Nlagafaw R gioi1. COM March 6, 2012 Page 1 of 15 REPORT TO: RECOMMENDATION PURPOSE SUBJECT: Comments. welcomed provided

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1 Page 1 of 15 Nlagafaw R gioi1 REPORT TO: Co-Chairs and Members of Public Health and Social Services Committee SUBJECT: Social Assistance Review Response to the Commission s Discussion Paper RECOMMENDATION this report BE FORWARDED to Ontario Municipal Social Services Association (OMSSA) and the Association of Municipalities of Ontario (AMO); and 2) That a copy of this report BE FORWARDED to the Commissioners of Ontario s Social 1) That a copy of Assistance Review stating that Niagara Region RECOMMENDS to the Commission that: municipalities are the logical choice for delivery of human services such as social a) assistance and employment because of the capacity to respond to local issues, however, funding for such services cannot be sustained through property taxes; b) improvements efficiency are come with c) d) to social assistance welcomed provided aimed at improving service effectiveness and do not bear any costs that that municipalities service delivery changes; the Commission follow the advice of sixteen city Councils across the province and add a $100 Healthy Food Supplement as an alternative to moving Special Diet to the Ministry of Health and Long Term Care; and Temporary Care Assistance be transferred to the Ministry of Children and Youth Services so that children and their caregivers can be supported through a comprehensive policy framework. PURPOSE This report sets out a response by the Regional Municipality of Niagara to the Discussion Paper released on February 2, 2012 by the provincial Commission for the Review of Social Assistance Comments to the Commission are due March 16, The response outlined in based on community consultations, prior positions taken by provincial associations, and Niagara s experience in administering social assistance. Social assistance programs, such as Ontario Works (O\/\/) and the Ontario Disability Support Program (ODSP) have a significant impact on the lives and well-being of many citizens in the Niagara region, and about 8% of Niagara s citizens rely on social assistance. In making a submission, Council is demonstrating its commitment to healthy communities by supporting a safe, healthy, diverse, culturally rich community where people of all ages and incomes enjoy a high quality of life. in Ontario. this report is.

2 Page 2 of 15 BUSINESS IMPLICATIONS Social assistance more than 34,475 is crucial in the lives of a growing number of Niagara s citizens. In 2011, on either or ODSP, representing about 8% of the region s population. Caseload for grew at a rate of 5.23% for 2011 and 21,124 individual clients were served throughout the year, and a further increase of 8% in 2012 is projected. individuals relied Improvements to social assistance aimed at making it fairer, more adequate and with a more effective employment focus are of particular importance to the Niagara region given its economic situation. Since the recession began in the last quarter of 2008, Niagara s social assistance caseload has increased by 41% and our region has experienced some of the highest unemployment rates in Canada. This report does not have any immediate financial implications, however, many of the options in the Discussion Paper, if approved by the provincial government and implemented, may have and human resource impacts which cannot be determined at this time. Many of the questions raised by the Commission in the Discussion Paper acknowledge the need to balance improvements to social assistance with long-term sustainability. As noted below, while staff agree that municipal governments are best positioned to deliver integrated social assistance and employment services, we also agree with positions taken by the Association of Municipalities of Ontario (AMO) and the Ontario Municipal Social Services Association (OMSSA) that social and health programs cannot be sustained through property taxes and that municipalities cannot bear any costs that come with service delivery changes. financial Business implications also may arise from the recommendations made inthe Drummond report released on February 15, 2012 which were reported to Council on February 16, Although Drummond s report defers to the Commission s Review on Social Assistance, Drummond provides some early recommendations including consolidating Ontario Works and Ontario Disability Support Programs into a single program delivered at the local level and recommends employment services with Employment Ontario (currently funded by the and Universities and delivered by agencies in the community). Further implications to Niagara stem from Drummond s recommendations to close a Casino in Niagara Falls as well withdrawing funding to support the Fort Erie Race Track. Both of these recommendations may impact local jobs, tourism and increase the demand for social further integration of Ministry of Training Colleges assistance. A REPORT 2008, the provincial government released its poverty reduction plan, "Breaking the CycIe" at reducing child poverty in Ontario by' 25% over five years. As part of this plan, the province committed to review social assistance. In aimed COM Commission for the Review of Social Assistance Review in Ontario provided Regional Council with information regarding Ontario s major review of provincial social assistance programs. This is the first major review of the province s social assistance programs in 20 years. It is being led by two commissioners, Frances Lankin and Dr. Munir Sheikh.

