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Strengthening Social Assistance in Ontario

Wednesday, August 31, 2011


A BRIEF IN RESPONSE TO: A Discussion Paper: Issues and Ideas

Submitted by:      Alliance for Equality of Blind Canadians / L'Alliance pour l'Égalité des Personnes Aveugles du Canada (AEBC)

August 31, 2011


The Alliance for Equality of Blind Canadians / L’Alliance Pour L’Egalite des Personnes Aveugle du Canada (AEBC) is pleased to have the opportunity to comment on the Discussion Paper, Issues and Ideas. In this brief, the organization intends to briefly add its voice to the work of the ODSP Action Coalition, discuss a number of issues that are of particular importance to the blind community, challenge the notion of employment as a "one size fits all" panacea to chronic poverty, and to outline some of its proposals concerning the need for a comprehensive Economic Strategy.


The Alliance for Equality of Blind Canadians is a national organization, comprised mainly of rights holders who are blind, deaf-blind, and partially sighted that is active in the province of Ontario. Four of the seven individuals who volunteer on the Board of Directors reside in Ontario, and two of AEBC's chapters are also situated in this province. The work of AEBC focuses on removing existing barriers and preventing the introduction of new ones; improving public attitudes; and providing input on public policy issues that affect the daily lives of members of the blind community. Reducing the level of chronic poverty that is the lived experience of far too many of its members is a priority to the AEBC. For background on the work of the AEBC, including some of its previous submissions, please visit the website at


Members of the AEBC have been participating in the ODSP Action Coalition for several years, and are fully aware of its extensive and thoughtful submissions. Therefore, this document will not simply reiterate what is contained in those submissions on such topics as: the need to immediately raise the rates to provide a more liveable level of income, treating social assistance recipients with enhanced dignity and respect, reducing difficulties in contacting one's worker, and streamlining administration and reduce the number of "stupid rules." These issues are also of interest and concern to members of the AEBC.

In this submission, the AEBC will focus on a number of topics that are of particular importance to Ontarians who are blind, deaf-blind and partially sighted who are or who may become ODSP recipients.


For many years, Section 1 of the Ontario Human Rights Code has provided:

Every person has a right to equal treatment with respect to services, goods and facilities, without discrimination because of race, ancestry, place of origin, colour, ethnic origin, citizenship, creed, sex, sexual orientation, age, marital status, family status or disability. R.S.O. 1990, c. H.19, s. 1; 1999, c. 6, s. 28 (1); 2001, c. 32, s. 27 (1); 2005, c. 5, s. 32 (1).

Despite this clear provision, the AEBC still receives inquiries from ODSP recipients who tell us they cannot obtain information, either about the Program itself, or their own particular circumstances in a format they can read independently. This results in violations of their privacy and human rights, and can result in extensive delays in gaining access to critical, time limited information.

The AEBC believes the ODSP must comply with its obligations under the Ontario Human Rights Code and recommends that it provide all recipients the right to access information in their preferred format - print, braille, audio, or electronic.


It is generally acknowledged that the ODSP application process is too involved and complex. It is even more difficult for applicants who are blind, deaf-blind, and partially sighted, as the forms are not available in various multiple formats.

All individuals applying for ODSP must obtain and complete a Disability Determination Package. Detailed medical information is required, which must usually be provided by a range of medical specialists, who are already overworked. Applicants may also face direct costs related to obtaining information and assistance from medical professionals, which can easily range from $50.00 to $120.00. 

Medical practitioners are similarly left without adequate supports and many find the package confusing and difficult to complete. Frequently, they do not understand the forms or the perplexing grading systems that are used.

While eligibility must be determined, the AEBC recommends that the process be streamlined and simplified. Forms must be provided in multiple formats and the program should cover the costs for physicians to complete medical forms.


Social assistance recipients live thousands of dollars below the poverty level. Poverty is a primary cause of societal exclusion and poor health among Canadians. This has been amply documented in numerous reports from Canada and abroad. Ontario's Public Health Authorities have urged the provincial government to raise the rates for several years so that people can afford to eat nutritiously, yet the Ontario Government has introduced reductions to its Special Diet Program. The rates must be increased, and should also be adjusted annually for inflation, as determine by an independent Commission that includes significant representation from social assistance recipients.


The excessive nature of the "claw back" under Ontario's social assistance programs represents a serious disincentive to those who wish to work. In BC, by contrast, recipients keep the first $500 a month before any claw back is imposed. The AEBC recommends that Ontario replicate BC's claw back model in order to encourage more recipients to seek work.


