Introduction
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The Ontario Disability Employment Network (the Network) is a professional body of employment service providers that operate in Ontario. Our vision is that all people who have a disability in Ontario have access to the labour force and the ability to achieve meaningful employment. By âmeaningful employmentâ the Network subscribes to jobs that meet the requirements of the Employment Standards Act; are paid at commensurate wages and that add value to the economic and social well being of people who have a disability.
Member organizations represent all disability groups and types. Some are specialized (service one specific disability group) while others service a broader range of disabilities. They also represent agencies that access the full range of employment funding options â Ontario Disability Support Program Employment Supports (ODSP-ES), Employment Ontario (EO), Service Canada Opportunities Fund (Service Canada OF), Ministry of Health and Long Term Care (MOHLTC), Ministry of Community and Social Services Developmental Services Act (MCSS DSA) as well as private grants and donations. Some agencies access only one funding source, e.g. MCSS DSA funding, while others access multiple funding sources.
The Network facilitated, and participated in, group discussions with service providers, advocacy groups and service users from across the province. This is a summary of our findings.
Index
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Executive Summary  ……………………………….. 4
Principles and Values â Employment Services  ……………………………….. 4
Principles and Values â Income Support and Benefits ……………………………….. Â 8
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Features of Effective Services and Supports
Consistent Assessment and Case Management  ……………………………….. 9
Integrated pre- and post-Employment Services and Supports ……………………………….. 10
Access to the Same Level of Services and Supports ……………………………….. 10
Strong Connections with Employers  ……………………………….. 12
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Discussion Questions
How Can Employment Services be Made More Effective  ……………………………….. 13
Encouraging Greater Consistency  ……………………………….. 15
Standard Assessment Tools  ……………………………….. 16
Employment-Related Participation Requirements  ……………………………….. 17
Tools to Assess Work Capacity  ……………………………….. 18
Engagement Strategies and Incentives for Employers  ……………………………….. 18
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The Options
Improved Provincial â Municipal Relations  ……………………………….. 19
Municipalities Deliver all Employment Supports ……………………………….. 20
Employment Ontario Delivers all Employment Services  ……………………………….. 21
Appropriate Benefits Structure
Adequacy and Wage Benchmarks ……………………………….. 22
Setting Rates  ……………………………….. 23
Health Benefits for All Low Income Ontarians  ……………………………….. 23
Two Rate Approach ……………………………….. 24
Earned Income Supplements  ……………………………….. 24
Housing Benefits and Fairness  ……………………………….. 25
Discussion Questions â Disability Specific
Income Supplements for low-Income People who have a Disability ……………………………….. 25
Separate Basic Income Program for People with Severe Disabilities  ……………………………….. 26
Rate Structures
Rate Structures, Verification and Monitoring  ……………………………….. 26
Dietary Needs  ……………………………….. 27
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Easier to Understand
From Surveillance to an Audit-Based System  ……………………………….. 27
Penalties  ……………………………….. 28
Risk Tolerance  ……………………………….. 28
Recommendations
Short-term (Immediate to 2 years) Â ……………………………….. 29
Medium-term (2 years to 5 years) Â ……………………………….. 30
Long-term (5 years +) ……………………………….. 31
Appendices/Attachments
Appendix A â Path to Employment
Appendix B â Barriers to Employment
Appendix C â MCSS Supported Employment Code Explanation
Executive Summary
The Ontario Disability Employment Network would like to commend the Commission for under-taking such an in-depth and detailed review of Ontarioâs Social Assistance system. There are many concepts and ideas within the second discussion paper: Approaches for Reform that the Network supports.
Everyone seems to agree that the status quo is not acceptable and a major overhaul of the system is required. As the Commission stated; âwe need to transform the social assistance system; small fixes will not be enough.â The challenge is to turn what some feel is the âimpossibleâ into manageable steps and actions that will move the system forward.
In the final chapter of this report, the Network has made 37 specific recommendations. These recommendations have been divided into short- (immediate to 2 years); medium- (2 â 5 years); and, longer- (5 years +) term actions. We believe these actions will help transform the employment service delivery system to one which is stronger, more responsive and more effective without de-stabilizing the lives of people who have a disability who depend on these services or the employment service agencies that have decades of experience to contribute.
Many of these recommendations will not require financial resources. Rather, we believe they will create immediate and transformative improvements to the system. At the same time, many of these recommendations will result in significant financial savings that can be re-invested in the system. With significant improvements to the employment services system, more people will be encouraged to pursue this option. The system, in turn, must build its capacity so that it can respond accordingly.
Principles & Values â Employment Services
First and foremost it is important to recognize that âemployment servicesâ is more than just the transfer payment agencies that provide direct services to people who have a disability. Government Ministries that set policies, regulations, funding mechanisms and manage both people who have a disability who want to work and relationships with transfer payment agencies must also be viewed as âemployment servicesâ in this context. To state that employment services are ineffective in Ontario, in turn, means that âGovernmentâ is complicit in this ineffectiveness.
Affecting positive changes that will improve employment services and lead to better employment outcomes for people who have a disability, will require a collaborative effort by Government, employment service agencies, people who have a disability and business.
People who have a disability must be viewed as a distinct target group, separate from general welfare (OW) recipients. While they may share the commonality of dependence on the state for financial assistance and benefits, services and supports for people who have a disability are very different and highly specialized. So much so, that the degree of specialization is often unique and based on the specific disability. At the same time, disability is typically âfor lifeâ as opposed to short term or intermittent.
We applaud the Commission for recognizing the essential elements of effective services and supports that must be available to people who have a disability. Many people who have a disability can work and want to work, provided they have access to effective services and supports.
These services and supports must be integrated and coordinated in order to achieve better employment outcomes. It must also be recognized that not all people who have a disability will need all of these services. Nor are they necessarily linear from a delivery perspective. People who have a disability must simply be able to access the services they need, when they need them.
As a general principle, the Network believes that government, whether provincial or municipal, should not be in the business of direct service delivery. Rather, it should retain the role of âservice managerâ and contract direct services to third party delivery agents.
Assessments must not be used to determine eligibility or to screen people out. People must not be denied access to employment services and supports based on the severity of their disability. Assessments must be individualized and flexible as a means to assist people to determine a career goal and path and to identify the supports they will need to be successful. A variety of assessment tools and formats must be available ranging from pre-employment preparation programs and time-limited work experience programs to more formal assessments.
The Network believes that both Assessment and Case Management should be managed by the primary service provider with an option to contract out or purchase formal assessments where appropriate.
Capacity assessments, on the other hand, are fraught with problems and should not be considered at this time. There are many improvements and savings to the system that can be achieved before considering this question and approach.