3 Page 3 of 15 Niagara was one of eleven communities in Ontario visited by the Commission. They visited Niagara on July 5, 2011 to consult with social senrice agencies, social assistance recipients, employers and other stakeholders; the chair of Public Health and Social Sen/ices Committee also attended. Feedback from Niagara included the need to strengthen client centred service by working across silos, change social assistance rules to support individuals and families living in poverty and to improve benefits and labour market conditions for workers. Across the province, over 700 submissions were sent to the Commission from various community groups and agencies. On February 2, 2012, the Commission released a 66 p age Discussion Paper outlining several possible approaches to reforming social assistance based on what they heard during round of consultations and submissions which occurred last summer. The discussion paper seeks further feedback from stakeholders and communities on the Commission s five objectives for social assistance: reasonable expectations and necessary supports to employment; appropriate benefit structure; a system that is easier to understand; long term viability, and; system integration. The Commission s final report is due in June The full discussion paper is available online at their first publications I As the Commission committed to meeting its deadline of June 2012 for a final report to the limited time available for responding to the February 2012 Discussion Paper by the deadline of March 16, With only six weeks (less time when Committee and province there is is Council timelines are considered), it was not possible for staff to prepare a detailed submission in response to all questions raised or undertake a thorough consultation process. Therefore the recommended responses contained in this report (summarized below and set out in detail in the Appendix A) were compiled by reviewing prior submissions and obtaining as much current feedback as possible in the time available. In preparing this report, we considered the following submissions and feedback: the Niagara community consultation undertaken in 2011 for the Commission; prior submissions by AMO and OMSSA; prior submissions by Poverty Free Ontario and Community Legal Education Ontario; submission to the Federal Government from the Senate Committee on homelessness and poverty; feedback from local internal and external stakeholders; and comments from Community Sen/ices staff with respect to our experience in delivering social assistance. Staff have notified stakeholders in short time available, encouraged Niagara about the Discussion Paper and, in view of the them to make their own submissions directly to the Commission by the deadline. We understand that the Ontario Municipal Social Services Association (OMSSA) and the Association of Municipalities of Ontario (AMO) are currently preparing responses on behalf of members. As an active member of both associations, Niagara Region strongly supports a response from AMO and OMSSA because they have worked collaboratively with municipalities to present issues and a strong vision for system improvements to the Commission. Niagara s response supports AMO and OMSSA s position that municipalities their

4 Page 4 of 15 are the logical choice for service delivery because of the capacity to respond to local issues but funding for social and health programs cannot be sustained through property taxes. Summary of Recommended Response The discussion paper outlines the complexity of the current elements of the social assistance interdependency with broader systems such as the labour market, affordable housing, child and health care and the economy. lt outlines the Commission s view that because of this complexity, small fixes are not enough and that bold thinking is required systems and their for positive transformation to occur. The Discussion Paper poses extremely complex questions, and responses rather than possible approaches, each of the Commission s question could have serious financial, labour, seryice delivery, and quality of life implications. Specifically, questions regarding the issues of fairness, adequacy of benefits and employment seryices are highlighted below: to Fairness The discussion paper addresses the need for social assistance to be fair to everyone. lt notes the discrepancy between a low wage worker who does not have access to health benefits while someone receiving social assistance does. How does one achieve fairness in such a case? By taking away the benefit from one or by giving it to the other? lt appears the Commission has positioned the issue of fairness as a competition between people who are poor. The questions that focus on increasing incentives to work also seem to be at counterpurposes to one of the objectives of the Review which is to increase the number of social assistance recipients who are hired. The questions reinforce the idea that social assistance recipients do not want to work. The notion that they need incentives to leave social assistance does little to increase their appeal to employers as a suitable pool of potential employees. This approach will be considered by many as a missed opportunity to achieve a key goal of the Review reducing poverty in Ontario. For this reason, staff recommends that the Commission be urged to focus their final Report to the province on improving working conditions for T i all low income Ontarians. Furthermore, staff recommends that fairness would be achieved if the Commission transfers the Temporary Care Allowance to the Ministry of Children and Youth Services where a comprehensive policy framework would better support children and their caregivers. Adeguacy 79% of all of the written submissions made to the Commission said that social assistance rates are too low. Local feedback reflects this idea and in the past Regional Council has advocated reforms to social assistance including increasing rates. The Discussion Paper notes the challenge of raising social assistance rates when low wage earners are barely making Approximately ends meet and often do no earn enough to lift them out of poverty. However, stakeholders would argue the solution is not to keep everyone poor, but rather to raise the bar for everyone living in poverty by creating jobs that pay enough to lift families out of poverty, and by creating a safety net that supports health and weii being and provides individuals with opportunities. Currently, individuals with unique health conditions can apply for the Special Diet Allowances social assistance if they meet certain medical conditions. The on Discussion Paper asks if this benefit should be transferred to the Ministry of Health and Long Term Care. Staff recommends