As the ODSP Action Coalition observes, "there is no clear dividing line between people with disabilities who “can” and “cannot” work. No two such groups of people with disabilities exist in reality. People with “severe” and “less severe” disabilities are not equivalent categories to those who “cannot” and “can” work. Like disability itself, the employability of people with disabilities is a dynamic interaction that exists along a continuum determined by a number of factors, including the health, age, education, skills, and past experience of the individual, as well as the supports available to facilitate their employment, the degree of accommodation available in the workplace, and the job opportunities available in the labour market." 

The AEBC would take this point at least one step further. Not only are no two groups of persons with disabilities the same, often two individuals with the same disability are very different. In the area of eyesight, for example, if one has 5% residual vision, this does not indicate how usable that remaining vision may be and whether that person’s vision is usable up close up or far away, nor does it indicate what kind of coping mechanisms and alternative techniques that person has developed to remain as independent as possible.

Some people with “very severe” disabilities are able to work full time. Some who have what might be considered “less severe” disabilities are not. The real question is to what extent are workplaces organized with persons with disabilities in mind, and to what extent have employers developed a more positive attitude to employing us and to providing needed accommodations, as have been required by the Ontario Human Rights Code since the early 1980s.


If one examines responses from the Government of Canada to poverty reports from both the House of Commons and Senate, one could summarize these responses in a single phrase - the solution to poverty is to get a job. The AEBC must strongly challenge this one size fits all panacea. Examining the premise that a job is the solution to poverty for persons with disabilities raises a fundamental question: Where are all these jobs that social assistance recipients are expected to go out and acquire? The AEBC simply challenges the thesis that these jobs are out there and available! Where are they? The AEBC recommends the Commission research and attempt to respond to this fundamental question.


The so called "trickle down" theory of economics postulates that in good times, economic benefits will reach all groups in Canadian society. However, not only has the so called "trickle" failed to reach the bulk of Canadians with disabilities, more recent statistics show the reality is that wealth is being concentrated more and more in the hands of an ever narrowing number of individuals. Canadian history tells us that persons with disabilities have never known the boom times that other Canadians once took almost for granted, and it is time for governments to take new steps to help remedy the historic and chronic marginalization from the mainstream of Canadian society.


The world of work has changed dramatically over the past two decades. Twenty or more years ago, it was suggested that emerging technology would be the “great equalizer” for persons with disabilities, including the blind community. So far, it has achieved that promise for some, but for many others, it has proven to be a double-edged sword. New barriers now exist, including:

  1. Nowadays, it is assumed most workers will participate in several jobs during their working lifetime. On average, it takes longer for a person with a disability to obtain employment; thus, this barrier will have to be surmounted over and over again during one’s working life.

  2. Technology has rendered obsolete several kinds of jobs that blind workers often used to perform, e.g. telephone operator, receptionist, darkroom technician, and transcriptionist. Many of these jobs no longer exist or do not exist in the numbers they once did.

  3.  Changes in technology take place at a fast pace, and often, needed accessibility is not built in at the same time as new technology, thereby requiring ongoing catch up.

  4.  Some software that is used in the workplace is not accessible to individuals using a screen reader to read and navigate a computer.


The problem of finding work has been even further exacerbated by the recent recession. Not only must social assistance recipients deal with persistent and pervasive negative employer attitudes, need for expanded accessible transportation, employer failure to provide proper workplace accommodations short of undue hardship, and the number of individuals competing for available jobs. In an effort to deal with the results of the recession, a number of retraining programs were developed for workers who were EI eligible. 

This represents one of those "new" barriers to equalizing the historic imbalances that continue to confront persons with disabilities. Too many in the blindness community do not have previous workplace attachment and, thus, are not eligible for programs that require EI eligibility. This in turn puts in place yet one more new barrier to the employment of persons with disabilities, many of whom could have benefitted from training programs that were designed to provide Canadians with current skills designed to lead to a job.


On June 24, 2011, the Ontario Government unveiled its 10-year Infrastructure Plan for Ontario. It lays down the policies and principles that are supposed to govern the billions of dollars of infrastructure spending by the provincial government over the next decade. It requires that "all entities seeking provincial infrastructure funding for new buildings or major expansions/renovations are to demonstrate how the funding will prevent or remove barriers and improve the level of accessibility where feasible."

This policy should result in increased access in such critical areas as education, buildings, and the procurement of goods, services, and technology. The AEBC commends the Ontario Government for building this important accessibility requirement into its 10-year Infrastructure Plan. It is now critical for the Ontario Government to develop a concrete action plan, which must include wide publicity, and building in accountability measures to ensure that it is followed and makes a difference in the lives of Ontarians with disabilities.