Employment outcomes should be broadened to include a greater range of performance measures. The Network concurs with the conclusions of âWhen the Bough Breaksâ and believes these apply equally to people who have a disability. It is to everyoneâs advantage to support people for a longer period of time. Given the nature of the labour market, people will need additional supports (beyond placement) to grow their careers and further reduce or eliminate their dependency on the income support system. Employers will be more open and willing to hire people who have a disability if they are confident that support will be available to them over the long term.
Employment service providers must be compensated for providing these additional supports through a more integrated funding system.
Should ODSP continue to be a primary support for people who have a disability in the future, they must put more emphasis on helping people prepare for and find employment. Services and supports must be better integrated and available from a single employment service provider with an option to outsource specific services and targeted interventions, I.E. formal assessments, skills training, etc. People who have a disability must also have access to mainstream services and supports that are available to others with employment barriers. They must have a choice as to where and when they access these services and supports.
Early intervention is the key to helping people bypass the Income Support system. It is critical that government give serious consideration and make strategic investments in youth employment initiatives. At the same time, employment service agencies must be compensated at the same level for supporting eligible non-income support recipients.
The Network strongly supports the Commissionâs goal âto make recommendations that will respond to the work aspirations of people with disabilities and support their participation to the maximum of their abilities.â However, we do not believe that people who have a disability should be compelled to work through mandatory participation regulations given the number of barriers that are beyond their control.
If conditions are favourable and quality services and supports available, many more people who have a disability will chose to pursue employment.
Strong connections with employers are critical to success. Employers must be seen as a âcustomerâ and additional resources are needed to adequately and appropriately service this customer. The greatest incentives for employers are often those that alleviate their fears and reduce their perceived level of risk. This, in conjunction with the trust and knowledge that the agencyâs services are of high quality and available over the long term are often enough to convince an employer to hire.
More effort is needed in the area of employer education and awareness. While there is speculation that the AODA will enhance employment opportunities, there is also speculation that it may have a short-term negative effect as employers attempt to âduckâ government involvement and compliance requirements. Many of todayâs, business-to-business campaigns like the Networkâs Champions League and Rotary at Work, attempt to show businesses the âcarrot, rather than the stickâ when it comes to the benefits of hiring people who have a disability.
Marketing to business should not be designed and delivered by government. Business is generally shy of government initiatives. Rather, government should support marketing initiatives developed and implemented by third party providers.
Revisions and improvements to the employment services system must ensure employment service providers spend more time on service delivery and less time on administration. Managing multiple service contracts, reporting relationships, data bases and accountability processes is not efficient and takes time and resources that could be better spent on delivering services and supports. This will require a single source funding relationship. Further administrative efficiencies can be gained by moving to an audit based accountability system for those people who have a disability who work.
Supported Employment, which has some distinct service characteristics, is defined as paid employment â âreal work for real payâ. While it was initially launched as a strategy to engage people who have an intellectual disability in employment, it has been adopted by a much broader audience as a successful service technology. The Commission should not overlook the impact of the DS Sector and DS Branch of the MCSS in its review of employment services in Ontario.
The Network agrees that Government must make a greater investment in employment services for people who have a disability. Much of this investment can be found in the administrative efficiencies identified in this report. Investment is needed to increase the capacity of service providers as well as in professional development and innovation. Funding for employment service agencies need to balance core operating costs with performance-based incentives.
Once an effective operating environment is achieved, employment service providers that consistently under-perform should be phased out.
People in receipt of ODSP need greater incentives to work and the security that they will not be financially worse off by working or penalized if they fail in the workforce.
The Network strongly supports the Drummond concept that government must invest more money in people that need more support. At the same time, if Government wants to see more people get jobs, they must build the capacity of the employment service sector to respond. There is no value in assessing people as to their needs, if appropriate services and supports are not available.
The Network does not believe that employment services should be consolidated under EO. Fundamentally, we believe the Ministry of Training Colleges and Universities does not have a good understanding of the unique needs of people who have a disability when it comes to employment services and supports. Furthermore, the types and amounts of services and supports people who have a disability need does not fit the One-Stop model that MTCU is mandated to provide. We strongly believe that under this model, people who have more significant disabilities will fall even further behind.
Irrespective of which delivery option is chosen, inter-ministerial collaboration is a fundamental requirement. All government ministries and departments that touch on any aspect of disability is in a position to positively or negatively impact employment outcomes for people who have a disability. One ministry or department should not be initiating programs or services that compete with or undermine employment options and opportunities.
Service participants and employment service providers must have significant input into what the new system should look like.
Principles & Values â Benefits
Adequacy levels are an overriding and dominating issue that needs to be addressed. As the Commission has pointed out, this exercise must unfold through a poverty-reduction lens. For people to consider pursuing employment there must be a sense of financial stability and security. In addition, consequences for failure in the workforce must be minimized or eliminated.
The Commission must look at the combination of income support and wages with improved incentives that encourage people to try working. Adequacy and financial stability/security must also consider; medical benefits, specific disability-related supports (E.g. special diet allowance), child care and housing. People with disabilities need the security of knowing that health benefits will be stable, irrespective of their status in employment or social assistance. In some cases the disability itself will result in a higher dependency on medical benefits.
The Network believes, in principle, that health benefits should be available to all low-income Ontarians. There is a cost of providing health benefits, but there is also a cost of not providing health benefits.
The Network does not support a two-rate approach. Instead, we support a system that âincreases asset limits for an initial period of time when an individual first enters the programâ.
There should not be a separate, basic income program for people with severe disabilities. Supplements, due to additional costs associated with the disability may be considered as should different services and supports. However, the Network and its members believe the notion of dividing disability into two groups based on employability has some severe consequences. The proposed concept will entrap people in the social assistance system for life.
While there is some concern that record keeping may be a bigger problem for people who have a disability, most people seem to be satisfied that, with proper support, people who have a disability should be held to the same standard as other citizens.
It is imperative that people understand the rules that govern the income support system. This includes those who manage the system, service recipients and the support organizations and advocacy groups that act on behalf of people who have a disability. Materials and documents related to the income support system must be available in plain language and in alternate formats.
Chapter 1: Reasonable Expectations and Necessary Supports to Employment
Features of Effective Services and Supports
We applaud the Commission for recognizing the essential elements that create effective services and supports. The overview of these services and supports is very much in keeping with those identified by the Network (see Appendix A â Path to Employment). The following reflects some of the comments/clarifications and recommendations from our constituents:
Consistent assessment and case management:
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Assessments must be individualized and flexible. The type and intensity of assessment must respond to a variety of situations – the type and/or level of disability; career goals; degree to which the individual is self-directed; etc. Often, for people who have a disability, the most critical assessment is the determination of individual motivation, reliability and dependability (MRD). This is often determined through participation in pre-employment preparation programs. Pre-employment preparation programs are also valuable in assisting the service provider to get to know the candidate. This greatly assists in ensuring a good job âmatchâ.