5 Page 5 of 15 this transfer in principle however the MOHLTC does not have the systems in place to provide Commission to consider was outlined in many of the submissions to the Commission regarding the $100 food supplement for people receiving social assistance. Sixteen city councils, including some from Niagara, passed resolutions supporting a $100/month Healthy Food Supplement. Adding this benefit to social assistance would allow individuals and families access to nutritious food which supports better health. Their financial eligibility for social assistance already establishes that they meet the condition of being poor therefore any medical benefits should be rationalized by medical professionals. Asking case workers to determine eligibility for medical or dental services is administratively cumbersome because it is beyond their expertise and can place the individual and the delivery agent at risk. direct benefits to individuals. An alternative for the Employment Stakeholders speak of the need to balance social assistance as a safety net with one s right to employment. ln order to support that right, employment assistance programs need to be of high caliber, easier to access for all workers regardless of their source of income and need to focus on improving working conditions, including paying a livable wage. ln this way, employment services shifts from an individual responsibility borne either by the worker or the employer to a benefit to employers and employees. In Niagara, this is critically important because the largest growth sector is self-employment and small and medium sized companies. A bold perspective is to build employment assistance as a way needing social assistance or to support able to sustain them and their families. their transition to prevent individuals from social assistance into from a job that is Rather than focusing stakeholder feedback on ensuring that social assistance isn t a Commission could focus on approaches to ensuring that employment assistance facilitates work. Specifically this means that low wage earners shouldn t be working full time and living in poverty. Employers and employees paying into El are already contributing to a system of supports that many don t benefit from (employers must bear the cost of training employees, employees must bear the cost of upgrading skills, and families are having to access disincentive to work, the while waiting for EI). Researchers and people who work in social assistance believe that the system has the potential to respond to the needs it is designed to address but without adequate resources (including and adequate benefits) it will continue to miss the mark. Employment assistance and retraining programs can be successful if adequately and appropriately resourced. For example, as reported in Employment Outcomes facilitative policy, integrated system designs COM and COM Update on Enhanced Employment Services (EES) for Vulnerable Persons since Discontinuation of Provincial Funding, longer term help and flexible participation are features that increase the effectiveness of employment supports that are not currently core features of social assistance. lf social assistance is to be both a safety net for poor unemployed people and a pathway to employment, benefits and their delivery must be adequate and facilitate the program s intent. Niagara s experience with EES demonstrates this type of success. Approximately 90 EES participants with minimal or no attachment to the labour force who experienced multiple barriers to employment were able to secure employment and exit from social assistance. The return on investment for this type of support has the potential to be significant.