Over the past two decades, numerous awareness programs have been carried out by governments, service agencies, and rights holder organizations such as the AEBC. While some individuals have undoubtedly benefited from these initiatives, taken together, statistics and personal stories reveal these past efforts have failed to move the bulk of individuals with disabilities from the margins to the mainstream of our society.

Today, blindness remains one of the most feared and misunderstood of all disabilities. There is a chronic need to develop new messages and approaches to improving public attitudes. There is a need to develop new awareness programs and to give rights holder organizations and individuals with disabilities a preeminent role in developing and carrying out these new initiatives. Blind people know best the needs and aspirations, and are the best spokespersons. The AEBC believes firmly in the phrase, "nothing about us without us."


To deal with the historic roots of poverty among persons with disabilities, The Ontario Government must lead by example and forge a comprehensive Provincial Economic Strategy for people with disabilities, This Economic Strategy must  be based on the tenets of full inclusion and universal design, and must be developed through direct participation of people with disabilities who have real life experiences of social assistance, rights holder organizations of persons with disabilities, service providers, the private sector, labour, and all relevant Ministries and levels of government. 

The goals of the strategy must be both to alleviate the chronic level of poverty that is the lived experience of far too many Ontarians with disabilities, and it must also result in the creation of increased job opportunities for people with disabilities that are appropriate for the individual. Such an Economic Strategy must be comprehensive. It must not only focus on reducing poverty for families with children, it must also include people without children, such as the majority of ODSP recipients. Such a strategy would also allow Ontario to better meet the objectives of the Canada-Ontario Labour Market Agreement for Persons with Disabilities and the Canada-Ontario Labour Market Agreement. 

These agreements are intended to provide a framework for the provision of employment-related supports and services to people with disabilities, in the first case, and to people who are not EI eligible, including people with disabilities without employment earnings and/or receiving social assistance, in the second. 

At the same time, the AEBC is concerned that the unique challenges facing people with disabilities may be lost if the primary focus of any poverty reduction strategy is helping people make the transition to work, as experience shows clearly that many individuals are simply not going to become employed, regardless how much they might wish to work. The changing nature of the workplace has simply not responded to the idea of employing persons with disabilities in significantly higher numbers. Any new Strategy must avoid the introduction of forced work or "work fare" initiatives, as they do not contribute to the dignity of recipients, nor do they work.


A heightened level of government commitment: The Government of Ontario must demonstrate a new level of urgency and leadership to the ongoing and pervasive economic and unemployment plight of persons with various disabilities, including Canadians who are blind, deaf-blind, and partially sighted. The AEBC recommends that the Premier call together leaders from business, labour, and organizations "of" persons with disabilities to develop a heightened commitment, new strategies and programs, and new partnerships.

Scope of the economic strategy: Ontario's new Economic Strategy must cover individuals who have both visible and invisible disabilities. It must address the needs of persons with various levels of disability, (including those who are considered "severely" disabled), and should work actively to achieve employment and income rates among persons who are blind and otherwise disabled that are roughly equivalent to those of non-disabled Ontarians.

The federal role: As part of Ontario's new Economic Strategy, the Government of Ontario should pressure the Government of Canada to participate proactively, including expanding the Employment Equity Act and Federal Contractors Program to reduce IN STAGES the coverage threshold from 100 employees to not more than 20 employees, and these initiatives should be strengthened to provide greater results regarding the representation of persons with various disabilities, rather than as follows:

Employment in the Ontario Public Service: One long-term employee in the Ontario Public Service observed, "I can't move higher because I have not had management experience, and I can't get management experience without opportunities. I am in a position where I have found myself before - no one knows what to do with me. [It is] very demoralizing." 

To demonstrate a heightened commitment, Management Board must take steps to transform the Ontario Public Service into a model employer. These steps must focus on three major areas:

  • Recruitment
  • Retention
  • Promotion

The Ontario Public Service (OPS) should lead by example. The OPS should develop an aggressive proactive recruitment plan to increase the representation of persons with various disabilities at all levels, including persons who are blind, deaf-blind, and partially sighted; review job descriptions to ensure that job requirements are current and job-related; develop a targeted program of internships; maintain the Accommodation Fund; conduct an ongoing awareness program with managers to remove attitudinal barriers; and ensure that training is available to facilitate career progression.

Employer commitment: Blindness remains one of the least understood disabilities. There is a need for an ongoing program to educate and gain commitments from employers on a province-wide basis for the employment, retention and advancement of workers with various disabilities, including employees who are blind, deaf-blind, and partially sighted. Consumer organizations such as the AEBC must be directly involved in developing and delivering such programs. As rights holders who live with a disability on a daily basis, this group knows best the needs and capabilities of those who are blind, deaf-blind, and partially-sighted.