Work experience should also be considered a form of assessment and is often built into pre-employment preparation programs. Guidelines are needed to ensure work experience placements are time-limited and curriculum-based and not simply âfree labourâ or never-ending.
Formal assessments are more common where the individual wishes to pursue a particular career goal, skilled trade or profession; or, where there is question about the stability of someone who has a mental health or medical disability.
Assessments must not be used to determine eligibility or to screen people out. Everyone who is motivated to work must have access to the employment delivery system. It is not uncommon to find employment for a highly motivated individual with an accommodating employer even though the severity of their disability may seem impractical or insurmountable on first encounter. In a 2003 study of over 2,500 people who had a disability and who engaged service agencies for assistance to find paid employment, the most successful disability group was people who have an intellectual disability. On a per capita basis, this group was the most successful at both getting jobs and in their job retention. (See http://www.odenetwork.com/library/employment-outcomes-project-report-sept-2003/ for details.)
Case management must be provided by the primary service provider. Again, this is an individualized and flexible service that is very dependant on the individualâs needs and ability to self-manage their services and supports. Case management is more successful when provided by the primary service provider as the service provider is a âconstantâ in the employment delivery process and most often is the one that is setting up appointments and interviews and assisting the candidate to achieve their goals. Often third party case management is not readily available and typically is not responsive to the needs of the individual in a timely way. This service is best provided by those who work with the individual on a day-to-day basis.
In the early launch of ODSP ES, Assessments were routinely performed as a separate, stand alone service and often by third party assessors. Experience has shown that these assessments tended to be âformula-drivenâ, were often unhelpful to the employment process, irrelevant and rarely addressed the match between a motivated candidate and an available opportunity. Valuable resources were wasted when each individual was required to undergo a mandatory assessment by these third-party assessors. Third party assessments should be available by exception rather than the rule.
The Network believes that both Assessment and Case Management should be managed by the primary service provider with an option to contract out or purchase formal assessments where appropriate.
Integrated pre- and post-employment services and supports:
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The Network agrees that outcomes âshould be broadened to include performance measures related to pre-employment activities and addressing barriers to employmentâ for people who have a disability. In general, it would be advantageous to support people for the long run and in a more holistic way. In this respect the conclusions of âWhen the Bough Breaksâ apply equally to people who have a disability.
Despite the funding limitations of ODSP-ES and EO, some service providers offer on-going support to people who have a disability and to employers through pre-employment preparation programs, job coaching and trouble-shooting. These service providers often have access to other resources and/or supports, financed by Service Canada, DSA or MOH funding. In addition they frequently address âoff the jobâ issues like housing, transportation, budgeting, financial reporting, etc. These service providers tend to have better employment outcomes than those who operate with only one funding source. (See http://www.odenetwork.com/library/employment-outcomes-project-report-sept-2003/ for details.)
Given the changing labour market, people who have a disability often enter the workforce in low, entry-level positions, often working part-time without benefits. While this is a good first step, in order to reduce and eventually eliminate peopleâs dependency on ODSP-IS, additional supports may be needed. This will help people grow in their career and/or assist them to get new or second part-time jobs. This is particularly important in the current labour market.
Access to the same level of services for people who have a disability:
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ODSP must put more emphasis on helping people who have a disability prepare for and find employment. People who have a disability can work and want to work. They must have access to the same range of services, including skills upgrading and training as other groups, in addition to disability-specific services and supports.
People who have a disability need access to the full range of services and supports, from pre-employment preparation & training to job placement and post-employment supports. These services and supports must be better integrated and, in general, available from single source service providers. Employment service providers may need to outsource specific services for targeted interventions as needed; E.g. skill specific training.
We support the Commissionâs conclusion that early intervention is important for people with mental illness. In fact, we believe early intervention should be seen as a critical investment for all people who have a disability. Early intervention is key to helping people bypass the Income Support system. People who have a disability often graduate from high school, college or university with little or no work experience, no practical experience for their resume or understanding of realistic career goals. The need for financial security while the individual is struggling to gain employment typically âdrivesâ them to the Income Support system and the longer a person is receiving ODSP-IS, the more difficult it is to help them leave that system.
Graduating from school with practical work experience raises the expectation that work is the next logical step for people who have a disability. Service providers are seeing more people who have a disability who are not in receipt of Income Support in cases where those individuals have had access to co-op placements, summer employment and after school jobs.
We appreciate the Commissionâs goal âto make recommendations that will respond to the work aspirations of people with disabilities and support their participation to the maximum of their abilities.â This aligns with the Networkâs position that people who are motivated should have access to the labour market and the services and supports that will help them achieve this goal. However, we do not believe that people who have a disability should be compelled to work through mandatory participation regulations.
There still remain too many barriers, many of which are beyond the control of people who have a disability, to mandate participation. (See Appendix B â Barriers to Employment) Business and the labour market are not yet ready to support full participation and the service system does not have the capacity to support full participation. Current, government policy frameworks and funding do not support full participation and many families and individuals with disabilities are very risk adverse with respect to the loss of income support and benefits. Furthermore, it is extremely difficult and costly to force âmotivationâ with people who have no desire to work. Who would be held responsible for a lack of success due to lack of motivation, and who would be covering the cost of providing these services?
At this time, active engagement in the labour market should be limited to and focused on youth through further development of youth employment programs and mandated work co-op placements while in school.
The Network would like to caution the Commission with respect to capacity assessments. This could have a number of negative impacts on the system. Assessment tools tend to be unreliable when it comes to determining employability and can create a dependency for life for many people who might otherwise work. Often the impact of disability changes, technology advances and new and creative ways to construct employment emerge. Additionally, opportunity often emerges when least expected. These opportunities should not be overlooked.
Finally, it is our experience that capacity assessments are often used to screen people out or to determine that people are too costly to serve. Assessors, particularly government case workers, are often out of touch with the business environment and the opportunities that may be available.
Strong Connections with Employers
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The Network and its members strongly support the direction of the Commission with respect to employer engagement. Current funding models do not provide sufficient resources for effective marketing campaigns and often limit longer term coaching, trouble shooting and other interventions, customer service and quality assurance. The relationship with employers and the business community is critical in terms of creating employment opportunities, repeat business, and ensuring job retention, including career advancement and growth.
The connection with employers needs to be done at the local level. While there is a need for âbig pictureâ marketing and education campaigns, it is the relationship at the local level that ensures a strong relationship and that businesses trust the service agency and have access to the on-the-ground services and supports that both employees with disabilities and businesses need.
Business-to-business educational programs have proven to be successful and government should support these types of initiatives. Unfortunately, government-led initiatives like âDonât Waste Talentâ have been less successful. Business operators tell us the message just doesnât resonate with them.