6 Page 6 of 15 With respect to delivery of employment programs, Niagara s response supports AMO and OMSSA s position that municipalities are the logical choice for service delivery because of the capacity to respond to local issues but funding for social and health programs cannot be sustained through property taxes. Previous Reports Pertinent To This Matter COM January 10, 2012 Commission in for the Review of Social Assistance Review Ontario COM Niagara Prosperity Initiative Update COM Update on Enhanced Employment Services for Vulnerable Persons since Discontinuation of Provincial Funding COM Niagara Emergency Energy Fund COM Increased Demand for Social Assistance - Additional Staff Required PHD COM Poverty and Healthy Eating COM Employment Outcomes Social Assistance and Employment Opportunities COM Increased Demand for Social Assistance Additional Staff Required lmpact of Current Economic Condition on Niagara Region s COM PHD Community Services, Niagara Regional Housing and Public Health Programs COM Integrated Labour Market Planning Project COM Income Replacement and Employment Supports System PHD COM Nutritious Food Basket (NFB) 2006 Sun/ey Results COM Rate Structure for Social Assistance Submitted by: Katherine Ch`, Approved lett Commissioner, Community Services by: {0/1/ Mike Trojan Chief Administrative This report was prepared by Sarah Pennisi Director Social Assistance fticer and Employment Opportunities. Attachment: Appendix A: Niagara s Response to the Social Assistance Review Discussion Paper

7 Page 7 of 15 APPENDIX A: Niagara s Response to the Social Assistance Review - Discussion Paper This Appendix summarizes each chapter of the Discussion Paper, lists the related consultation questions including a brief commentary about the chapter, and then provides commentary about the topic covered. This commentary is informed by reviewing: comments from OMSSA s submission to the Commission August 2011 AMO submission to the Commission October 18, 2011 participants in the Commission s visit to Niagara on July 5, 2011, http;//wvwv.omssa.com/lib/db2fiie.asp?file=37162; Watch FiIe1&TempIate=/CM/Conte ntdisplay.cfm&contentld= comments from Poverty Free Ontario February 6, 2012 PFO Bulletin #9: Social Assistance Review Discussion Paper 2: Missed Opportunity, Even Backsliding, as Austerity Agenda Looms Poverty Free Ontario; Community Legal Education Ontario (CLEO) the Senate Committee on homelessness and poverty ln From the Margins: A Call to Action on Poverty, Housing and Homelessness ; dec09/reports e.htm;and feedback from local internal and external stakeholders. Chapter 1: Reasonable Expectations and Necessary Supports to Employment. Summary case management systems and employment support services need to improve to help social assistance recipients find and keep jobs. Employment services need to be better integrated across the different jurisdictions and people with disabilities who can work should receive particular consideration. Communication and connections with employers must also be improved. A more integrated employment services system may be created by improving provinciai municipal/first Nations collaboration, the delivery of both social assistance and employment assistance by municipalities/first Nations only and/or that employment services provided under and ODSP be consolidated with Employment Effective assessment, Ontario providers. Questions: 1. How can employment services be made more effective? 2. What should the Commission recommend to encourage greater consistency in effective employment services and supports for social assistance recipients, while still allowing for local flexibility and innovation? Should standard assessment tools be used to identify people s needs and match them to appropriate services and supports? What should be considered appropriate employment-related activity participation requirements for people with disabilities? Should participation requirements for people with be different from those for other people receiving social assistance? Should a tool be developed to assess the work capacity of people with disabilities? If so, how should the tool be developed and how should it be used? disabilities 5.

8 6. 7. Page 8 of 15 What kinds of engagement strategies and incentives would be most effective in encouraging and supporting employers to hire more social assistance recipients? Which approach would be most effective in improving the delivery of employment services'? Commentary The primary focus the assessment of work capacity. Although both and main questions are about whether Ontario should introduce employment screening tools for ODSP recipients or wait until the Accessibility for Ontarian s with Disabilities Act (OADA) is fully implemented. ODSP of this section is recipients are included in the discussion, the ln August 2011, OMSSA submitted a vision for social assistance reform to the Commission. This vision constructs social assistance as an income security system and a workforce development strategy that includes the following four strategies: Macro level labour market development at the community level to ensure that good jobs are available; Micro level workforce development for individuals to ensure people have the right skills and supports to access jobs regardless of their income source; An income security system with three streams of income support including medium term benefits and a pension style guaranteed income for people whose reasonable prospects of earning liveable incomes from employment are limited by disability or other circumstances; Financial supports based on income and allowing for the ability to look at the current year for income in the case of significantly changed circumstances. integrated short term benefits, There is no one-size fits-all approach to providing employment seniices and supports for social assistance recipients. Niagara s vision for employment services is to expand the current menu of seniices so that they are accessible to all workers regardless of their source of income. This means true integration of social assistance with employment and other services delivered across ministries (Ministry of Training Colleges and Universities, Ministry of Citizenship and Culture, etc). Because municipalities are the gateway for other human seniices (childcare, subsidized housing, etc), municipalities are well positioned to deliver the outcomes envisioned by the Commission. Services must be responsive to individual circumstances, i.e. working with literacy issues, addiction issues, social skills programs, apprenticeship programs etc. There needs to be a wide range of supports and a better coordination of these seniices to assist individuals as they maneuver through the system. An integrated system must be based on employment supports for employers and job seekers not on someone s source of income. The Commission should also consider uncoupling employment supports from income assistance. Currently, the client path is artificially divided into two streams: income support and employment supports and most often there is a contest for resources and energy that are spent filling the gaps that occur between these two streams. The result is that the urgency of providing financial assistance as well as the primacy of auditing eligibility often takes precedence over the employment part of the program. In this equation delivery agency staff are

