to gather for themselves, and the lack of
assistance to applicants in navigating the complex application process (except for some
highly successful community-driven local projects). It is this very difficulty in accessing
the program that contributes to fears about re-entering the labour market. People will be
more likely to risk entering the labour market if they are given the assurance that
necessary supports will be easily accessible when needed.
Employment Supports and Training and Improving the Labour Market
We support much of what the Commission says about the improvements that are
required to ensure quality employment services and supports for people receiving OW
and ODSP. However, in order for such improvements to make a meaningful difference,
the labour market must be improved. Otherwise, we simply consign people currently
living in poverty on OW or ODSP to a future of poverty from paid employment.
The next Poverty Reduction Strategy must take strong measures to address the
increasing precarity of jobs, below-poverty wages, and employment insecurity. Others
have made numerous recommendations on this aspect of poverty reduction, which we
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support, including instituting a minimum wage that takes full-year full-time workers out of
poverty; increasing employment standards coverage and enforcement; instituting
employment equity legislation; increasing the ability of workers to unionize; creating a
good jobs strategy for Ontario; and instituting a public system of extended medical and
dental supports.
Reduction of the OW and ODSP caseload must not be a poverty reduction strategy
target. There are many ways to reduce the numbers of people receiving assistance that
do not include successful integration into an inclusive labour market that provides a living
wage. Caseload reductions must only be an outcome of good quality supports that
successfully move people into the kinds of jobs that are sustaining and sustainable.
Poverty Reduction and Equity
Ontario’s next poverty reduction strategy must adopt an equity approach. We and others
have highlighted the important recognition contained in the Poverty Reduction Act 2009
to the differential risk of poverty among different groups in Ontario, stemming from the
barriers to full participation in society that are placed in their way, including various forms
of discrimination and racism. This recognition must be coupled with distinct, strategic,
and targeted action.
Different supports and services are needed for different groups to adequately address the
barriers they face and to make headway on poverty by addressing root causes. This is
why we call for an equity approach. Addressing poverty through generic responses that
ignore the differential experience of poverty among different groups in Ontario society is
not only inappropriate but will not be successful.
Poverty Reduction and Austerity
For government to make a serious commitment to poverty reduction, it must abandon its
focus on spending restraint and refocus on investing in Ontarians. Committing to allocate
and/or raise the revenues necessary to make the required investments will be key to
progress on poverty reduction. The next strategy must also identify how much money
government is going to invest in each of its program areas and in what year these
investments will be made.
Countless reports have demonstrated the need for more money, not less, and
investments in the Ontario Child Benefit and other poverty reduction initiatives have
demonstrated the success of an investment approach. Reducing poverty can’t be
accomplished by “doing more with less”. Investing resources is required.
Conclusion
We appreciate the government’s commitment to poverty reduction and the important
progress on reducing child poverty that has been made to date. This next five-year period
is a critical opportunity for government to continue to make progress, to expand the focus
of poverty reduction beyond children, and to be more strategic in its approach. We hope
that our recommendations will assist in achieving these objectives.
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The Honourable Teresa Piruzza MPP
Minister Responsible for Poverty Reduction
14th Floor - 56 Wellesley Street West
Toronto, Ontario M5S 2S3
October 8, 2013
Dear Minister Piruzza:
Please consider this letter an addition to ISAC's submission on the second Poverty
Reduction Strategy for Ontario.
One of the most devastating losses to people receiving social assistance benefits over the
past five years was the elimination of the Community Start-Up and Maintenance Benefit.
CSUMB was a critical lifeline for people on both OW and ODSP who were in need of
additional funding to become or remain appropriately housed. The transfer of partial CSUMB
funding to municipalities through CHPI was not only done with too much haste and no
consultation, it remains an insufficient response to the need in communities. Municipalities
have been put in the very difficult position of responding to the need with, in many cases,
insufficient funds, particularly as the elimination of CSUMB was accompanied by a cap in
discretionary non-health benefits. Some municipalities have created CSUMB-like programs to
try to meet this need. But others have not, increasing the patchwork nature of benefit
provision across the province for people who receive benefits from what are provinciallymandated programs.
Prior to the end of CSUMB, government took a decision to provide a temporary funding
increase to CHPI to assist municipalities through the transition to the new CHPI system. We
would argue that municipalities – and indeed, the people who live in municipalities who
receive Ontario Works and ODSP benefits – require additional funding on an ongoing basis
to meet their urgent housing needs.
As you know and have undoubtedly heard throughout the public consultations you have held
on the next strategy, ensuring sufficient supports for housing is a fundamental part of
reducing poverty. A poverty reduction strategy that does not provide additional funding to
municipalities for CSUMB-like programs will miss an important opportunity to ensure that
Ontarians who rely on OW and ODSP – and whose housing needs are incontrovertible –
have access to the funds they require. We feel strongly that restoring full CSUMB funding is
critically important to responding to the need in communities and must be part of Ontario's
second poverty reduction strategy.
Thank you for your consideration of this addition to our submission.
Sincerely,
[by email]
Mary E. Marrone
Director of Advocacy & Legal Services