There are mixed reactions to programs that provide incentives like tax breaks and wage subsidies to employers. Many of the Networkâs members find that wage subsidy programs help create opportunities for people who have a disability but that these opportunities too frequently end when the subsidy runs out. As a result many donât utilize wage subsidy programs or use them only as a measure of last resort. The principle is that when an employer pays the individual, they are, in essence, investing in that person and therefore more committed to a successful outcome. Wage subsidies may be considered legitimate where there is a real cost to the employer that is directly related to the disability.
The incentive for many employers is the trust that the agencyâs services and supports will be available over the long term. The security of knowing that support is just a phone call away, is often all the reassurance the employer needs.
The Network recommends that an independent review of wage subsidy initiatives be undertaken. Such a study could examine which employers use wage subsidies and why, how many jobs were created as a direct result of wage subsidies and, what the job retention rate was after the subsidies ran out. With resources so scarce, we need to justify where they are spent and ensure they are being put to good use.
Discussion Questions
How can employment services be made more effective?
First and foremost it is important to recognize that âemployment servicesâ is more than just the transfer payment agencies that provide direct services to people who have a disability. Government Ministries that set policies, regulations, funding mechanisms and manage both people who have a disability who want to work and relationships with transfer payment agencies must also be viewed as âemployment servicesâ in this context. To state that employment services are ineffective in Ontario, in turn, means that âGovernmentâ is complicit in this ineffectiveness.
Employment services must be coordinated and integrated at the government level as well. The Ontario Disability Employment Network strongly recommends that government create a policy framework related to employment for people who have a disability. Such a framework must set the parameters that all Ministries and departments that fund services for people who have a disability (not just employment services) must adhere to.
Recognizing that the implementation of a policy framework will be a longer term proposition, the Network recommends the Commission set out short-, medium-, and long-term goals. These might include:
- Creating an inter-ministerial committee with a mandate to look at employment issues, policy and funding as well as the relationship to other non-employment services for this target group (including Ministries of; Education, Training Colleges & Universities, Community and Social Services, Health and Labour)
- Enhance the provincial Accessibility Advisory Committee guidelines to include accessible employment (currently, accessible employment is not included in the provincial mandate for Municipal Accessibility Advisory Committees)
- Including summer and after school employment for students in the new employment delivery system
- Create policies that any ânewâ money allocated for daytime activity programs is to be directed toward employment programs
- Develop a transition strategy for existing sheltered workshops and day programs that want to convert to employment programs
- ¡ Ensure other funding programs for people who have a disability do not conflict with, undermine or otherwise compete with employment programs (Currently individualized funding models for people who have an intellectual disability are largely unregulated and often used to establish unpaid work in the private sector. As recently as February 2012 the DS Branch of MCSS set out service code guidelines for its transfer payment agencies that not only condone, but promote, unpaid work in the private sector. Given the recent Human Rights case http://www.yorku.ca/ddoorey/lawblog/wp-content/files/Garrie-v.-Janus.pdf where a private business owner was found to be in contravention of Ontario labour law for such practices, it is difficult to understand why one branch of government would promote activities to its Transfer Payment Agencies that clearly contravene the law. (See Appendix C â MCSS Supported Employment Code Explanation)
- A mandate to provide co-op work experiences to all students who have a disability
- Review funding of day programs under the DS Branch and Ministry of Health to determine the extent to which these Ministries are supporting employment programs* The Commission should not overlook the degree and potential impact of these two funding streams if we are to achieve a single funding stream for employment services.
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Along with this policy framework, the Network also recommends moving to a single source funding stream for employment services for people who have a disability. A move to single source funding will achieve efficiencies both at the service level and financially for both the Government and transfer payment agencies. The savings and efficiencies must then be reinvested in the service delivery system.
We must find ways to ensure employment service providers spend more time on service delivery and less time on administration. Service agencies that currently spend countless hours managing multiple funding contracts; administering several different databases; managing different reporting and accountability measures; and, managing relationships with various Ministry program officers, could redirect those resources into providing more services and/or creating effective marketing initiatives, training staff and managing quality assurance programs. Entire departments within Government Ministries that manage service contracts and client case workers could be reduced or eliminated, again, saving precious resources that could be re-invested into increasing and improving employment services.
There needs to be standards of practice for employment service agencies. Such standards go beyond current Ministry requirements and should include business practices such as: ensuring operators have annual work plans; marketing initiatives are in place; training and professional development for staff; quality assurance programs; client satisfaction programs; customer service standards; and, etc.
Recognizing there will always be resistance to standards, this will be minimized if they are developed by the sector in consultation with service participants, employers and government rather than being developed by government alone.
Government must make a greater investment in employment supports for people who have a disability. As noted in the Commissionâs report, âthere is little focus on helping people receiving ODSP prepare for, and find employment. Investments must be made in professional development and innovation. Since the advent of ODSPâs outcome based funding model, professional development has all but been eliminated. We are now seeing the consequences of this as staff skill levels are not maintained and turnover has meant many more people are working in the sector without the pre-requisite skills. At the same time, without innovation, and resources to encourage and support innovation, service models stagnate and new service technologies fail to emerge as people retrench around old ways of doing business. Since the advent of ODSP-ES, this has become the current state of the industry.
People in receipt of ODSP need greater incentives to work (see chapter 2) and security that, if work fails, they will not be destitute. Employment service providers also need incentives and an understanding that excellence in performance will be rewarded. This comes with the caveat that a 13 week job is not the only performance indicator.
Once improved policy structures and funding frameworks are put in place, service providers that consistently underperform should be phased out.
While the Commissionâs report takes an in-depth look at Income Support, including incentives to work, there needs to be a more detailed and comprehensive study of best practices in employment services to identify the key factors that contribute to superior performance.
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?
Some suggestions that have already been made will encourage greater consistency while allowing for local flexibility and innovation.
- Enhance the mandate of Municipal Accessibility Advisory Committees
- Engage the employment service sector in the design and development of standards of practice
- Create a provincial resource that is designed to support innovation
- Better coordination between various departments of government by establishing an inter-ministerial committee on employment for people who have a disability
Additional strategies might include creating a Provincial advisory/oversight body. This could be similar to an âOntario College of Employment Servicesâ with input from service participants, advocacy organizations, employers, service providers or their networks and Government. This body could be responsible for creating and monitoring service standards, addressing issues related to training and professional development, complaints and appeals, etc.
Alternately or perhaps, in addition, an advisory body of self advocates would be very helpful.
Further comment on consistency, local flexibility and innovation will follow in discussing the preferred delivery options.
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Should standard assessment tools be used to identify peopleâs needs and match them to appropriate services and supports?
Every individual is unique, as are the circumstances that surround them â the nature of their disability, their life circumstances, personality traits, family environment, external environment and the opportunities before them. It is not realistic to expect a single, standard assessment tool that can assess the needs of all people and match them to the services and supports they need.