9 Page 9 of 15 having to choose between either sewing the unemployed person or satisfying funder s requirements. Standard assessment tools can be useful only if they are structured in a way that is cooperative between the individual and the case manager and allows individuals to be honest about their current situation without fear of penalties (i.e. non-compliance penalties that lead to termination of benefits). These tools must be informed by labour market conditions as the context for options available. employment assistance for people with disabilities is intended to enhance opportunities for and civic engagement, then employment activities must not be ob igation based. Activities should include: volunteering, apprenticeship, training, education upgrading, etc. These skill enhancement activities differ from participation requirements in that they would not be mandatory for receipt of social assistance. If social inclusion There are many examples of effective employment supports for people with disabilities. An example of this success was the Enhanced Employment Supports initiative which provided intensive and personalized attention with great success. This initiative and others have demonstrated that employment assistance based on the principles of collaboration between the individual and the case worker and on acknowledgment that fundamentally people who can work want to work has the greatest potential for success. Employers that participated in the Commission s visit to Niagara noted that the supports to keep recipients employed, including childcare, pre and post emp oyment supports are valuable aspects of an employee s successful transition from social assistance into sustainable employment as well as preventing workers from needing social assistance. Participants also noted that employment is difhcult to achieve when social assistance recipients don t have stable housing or enough to r eat. Local employers consistently report that their primary need is for good qualified employees through one stop service. By making social assistance conditional upon employment participation, the policy is reinforcing the idea that social assistance recipients (either or not want to work and that recipients must be coerced or conditioned into working. The most effective strategy that the Commission could implement would be to reverse the negative stereotypes inherent in the system. ODSP) do Chapter 2: Appropriate Benefit Structure. three of the Review s objectives are highlighted: (1) Benefit adequacy; (2) Fairness between social assistance recipients and low income workers; and (3) Maintaining incentives to work by controlling benefit levels. The Commission highlights the complexity of In this section, these objectives focusing on the tradeoffs to consider. The absence of an official poverty line is noted, and the Commission comments about the need to either adopt one of the three existing measures (Market Basket Measure [MBM], Low Income Cut Off [LICO], and Low Income Measure [L M]) or to develop a "reference wage". This instrument is intended to be an equalizer between the working poor and social assistance recipients. The Commission also introduces the notion of a "benefit withdrawal rate" which they contend is necessary to ensure recipients entering the labour market have no unfair advantage over low wage