Employment readiness programs: To help overcome the effects of marginalization and lack of employment opportunities early in life, targeted employment readiness programs must be made available to assist persons with various disabilities, including individuals who are blind, deaf-blind and partially sighted, to gain access to jobs in the regular labour market. Work experience programs are particularly important for persons with limited exposure to the labour market or who have lower levels of education.

Currently, the federal Employment Insurance Program (EI) offers some retraining and other employment supports. However, these initiatives are intended only for EI recipients. This has the effect of doubly penalizing many individuals with disabilities who have not had the opportunity to accumulate sufficient labour market attachment to qualify for EI benefits. The Ontario Government should press the Government of Canada to extend eligibility to include historically disadvantaged groups such as persons with various disabilities, or to initiate new and targeted employment support programs.

Accessible and usable technology: Information and Communications Technology (ICT) that is fully accessible and usable will increase an organization's bottom line and support the employment of all groups of Canadians.

However, changes to existing ICT can make it impossible for current employees, particularly employees who are blind, deaf-blind or partially sighted, to use new technology, which threatens experienced employees and prevents new hiring. Employers, especially governments at all levels, should restrict purchases to ICT (devices and software) that are usable by all employees.

Workplace accommodations: Accommodating an employee with a disability is a very individualized process. The affected employee, who often knows best what is needed, must be directly involved. The technology and solutions are known but often not used. Cost is usually far less than expected, and large employers like the Ontario Public Service can bear such costs. Federal, provincial, and territorial officials should discuss the creation of a fund to assist smaller employers, but first and foremost, employers must recognize and discharge their legal obligation to accommodate employees, short of undue hardship.

Expanding the OPS Accommodation Fund: Despite study upon study over numerous years that recount extensive employer experiences that, on average, the cost to accommodate an employee with a disability averages about $500, employers, especially smaller employers, remain afraid of the possible costs of employing persons with disabilities. The Ontario Government should consider expanding the Accommodation Fund, which covers accommodation costs for its own employees, to also cover broader sector transfer payment organizations, and organizations in the broader public and private sectors, with a focus on smaller employers.

Employer incentives: While the AEBC supports measures that would make it easier and more financially rewarding for social assistance recipients to go to work, the organization’s experience is that the current nature of work prevents many from attaining and retaining meaningful employment.

Employment incentives alone are inadequate as an anti-poverty strategy. Financial incentives to employers have proven to do little to encourage employers to be more flexible and accommodating. They must be accompanied by other measures, including an enhanced commitment to employ persons with disabilities, including Ontarians who are blind, deaf-blind, and partially sighted, new awareness programs and more rigorous enforcement of statutes, including the Ontario Human Rights Code.


Poverty reduction makes both social and economic sense. The AEBC believes in an inclusive Ontario, where everyone can develop their talents and contribute to thriving communities throughout our great Province. The AEBC wants an Ontario with a vibrant economy where all Ontarians share in its prosperity.

Disability issues cut across virtually all levels of government, departments, and sectors of Canadian society. To move forward, commitment and collaboration to a comprehensive Economic Strategy are required. Employment initiatives are needed but they alone will not achieve the intended results. They must be accompanied by initiatives in other areas, such as regular raises in social assistance rates, disability supports, training, housing, transportation, and the removal of disincentives in income security programs.

Disability needs are individual and a more positive climate must be created where the individual is encouraged and supported to take risks and experiment. Flexibility, consumer involvement, and coordination are the critical elements of any successful initiative to address disability issues. Governments, business, labour and the disability community must work collaboratively to find new solutions. This work requires a long-term commitment. The AEBC is anxious to play a role in realizing a new day for Canadians with various disabilities.

The AEBC urges you and your colleagues to consider our reality and develop a comprehensive poverty reduction strategy that addresses both income and labour market issues. It is time for people with disabilities to join the mainstream and to enjoy a decent quality of life. No longer should we be subjected to a life of poverty and marginalization in this affluent Province.

Increased investments in ODSP recipients through benefits, supports, and accommodations will enable recipients to be more engaged in their households, their communities, and the labour market. The net impact for government includes increased tax revenue through income and consumption taxes as well as decreased expenditures in areas such as health care and criminal justice. 

The Ontario Government stated in the Throne Speech (November 2007), "The Government of Ontario is committed to a Poverty Reduction Strategy with targets and measures to ensure "opportunity that is accessible to all."

This commitment has created expectations for change and improvements, and both recipients and the AEBC trusts the work of your Commission will help to realize these commitments and expectations. The AEBC looks forward to participating in the realization of this imperative. Persons with disabilities deserve nothing less in 2011.