There are some basic principles that the Network subscribes to, with respect to Assessments. They are:
- Focus on ability, what the person has to offer rather than their limitations
- Assessment tools should not be used to screen people out
- Pre-employment programs are vital and, in most cases, provide important assessment information
- There must be flexibility and a variety of assessment tools available
- People should be able to request a re-assessment at any time
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In general, there are two levels of assessments â one which assesses basic employability based on MRD (motivation, reliability and dependability) and a second that is more formal to assess skills and aptitudes for skilled jobs, trades and/or professional careers.
One of the critical factors related to assessments is that once an individual has been assessed as to their needs, they must then have access to the services and supports needed to be successful. Too often people are over assessed only to determine the appropriate services and supports are not available.
The Network strongly supports the Drummond concept that government must invest more money in people that need more support.
What should be considered appropriate employment-related activity participation requirements for people with disabilities? Should participation requirements for people with disabilities be different from those for other people receiving social assistance?
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As previously noted, we do not believe people who have a disability should be forced to participate in employment. Many of the barriers faced by people who have a disability are out of their control. There are still many businesses that do not welcome people who have a disability as well as challenges in accessing the labour market. There are physical accessibility issues, transportation, personal support needs, etc that create barriers. In addition, it will take time to improve the employment delivery and income support systems in order to assure people who have a disability that the risk-reward scenario is in their favour.
Forcing people who are not motivated to work or insecure with other aspects of their lives, will drive up costs due to increased efforts by service providers, higher failure rates and poor job retention.
As previously noted, active engagement in the labour market should begin earlier while people who have a disability are still in school
If conditions are favourable and quality services and supports available, many more people who have a disability will pursue employment. Having said that, it is imperative that more emphasis is placed on demonstrating that employment is a viable outcome for people who have a disability.
One of the simplest things that could be done to increase efficiency is to grant eligibility for employment at the same time that eligibility for income support is determined. Time and time again, we hear about lost opportunities. Employment service providers have employers willing to hire and candidates available to fill those positions, but by the time the ODSP Case Worker determines eligibility for the participant the job is lost. This can take as long as six weeks and employers just wonât wait. This is a needless step. Given, under the current ODSP outcomes-based funding model, the risk is on the service provider (as to whether or not they receive funding), we are unable to ascertain why this step is necessary. It is time consuming, an administrative burden and causes a loss of many employment opportunities.
It should be noted that once we increase the demand for employment outcomes, we must be able to respond with appropriate services and supports. The service delivery system will need to build its capacity to respond to that increased demand. Mandatory participation would add significantly to that capacity requirement.
Our recommendation is that the Commission focuses on other barriers within the system e.g. improving the delivery system, increasing employer engagement and acceptance, income security, housing etc. With such improvements in place, this may be a reasonable question for the future.
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?
The Network believes that capacity assessments are fraught with problems and should not be considered at this time. There are many improvements and savings to the system that must be achieved before considering this approach.
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What kinds of engagement strategies and incentives would be most effective in encouraging and supporting employers to hire more social assistance recipients?
As previously noted, the Network believes that an independent study on wage subsidies should be conducted. It is important to understand the level to which employers are also, if at all, investing in these employees and, therefore, vested in a successful outcome.
Alleviating employer fears with low risk options has had much success.
Some employment service providers have found that setting up time-limited work experiences has led to successful job offers. Often, at the end of the work experience, the employer is convinced that the individual can contribute to the workplace and commits to an on-going hire.
Some service providers offer options where they become the âemployer of recordâ for a short period. In these cases the service provider contracts with the employer and uses the contracted revenues to pay the individual. After a pre-agreed to time frame (4 to 6 weeks), the employer then decides as to an on-going hire.
Summer and after school employment has a double benefit. It is generally viewed by the business as a risk-free way to try a candidate who has a disability as there is an âend in sightâ. At the same time, this offers valuable experience to a young person who needs to build their experience, capacity and expectations with respect to work.
Some agencies offer on-going support for as long as the candidate is employed including âout-placementâ assistance if the hire doesnât work out. Many employers have told us that the greatest fear in hiring is the fear of firing. Alleviating this fear is a great relief to many employers.
In general, more work needs to be done to ensure and support employment service providers to view the employer as a âcustomerâ. Work places and jobs evolve over time and employers look to the âdisability expertsâ for on-going support. On-going customer service, including job coaching, trouble shooting and longer-term support such as re-training must be available. Local service providers must have the capacity and resources to build strong relationships with employers.
Much more effort and work needs to be done on employer education and marketing initiatives. Routinely we hear about labour shortages and the need to boost immigration as a primary solution to these shortages. We need to replace this mantra with one that suggests âa ready and willing labour source already exists, here in your own backyardâ.
Business to business models of educating and marketing work very well as evidenced by groups like Rotary at Work, the Networkâs Championâs League, JOINâs Business Leadership Network and others. These initiatives should be supported and developed further. There is a role for service providers to coordinate and support these efforts. However, if government assistance is provided, they must be held accountable through measures that assess their effectiveness, such as the number of businesses that have hired and the number of people employed as a direct result.
In general, marketing to employers should not be designed and delivered directly by government. The business mindset is that they want government âout of their faceâ and attempts by government to gain businessâs favour are typically rejected.
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The Options
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Improved Provincial-Municipal/First Nations Collaboration
While there is always room for, and a need, to improve Provincial-Municipal/First Nations collaboration, the Network does not believe this will result in the desired outcomes necessary to make significant improvement in the delivery of social assistance and employment services.
It is clear that no one is happy with the status quo and that major improvements are required. As the Commission has stated; âwe need to transform the social assistance system; small fixes will not be enough.â It is difficult to mandate and regulate collaboration and, based on past history, the Networkâs members are not convinced this will achieve the wholesale changes we need to make to the system.
Still, inter-ministerial collaboration is a must. There are many Provincial Ministries that have a steak in employment and disability â Ministry of Training Colleges and Universities, Ministry of Community and Social Services, Ministry of Health, Ministry of Education, Ministry of Labour and others. There must be an over-riding employment policy framework that each of these Ministries will operate within, regardless of which Ministry has the lead responsibility for employment services.
Service participants and employment service providers must have significant input as to what this system should look like.
Municipalities Deliver all Employment Supports
Under certain conditions, this would be the first choice of the Ontario Disability Employment Network and its members. Rather than integrating ODSP and OW into the EO system, we believe the disability portion of EO â mandate and resources along with ODSP-ES, MCSS DS Employment programs, MOH Employment programs and Service Canada OF, would all be better positioned with Municipalities.
Municipalities are more in touch with local issues and tend to be more flexible and supportive of the people who live in their communities. This would have a positive effect with respect to the delivery of Income Support and the integration of child care and housing supports.
Municipalities also tend to be better connected to local businesses and the local labour market. We recommend that municipalities will need to increase their profile and collaboration with local Training Boards and Employment Sector Councils in order to achieve greater success.