10 Page 10 of 15. workers who may not have access to supplemental benefits (i.e. access to free special health condition of the labour market are noted as challenges to achieving a balanced trade-off. Lastly, specific challenges are highlighted in considering an appropriate benefit structure for people with disabilities on ODSP, who have extraordinary daily living benefits). The nature and costs. Questions: Which adequacy and wage benchmarks should be used to set rates? Are there other measures that should be considered? In a methodology for setting rates, what proportions would balance adequacy, fairness and 1 incenuves? 3. Should Ontario use a two-rate approach, based on how long someone requires social assistance? If so, should there be exemptions from starting at the lower short term rate? 4. Should health benefits be provided to all eligible low-income Ontarians? lf so, how should the cost be covered? 5. Would an earned income supplement be a good mechanism to increase the incentive to work? If so, how should it be designed? 6. Would a housing benefit improve fairness and the incentive to work? lf so, how should it be designed? 7. How should income supplements for low-income people with disabilities be designed and delivered? Should such supplements be provided outside the social assistance system? 8. How should the current rate structure be changed to reduce complexity? 9. Should some special benefits be rolled into a standard rate? lf so, which ones? 10. Should the special dietary needs for all low-income people, including those receiving social assistance, be addressed through the Ministry of Health and Long-Term Care? 11.ShouId there be a separate basic income program for people with severe disabilities who are unlikely to generate significant earnings? 12. How should the different rates for different family types be established? Commentary August 2011 submission to the Commission, OMSSA argued that social assistance must provide an income that people can live on. " ndividuals and families must be assured a stable standard of living that provides them with the resources necessary to participate socially, culturally, politically, and economically in their communities" (OMSSA 2011:5). ln their proposed model, an entirely new income security system would be designed with the goal to streamline benefit structures and close the gap between current benefit levels and the cost of living/participating within the life of the community. Income security should provide enough money to cover necessities (food, shelter, clothing, personal care items, transportation, a means of communication, pregnancy and special dietary needs, etc.) and benefits are rationalized to what items really cost. OMSSA does not provide a formula but acknowledged that developing a benefit structure is complex and that many interconnected issues must be analyzed and that a working group, including OMSSA, should be called ln its together for this task. During the Commission s visit to Niagara, participants placed a high importance on adequacy and eligibility for benefits. In Niagara, providing adequate supports to poor unemployed people is particularly important given our community s struggle with of benefits

11 Page 11 of 15 unemployment and lagging average incomes. Benefits must reflect the cost of living in each community that is reflective of household compositions and should be founded on the principle of a living wage. It is recommended that the province establish a benefit rate board to fully examine the implications of each option that is respectful of the complexity of this question. Furthermore, because the Commission s work is nested in the provincial commitment to reduce poverty, benefit structures must meet the objective to reduce poverty. With respect to measuring poverty, the province established the Low Income Measure (LIM) as its measure of poverty in its' poverty reduction strategy released in December 2008, and it therefore, uncertain what impact this may have on the Commission s final is, recommendation regarding an appropriate measure.. Considerations Feedback from local stakeholders stated that the rates are not adequate and should be set so that individuals have enough money to afford minimum shelter costs and average nutritious food, and that the rates should be adjusted to reflect local costs rather than set provincially, and not be less than the LIM (the provincial measure set for poverty reduction). Local participants told the Commission that social assistance rates for shelter need to match minimum rental rates for the community. The Commission should understand that if the province decides to implement a housing benefit instead, it must not displace existing rent subsidies and be available to the all households that qualify. In other words, the number of recipients should not be capped. Adequacy must also be accompanied with corresponding labour market supports which could be done by completing a Living Wage assessment for all communities in Ontario and offer tax benefits to employers who pay a Living Wage to their employees. As with benefit structures, fairness lies in raising the bar for all families living in poverty and not pitting of benefit structure people receiving social assistance against low wage earners. Part of raising the bar includes considering the provision of dental and drug benetits for all low income households. The Senate s Commission on poverty and homelessness recommended that all tiers of government work together towards a national pharmacare program. The Commission should be discouraged from creating divisions in any way including their proposed two-rate approach based on how long someone requires social assistance. This may create additional complexity rather than streamline or make social assistance easier to understand. Furthermore, time restrictions for social assistance are intended to be a deterrent. This strategy implies that there is a high portion of social assistance recipients who strategy need stronger motivation to move off of assistance into employment. However, the Commission notes that less that 25% of cases "experienced a continuous period of receiving Ontario Works of two or more years between 2003 and 2009" (A Discussion Paper: Issues and Ideas 2011:9). Niagara, the average time receiving assistance is 13 months compared to the provincial average of 16 months. Only 19% of Niagara s caseload receives assistance for greater than 24 In months. The two-rate approach option deters attention from adequately responding to the majority of people who need social assistance because they are poor and unemployed and not because they choose not to work.

