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How to make Bill C22 Better: Our brief to the Senate

February 18, 2023

The Standing Senate Committee on Social Affairs, Science and Technology

Via email:

RE: AEBC Submission regarding the Canada Disability Benefit Act

Please accept this submission on the proposed Canada Disability Benefit Act (Bill C22), from the Alliance for Equality of Blind Canadians/l’Alliance pour l’Égalité des Personnes Aveugles du Canada (AEBC).

The AEBC is a national charitable organization of primarily blind, deafblind and partially sighted members. We are committed to increasing awareness of our rights, to ensure that we can participate equally in all aspects of Canadian society. The AEBC is a leader in leveling the playing field for members of our community. Since 1992, the AEBC has participated in working groups and committees at the national, provincial and municipal levels. The AEBC advocates for accessibility, equality and the elimination of barriers in the manner in which organizations and businesses deliver products, programs and services across Canada. AEBC members have made submissions in connection with the Accessible Canada Act and other legislation.

We have reviewed Bill C22 and would like to provide the following comments:

1. We applaud the government for considering a bill which should, according to its title, “…reduce poverty and to support the financial security of persons with disabilities …”

2. However, in our opinion, the stated purposes of the proposed Act will place a limitation on who can receive the benefit. Currently, the section reads: “The purposes of this Act are to reduce poverty and to support the financial security of working-age persons with disabilities.” We therefore respectfully ask that the term “working-age” be removed from all sections of Bill C22. Our reasoning is as follows:

a) In the present wording, “working-age” would appear to be a restriction, whereas the Charter of Rights and Freedoms and the Canadian Human Rights Act place no restrictions on age for an individual who wishes to work. In fact, the term “working-age” in Bill C22 could be considered discriminatory. It is apparent that the inclusion of “working-age” is a misguided attempt at trying to define a specific criterion for benefit eligibility. Moreover, Bill C22 has not defined any other eligibility criteria. In our opinion, the appropriate time for any and all criteria to be determined is at the regulation drafting stage, because a complete impact/benefit analysis will be conducted at that time.

b) It is evident from reading Bill C22 that a whole sector of individuals with disabilities will not be covered by the proposed Act. AEBC is worried in particular about those people with disabilities who have never worked and therefore will only be eligible for OAS and GIS when they turn 65. Those who qualify for the CDB for a few years may well find their income drops when they turn 65. The CDB amount or how it will be calculated has not yet been determined but if for instance it is set at $2000, a senior, aged 65, with a disability who has not worked would be only eligible for a maximum of about $1660 a month from OAS and GIS at today’s rates. This would be a drop in monthly income of $340 or 17% and would once again put them under the poverty line.

c) The Seniors’ Advocate in British Columbia recently announced that 50% of seniors in the province live on an income that is less than minimum wage, despite federal and provincial programs. They are relying on food banks more and more and have to choose between paying rent and other necessities such as medications, hearing aids or mobility devices. It can be presumed that seniors with disabilities who may have never been able to work or had the disposable income to put towards their retirement, are struggling even more. The aforementioned example from British Columbia, is in our opinion, reflective of the situation facing seniors in most jurisdictions in Canada.

d) Those with disabilities born before 1960 were not able to benefit from any of the very significant government contributions towards a Registered Disability Savings Plan and will potentially also be excluded from the CDB unless the "working-age" restriction (however defined) is removed from the Act.

e) Disability does not disappear at age 65 and, in fact, often becomes more financially burdensome with the complications of aging. Therefore, one of the focuses of the Benefit should be on lifting seniors with disabilities out of poverty.

f) The Bill states: “4 A person is eligible for a Canada disability benefit if they meet the eligibility criteria set out in the regulations.” We wholeheartedly agree that all eligibility criteria, including any restrictions, should be determined during the development of the regulations. The wording of the Act should therefore not be allowed to impose any limitations.

g) Finally, it is also hoped that the Disability Benefit will be based on the individual’s income whereas the current Seniors’ programs are based on that of the family. This could potentially lead to yet another disparity when CDB recipients turn 65.

3. We also wish to express our support for the views expressed in the brief submitted by Steven Muller, Vice President of Litigation at Share Lawyers, And Hart Schwartz. They clearly point out a serious flaw in Bill C22. As it stands now, there is no safeguard to ensure that private insurance companies will not claw back the Canada Disability Benefit. Money which the Federal Government intends to lift people with disabilities out of poverty should not be allowed to flow instead to these rich insurance companies.

In conclusion, we look forward to a Canada Disability Benefit which lifts all people with disabilities, including seniors, out of poverty. The AEBC would respectfully request the opportunity to appear before the Senate committee on this matter. Should you wish to discuss any of this submission, please feel free to contact the National President, Marcia Yale, via email at or via phone at 705-571-4445.

N.B.: We would ask that any response be provided in text format, i.e.: Word (.docx, rtf, txt). Please avoid sending a pdf as they are not always accessible.

***End of document

Update: AEBC will be appearing before the Soci Committee! We were notified on March 2, 2023 and await the confirmation of our presentation date!


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