We believe this model will work if the municipality becomes the service delivery manager. Municipalities will then contract with third party delivery agents. Not-for-profit agencies that specialize in disability should play a primary role in direct service delivery.
This will require all monies earmarked for disability and employment, regardless of source, be funnelled through the Municipality as a single funding source. This should include the Service Canada Opportunities Fund. Service Canada can determine what the money is to be spent on, but day-to-day management should be by the municipality.
As a general principle, the Network believes that government, whether provincial or municipal, should not be in the business of direct service delivery. Rather, it should retain the role of âservice managerâ and contract direct services to third party delivery agents.
At the same time, people who have a disability must have access to mainstream employment supports provided by EO or other employment services. This will be particularly important to individuals who are self-directed or who want to pursue professional designations and/or certifications.
The key is to have a choice of service delivery agents and methodologies to ensure people who have more significant disabilities â people needing more intensive employment supports, those who need pre-employment preparation supports and those who are not self directed â have access to the labour market and are not screened out based on the severity of their disability.
The Municipality could be the primary point of access for people who have a disability. In this way, the Municipality will be the first point of reference for information about employment services and will provide referrals to the employment service providers.
We caution, however, that the concept of âjob readyâ is highly subjective and can create its own barriers. Job Ready is often used as the rationale to screen people out and the concept overlooks âopportunityâ (the right place at the right time and/or the right âmatchâ).
It also tends to lead to service options where people must be deemed âjob readyâ before being referred into the employment stream and many valuable resources are spent on âgetting people readyâ. Experience has shown that many people are successful learning on the job when this is combined with time limited pre-employment preparation programs that work toward finding the right âmatchâ and effective job coaching supports.
We recommend, rather, that people are given âchoiceâ as to service providers/streams and that employment service providers are best suited to assess and determine âjob readyâ. As noted, this is often a case of matching the candidate to an opportunity available in conjunction with the service providerâs capacity to provide the necessary services and supports.
Employment Ontario Delivers all Employment Services
Consolidated Employment Supports under EO is the least desirable of the three options. The Canada-Ontario Labour Market Agreement was developed in 2005 and launched in 2008 with a commitment from the Federal Government of $1.2 billion over 6 years. As per the Agreement, persons with disabilities are to be one of the recipient groups of the services and supports funded through this Agreement. While some previous contracts that service agencies held with the Federal Government are still operating, we are now going into year 5 of a 6 year program and MTCU has not been able to establish a disability strategy.
Fundamentally, we believe the Ministry of Training Colleges and Universities does not have a good understanding of the unique needs of people who have a disability when it comes to employment services and supports.
Furthermore, the types and amounts of services and supports people who have a disability need does not fit the One-Stop model that MTCU is mandated to provide. The EO model and resource base, as calculated on per unit costs of specified interventions, is not flexible enough, nor does it provide sufficient resources to support people who have a disability. As noted in the Drummond report, Government must invest more money in people that need more support. This concept is at odds with the EO method of operating where unit costs are based on interventions rather than on people.
One-Stop service models existed in the 70âs and early 80âs, known then as Canada Manpower Centres. Similarly, these Centres were not able to service people who had a disability. The majority of people who had a disability that went to Canada Manpower Centres looking for assistance were referred to sheltered workshops or specialized disability agencies. Their capacity to service this group, both in terms of available resources and expertise, was insufficient.
The Network has serious concerns that people with more severe disabilities will fall even further behind in this service model.
For the past two decades, the disability service sector has been phasing out sheltered workshops in favour of community-based employment and other community options. Sheltered workshops contribute to lifelong dependency on Social Assistance and generally provide menial and repetitive tasks with little benefit for participants. Government should continue to support efforts to phase these programs out, in favour of competitive employment. Transition supports may be needed to do so.
Regardless of options, there must be sufficient resources to provide the full range of services and supports for people who have a disability, as the Commission has so clearly identified. If a One-Stop model is chosen, there must be access to the specialized services and supports people who have a disability need.
Chapters 2 & 3
The Network focussed its discussions related to âbenefitsâ primarily on those issues that will reduce the barriers to employment. While many of the following questions are focussed on all income support recipients, the Ontario Disability Employment Network has responded specifically from a disability perspective.
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Chapter 2
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Appropriate Benefits Structure
Discussion Questions – General
Which adequacy & wage benchmarks should be used to set rates? Are there other measures that should be considered?
Adequacy levels are overriding and dominating issues that need to be addressed. As the Commission has pointed out, this exercise must unfold through a poverty-reduction lens. For people to consider pursuing employment there must be a sense of financial stability and security. In addition, consequences for failure in the workforce must be minimized or eliminated.
In a methodology for setting rates, what proportions would balance adequacy, fairness & incentives?
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In looking at rates, the Commission must look at the combination of income support and wages with improved incentives that encourage people to try working. Adequacy and financial stability/security must also consider the total package including; income support, wages, medical benefits, specific disability-related supports (E.g. special diet allowance), child care and housing.
Even though the current system provides some level of financial incentives, the negative impact on subsidized housing often removes this incentive and can place the individual in a negative financial position.
If responsibility for the employment service delivery system were to move to the Municipality, it would be easier to manage an adjusted benefit structure that recognizes all financial elements of people who are in receipt of income support.
Once adequacy and the total financial package issues are addressed, the Commission should build in additional incentives such as an adjustment to the claw back formula or an earned income supplement.
Some incentives would be non-monetary. That is, if the system were easier to manage and understand and was more fluid, people would be more likely to pursue employment. (See discussion re: rate structures)
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Should health benefits be provided to all eligible low-income Ontarians? If so, how should the cost be covered?
The Network believes, in principle, that health benefits should be available to all low-income Ontarians. There is a cost of providing health benefits, but there is also a cost of not providing health benefits.
People with disabilities need the security of knowing that health benefits will be stable, irrespective of their status in employment or social assistance. In some cases the disability itself will result in a higher dependency on medical benefits. In an employment setting, this may result in higher costs to the employer and such costs should be off-set in order that a person who has a disability is not seen as a greater financial burden than other employees.
Additionally, ODSP should review eligible prescriptions, relative to the disability-related needs of people who have a disability.
Government needs to look at revenue streams as a part of the resolution to this issue. It is unfair that each time government faces a revenue shortage that it is people who are most vulnerable who pay the price through cost cutting and cost containment measures rather than looking for new revenue sources.
Consideration should be given to folding the cost of medical benefits into the Ontario Health Tax base so that there is only one program of this type for employers to be concerned about.
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?
The Network does not support a two-rate approach. Instead, the Network supports a system that âincreases asset limits for an initial period of time when an individual first enters the program.â Consideration should be given for people, disabled or otherwise, who run into emergency or dire, short-term difficulty. This will mean setting a maximum time limit on receiving financial assistance, e.g. 3 months, without having to reduce assets beyond a reasonable level. This might include maintaining a primary residence & vehicle (to a certain value), pension plan, registered education savings plans, etc. At the end of the time frame, the traditional asset rules would apply.