12 Page 12 of 15 Special diet allowances are provided to people who are poor if they meet certain medical conditions. Their financial eligibility for social assistance already establishes that they meet the condition of being poor; therefore, any medical benefits should be rationalized by medical Asking case workers to determine eligibility for medical or dental services is beyond their expertise and places the individual and the delivery agent at risk. However, transferring the benefit to the Ministry of Health and Long Term Care would mean that they would have to develop a way to provide benefits to individuals. An alternative for the Commission to consider was outlined in many of the submissions to the Commission regarding the $100 food supplement for people receiving social assistance. Some of Niagara s local councils advocated for the supplement as well. Increasing benefit rates so that they allow individuals and families access to nutritious food supports better health. professionals. Chapter 3: Easier to Understand Diverse groups agree that the complexity in the social assistance system is confusing to recipients and workers. However, simplifying social assistance must not reduce accountability for public programs. The Commissioners suggest moving from the current "surveillance" model to a more targeted "audit-based" approach to maintain compliance with system requirements. This chapter also speaks to the relationship between the asset levels individuals/households receiving social assistance are permitted to keep relative to their ability to make the transition to work. There are proposed approaches for relaxing limits on asset accumulation and a suggestion that there be a single total asset limit set rather than limits designated by different asset classifications. Questions 1., Should the social assistance system move from a surveillance approach toward an auditbased system of verification and monitoring? What penalties would be required and feasible in an audit-based system? What is the right level of risk tolerance, in either the current system or an audit-based system? Should asset limits be changed? lf so, how? Commentary OMSSA s submission to the Commission proposed an income support system that is "investment oriented", meaning that income security systems must prevent individuals and families from descending into poverty and help people living in poverty to emerge successfully and permanently. Participants in Niagara s community conversations spoke to the isolation that comes from poverty and the gradual stripping of assets as individuals fall into poverty. One participant described his fall from grace as a husband, worker, and father who lost his job, health, home, and family. While an audit system may seem less punitive, individuals who are most marginalized would be disadvantaged depending on the consequences that follow this new proposed process. For example, many people who are homeless have difficulty keeping identification and documents that would be required in an audit situation, and if an audit system were adopted, there should be supports available to assist individuals to keep records.

13 Page 13 of 15 Considerations The based on a surveillance approach meaning that "the measures in place to and reduce misuse involve intensive, time-consuming verification processes, applied to all clients at all steps of the eligibility process" (Oueen s Press 2012:38). According to the Discussion Paper, the surveillance approach takes up many of the system s resources with little evidence of a high return. The last review undertaken by the parliamentary assistant to the Minister of Community and Social Services (2004) found that the system had more than 800 rules. Eligibility verification needs to happen up front; ensuring individuals are receiving the amount of assistance to which they are entitled is crucial because there is very little capacity for an individual to repay assistance that is incorrectly issued to them. More research is needed to assess the current system s risk tolerance level based upon evidence of noncompliance. Individuals are compliant or can self-correct when the rules are easy to follow. The Commission s intent is to encourage employers to hire more people receiving social assistance, and therefore it is important that other requirements do not reinforce the stereotype that people receiving social assistance are individuals prone to fraud or that the social assistance system is at greater risk of abuse than any other government provided benefit such as public health care or education. current system ensure is compliance The Senate s Committee on poverty and homelessness reduction recommended that asset be increased for individuals and families applying for government assistance programs for the first 6-12 months to allow time to "regain economic footing". This action would also complement the provincial commitment to reduce poverty. In Niagara, increasing prosperity is recognized as critical for improving financial, health, and social and community vitality. limits _ Chapter 4: Viable Over the Long term. This chapter poses three options for the integration of sen/ices: (a) status quo with the separate delivery of and ODSP; (b) to create a "one-stop delivery model that would integrate Ontario Works and ODSP at the local Ievel"; or (c) to have municipalities administer case management and employment services while the province delivers the income support component. Questions 1. What are the strengths and weaknesses of these three approaches to the delivery of Ontario Works and ODSP'? Are there other approaches that should be considered? 2. Should Severe. full Temporary Care Allowance or Assistance for Children with be transferred to the Ministry of Children and Youth Services'? responsibility for Disabilities Commentary OMSSA and AMO have long advocated for a one-stop delivery model that would integrate employment and social assistance at a local level. This option is preferred because municipalities have developed the capacity and relationships to deliver an integrated social assistance program tailored to the needs of their communities. As well, municipalities are a gateway for other human services such as childcare and subsidized housing, and some direct delivery Employment Ontario programs (e.g. Waterloo, Windsor). However, the Commission limits integration to and ODSP. This model presents some risks because the intent of and ODSP are not interchangeable. While is the program that s most in need of