The concept of this approach is to assist people from falling into long-term dependency by not forcing them to liquidate, within reason, those assets that can help maintain their longer-term financial stability and independence.
This approach will require further study and consideration, in terms of establishing the right amount of support (insufficient support may not help people get out of their circumstances); how the length of time is determined; and, what assets are allowable and the appropriate limits of such assets.
Would an earned income supplement be a good mechanism to increase the incentive to work? If so, how should it be designed?
We have had a mixed response to this question from the Networkâs members. Some think that while a tax-based program would be more universal and easier to manage, others believe the relief needs to be more immediate for people who live in poverty. People who live âhand to mouthâ need those incentives to be more immediate and responsive.
Other members feel that âa better-designed earned income supplement, with a higher actual value and later withdrawal as income rises beyond a reference wageâ would be effective, although the proof lies in the detail and the Network would like to see some proposals with realistic figures in order to fully evaluate the merits of this approach.
Still others believe that the Government should reduce the ODSP claw back amounts or provide greater cash bonuses to people who work. Members generally concur that tax based programs are not as much of an incentive as changing the claw back formula.
Other recommendations include improvements to educate service participants about the benefit system, simplifying the language and moving away from the intrusive and punitive surveillance system that currently exists.
Amortizing income and reducing administration in chasing down paper work would add great efficiencies to the system while making it easier on service recipients to manage their budgets. (See âHow should the current rate structure be changedâŚâ Pg 26)
Would a housing benefit improve fairness and the incentive to work? If so, how should it be designed?
When considering personal and emotional priorities, a safe and secure place to live, personal health and food are paramount. People who do not have these three basic necessities are not generally well positioned to successfully pursue employment. The shortage of subsidized housing and loss of housing subsidies due to earned income is a deterrent to working. The Commission should address housing issues if it wants to see more people who have a disability pursue employment.
Housing subsidies should be managed as part of the total income security package. Reductions of housing subsidies should be on a sliding scale, initiated at a much higher level, where the combined family income of wages and income support is much closer to the reference wage or other poverty-level indicators. In this way, the housing subsidy would be reduced as the person or family makes there way beyond the reference wage or poverty level that is established.
Discussion Questions â Disability Specific
How should income supplements for low-income people who have a disability be designed and delivered? Should such supplements be provided outside the social assistance system?
Disability income supports need to be maintain as a distinct and separate system from other social assistance recipients. Income support for people who have a disability is not a short-term requirement â generally, disabilities are for life. People who have a disability should be seen as different from other social assistance recipients and resources should be directed at responding to the support needs of the individual due to their disability and the barriers that society has created for them, including the barriers to earn a reasonable income.
Should there be a separate basic income program for people with severe disabilities who are unlikely to generate significant earnings?
No. The notion of dividing disability into two groups based on employability has some severe consequences. As previously noted, emerging technologies, changing labour markets, improved service delivery technologies and greater employer acceptance will impact future job opportunities for people who have a disability. The proposed concept will entrap people in the social assistance system for life.
Discussion Questions â Rate Structures
The Network will answer the questions about changing the rate structure and moving from a surveillance system together as we believe the solution is inter-related.
How should the current rate structure be changed to reduce complexity?
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Should the social assistance system move from a surveillance approach toward an audit-based system of verification and monitoring?
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The Network envisions a reporting and rate structure that is like an equal billing process, similar to one used by Ontario Hydro or Enbridge Gas Company. That is: a system where people report their income monthly and their ODSP Income Support payments are calculated and adjusted annually. This should incorporate the following features:
- The individual will report any major income adjustments adjustments (up or down) or other change in life circumstances that would âtriggerâ an equal billing re-calculation.
- A deviation factor/range can be pre-set. In the event that a monthly report exceeds this range an equal billing re-calculation is triggered.
- In the event that an individual misses a monthly report, an average is calculated based on the previous 3 months to determine if any adjustments are required.
- Income reporting & social assistance payments will be reconciled annually (validated by a copy of the individualâs annual T4 slip) This means service agencies will no longer be required to chase down paperwork for every candidate on every pay period, which is the current practice
- Overpayments and required reimbursements will be calculated and paid back on a similar âequal billingâ basis.
- This will be an automated, computer-driven system which will create significant administrative efficiencies.
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In conjunction with this âequal billingâ system, the Network recommends moving to an âauditâ based system. Such a system should be applied in similar proportion to current tax audits and people who are audited should be entitled to the same rights of legal council and the ability to ânegotiateâ re-payments in the same way other people negotiate tax settlements.
We believe that together, these changes will achieve a number of outcomes:
- This will be much easier to administer, creating significant savings within Government. These resources can then be re-invested in service delivery.
- This will be more efficient for service providers, allowing them to spend more time on service delivery and other operational activities that benefit the people they serve.
- This system will be more dignified and less intrusive for people who have a disability.
- People will have a more consistent and stable income stream.
- This will streamline rules and be much easier to understand as equal billing is a familiar concept.
- This will also reduce administrative errors, which are not uncommon, that trigger letters that threaten to âcut people offâ.
- Other efficiencies may be found through this change, allowing for greater investment in employment services for people who have a disability.
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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?
This may be a consideration longer term but at this juncture, why get another level of government involved? This change is not deemed by the Network to be a critical issue that demands immediate attention.
Chapter 3
Easier to Understand
Discussion Questions â Managing Risk
Should the social assistance system move from a surveillance approach toward an audit-based system of verification and monitoring?
As noted, the Network believes that an audit system would be more efficient, much simpler and less intrusive. Along with this there must be reasonable ways to deal with overpayments and other potential abuses. Our concern is that Government tends to adopt the points they like and leave others out. To move to an audit system in isolation of the other items discussed would be unfair and could cause undue hardship to the people intended to be supported.
It should also be noted that abuses are not necessarily in the hands of the recipients. Administrative errors and mistakes are often made by the Ministryâs own staff as well.
What penalties would be required and feasible in an audit-based system?
As noted, overpayments would be reclaimed on an âequal billingâ basis, presumably over the following 12 month period or longer if deemed appropriate. Deliberate abuses should be dealt with within the legal framework.
What is the right level of risk tolerance, in either the current system or an audit-based system?
The current system seems to work on a presumption that abuses are rampant and people need to be kept in check. There is a cost to both a surveillance and an audit system. One would wonder, however, what this cost is and how much of our resources are going into the current surveillance system. When reviewing ârisk toleranceâ we would be better informed if we knew what the cost of monitoring is, relative to the cost of presumed abuses.
The Network recommends that the Commission undertake a study that looks at the cost of monitoring vs. the number (and cost) of abuses that exist. In this way Government can assess the level of risk involved and build an appropriate audit system.
It is imperative that people understand the system and the rules that govern the income support system. This includes those who to manage the system, service recipients and the support organizations and advocacy groups that act on behalf of people who have a disability.
Materials, guidelines and guide books must be developed in plain language and alternate formats so that everyone can understand the rules and regulations.
Consideration should be given to support third party aides who can guide people though the income support system. These guides could also act as advocates in the event of audits and/or reviews.
While there is some concern that record keeping seems to be a bigger problem for people with disabilities in an audit based system, most people seem to be satisfied that people who have a disability should be held to the same standard of accountability as other citizens. In moving to an annual reconciliation, based on a T4 slip, this risk factor would be reduced greatly.
Ontario Disability Employment Network
Recommendations
Recommendations â Short-term (immediate to 2 years)
- Disability supports â both income and employment â must be maintained as distinct and separate from other income support recipients I.e. OW. Disability is a life-long issue and a great number of the barriers faced by people who have a disability is beyond their personal control.
- Government should support business-to-business educational and marketing initiatives. These must include accountability measures to validate their achievements and effectiveness.
- An independent study of wage subsidy initiatives should be undertaken to determine if this is an effective use of resources. The study should review who uses subsidies and why and the percentage of people who retain their jobs once the subsidy is exhausted.
- An independent study of âbest practicesâ in employment supports should be undertaken to learn about creative and innovative approaches and how these can be replicated in the employment services sector.
- Create an inter-ministerial committee with a mandate to coordinate employment for people who have a disability as well as the integration of employment services with other non-employment disability departments and programs.
- Enhance the provincial mandate for Accessibility Advisory Committees to include accessible employment. This will by timely considering the introduction of the AODA Integrated Standards.
- Modify the eligibility requirements for ODSP Employment Supports such that once an individual is deemed eligible for ODSP Income Support, they are automatically eligible for employment supports, eliminating the need for employment service agencies to get additional approvals prior to assisting these individuals to find employment.
- Streamline the approval process for people who have a disability who are not in receipt of Income Support so that they are not forced to become Income Support recipients in order to access employment services.
- Conduct a review of funding for day programs within the MCSS DS branch and MOH, to determine the extent to which these funds are financing employment programs.
- Review other funding programs for people who have a disability and ensure they donât conflict with, compete or undermine the objectives of employment services e.g. individualized funding, DS supported employment service guidelines, etc.
- Create a provincial resource to support innovation.
- Municipalities should begin to engage and collaborate with local Workforce Development Boards and Employment Sector Councils.
- Ensure better education for people who have a disability and their advocates to ensure they understand how the Income Support system works and the effects of earned income on their income supports and benefits.
- Materials and guidelines must be developed in plain language and alternate formats to assist everyone to understand the rules and regulations related to the income support system.
- Create a system of third-party aids (or bolster and expand upon the APSW concept) who can guide people through the income support system to ensure everyone knows and understands the rules and regulations.
- Eliminate the âpunitiveâ approach to people who make mistakes in income reporting.
- Housing subsidies should be managed as part of the âtotalâ income security package. Reductions of housing subsidies should be on a sliding scale and initiated when the combination of income supports and wages is much closer to the reference wage or other poverty-level indicators. To earn extra income from wages is pointless if it triggers an off-setting increase to costs.
- Do not create a separate basic income program for people who have more severe disabilities. The negative consequences of such a move far outweigh the benefits.
- The Network does not believe that moving the special dietary allowance to the Ministry of Health and Long Term Care is a critical issue at this time.
- The Network recommends the Commission undertake a study to determine the cost of monitoring income support abuses vs. the number and costs of abuses that have been reported in order to assess an appropriate response and level of risk management.
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Recommendations â Medium-term (2 to 5 years)
- Government must create an employment policy framework that sets out the parameters â policies, programs and funding â that all ministries and government departments must adhere to.
- Government must move to a single stream of funding for all employment services for people who have a disability and this funding should be managed by municipalities. This should include ODSP-ES, MTCU EO (disability funds), MCSS DS employment funding, MOH employment funding and Service Canada Opportunities Fund. This should be done under a discreet and protected framework specified for the delivery of employment services for people who have a disability. Municipalities must become the service delivery manager and contract out the delivery of direct services to third-party delivery agents that specialize in providing employment services for people who have a disability.
- Develop and include youth employment programs â summer and after school jobs â as a legitimate stream within employment services for people who have a disability.
- Create policies that direct ânewâ investments for daytime support services to prioritize those programs and initiatives that promote employment and/or employment preparation
- Create a transition strategy to assist existing sheltered workshops to transition to employment programs
- Create a provincial mandate that all school boards must ensure co-op work placements for high school students over the age of 16.
- Support and work with the employment service sector and service participants to establish standards of practice for employment service agencies.
- Further investigation is needed with respect to incentives and the Income Support/earned wages balance. Today we still seem to have more questions than answers. Focus on fixing those aspects of the system that can readily be improved.
- Consider changing the asset rules and limits for people newly entering the Income Support system.
- Provide further studies and consultation on an âearned income supplementâ approach. Propose some realistic scenarios, with dollar values included, to help fully evaluate the merits of this approach.
- Change the reporting and rate structure to a technology-based system that mirrors an âequal billingâ process similar to that which is used by utilities companies. The potential savings from this action alone will be in the hundreds of thousands of dollars, possibly millions. These precious resources can be re-invested in the delivery system to help more people get into the workforce.
- In conjunction with this âequal billingâ system, Government should move to an audit-based accountability system. This will also create substantial savings in government efficiencies and in the service system that can also be re-invested in the service delivery system.
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Recommendations â Longer-term (5 years +)
- Investigate the potential and benefits of establishing an âOntario College of Employment Servicesâ for people who have a disability as a possible oversight body. This could include an advisory body of service participants, employers and government.
- Investigate and consider an accreditation process for employment service providers to ensure service quality and conformity to established standards of practice.
- Further study is needed with respect to crating a health benefit program for all low income Ontarians. In principle the Network supports this move but more details are needed in terms of how this will be financed and the impact of this benefit.
- Assess and evaluate the impact of the actions taken in the short- and medium-turn recommendations, and resulting changes to the employment and income support system for people who have a disability.
- Establish the next level of strategic analysis and actions necessary to continue to improve the employment options for people who have a disability.
Appendices
Appendix A â Path to Employment
See attached
Appendix B â Barriers to Employment
See attached
Appendix C â MCSS Supported Employment Code Explanation
See attached
* Note: there seems to be a common misperception that Supported Employment is unpaid or work paid at less than minimum wage. The definition of Supported Employment is âpaid work at commensurate rates and in accordance with labour lawâ. While some employment service operators have modified this definition on some occasions, largely due to a lack of monitoring and regulations, most employment service operators adhere to the full wage definition â âreal work for real payâ.