14 Page 14 of 15 improvement, much of the focus in ODSP. The such as OMSSA s s problematic traits the Social Assistance Review has been on overall risk, therefore, is that instead of getting the best out of proposals will recommend ODSP picking up some of such as making benefits conditional upon participation in employment activities. Unlike which helps people with economic challenges, ODSP was created to help people with specific needs. Of concern is that the Review intimates that people with disabilities will be defined based on who can and cannot work and that this definition will be accompanied by mandatory submission, the Review treatment or participation in work-related activities. Currently, disabled able to voluntarily participate in employment activities ODSP recipients are Niagara, Community Services has worked with other levels of government, service providers, education and the Niagara Workforce Planning Board to develop an Integrated Labour Market In (COM Integrated Labour Market Planning Project). This plan sets out Niagara s vision for an integrated and streamlined system that responds to the needs of employers and workers because it recognizes that employment services shouldn t be structured according to income source but instead should focus on helping people to find and keep adequate jobs and should help employers looking for workers. Participants at the Commission s visit to Niagara said that service systems need to have the client at the centre and that government funding can silo programs and makes accessing services difhcult. Niagara s vision of income support and employment services goes beyond the boundaries proposed by the Commission toward a system that sees integration based on the perspectives and capacities of employers and job seekers rather than funding streams. Plan Temporary Care placed in and should reside instead with programs that support children at risk. Although the primary intent is income support for children, these vulnerable children are often further marginalized because there is no comprehensive policy framework to address their special circumstances. is ill Chapter 5: An Integrated Ontario Position on Income Security This chapter focuses on social assistance being more compatible with, and complementary of, other service and support programs administered primarily by the federal government. Are there major and problematic program interactions that we have not mentioned here? What position should the Commission recommend that Ontario consider taking on specific intergovernmental issues, including First Nations issues, related to income security? Commentary Income support and employment programs need to be enhanced so that they respond to the need they were designed to address. For example, the federal, provincial and territorial workers compensation programs should be harmonized and Employment Insurance reformed to respond better to contemporary labour market conditions. These reforms must ensure that El adapts better to anticipated economic peaks and downturns rather than be based solely on recent or past experience. For Ontario and Niagara this is of particular concern because less than 40% of El contributors are eligible for EI benefits. Since the downturn in the economy began in the third quarter of 2008, Niagara s social assistance caseload has increased by 41%. Many poor unemployed workers apply for while they are waiting for their claims to be processed by federal services. This process means that

15 Page 15 of 15 individuals and families must deplete assets in order to qualify for a program because they are waiting for their application to be processed by another program. Chapter 6: First Nations and Social Assistance The Commission has held separate consultations with members of First Nations communities. These discussions informed their overall approaches to reform but there are issues unique to the needs of First Nations communities. The Commission notes that First Nations people see that new relationships must be developed between the federal and provincial governments and First Nations. As well, existing agreements do not adequately cover First Nations members with disabilities, which creates problems with respect to accessing ODSP. First Nations call for greater control over and access to employment services and special supports such as addiction services. Questions 1. How well do the various approaches set out in the desire for greater control and V 2. flexibility previous chapters align with First Nations with respect to social assistance reform? What other approaches should be considered to meet the needs of First Nations? What position should the Commission recommend that Ontario take with the federal government on issues related to First Nations and social assistance? Considerations As noted identified in the "BuiIding a New Legacy" report (COM ), numerous studies have Aboriginal peop e s experience of systematic discrimination as "pervasive and endemic." Comparatively speaking Aboriginal people have a higher proportion of the population living in poverty. Consequently, service planning and system design must be responsive to Aboriginal people s unique needs and experiences.