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PFO Bulletin #3: Suggested Questions for Community Discussion with the Social Assistance Review Commissioners

Commissioners Frances Lankin and Munir Sheikh start their consultation visits this week. Their current schedule is as follows:

  • Windsor – June 28
  • London – June 29
  • Hamilton – July 4
  • Niagara – July 5
  • Toronto – July 8, 14, 15
  • Kingston – July 12 (tentative)
  • Peterborough – July 13
  • Thunder Bay – July 20‐21 (tentative)
  • Peel – July 25
  • Timmins – July 26
  • Ottawa – July 27

The Discussion Paper and Workbook for the community consultations on the Social Assistance Review are available at www.socialassistancereview.ca. Communities not on the Commissioners’ schedule are invited to set up their own community “conversations” on the Review and to submit the results to the Commissioners.

Poverty Free Ontario also encourages communities to conduct their own discussions in July-August. In setting dates, we recommend that you avoid the dates on the Commissioners’ current schedule and invite the Commissioners’ attendance even though right now they are committed only to the above community visits.

Asking the Right Questions

In the Discussion Paper and Workbook, the Commissioners interpret their terms of reference as making “recommendations that will enable the government to:

  • Place reasonable expectations on people receiving social assistance to participate in employment, treatment, or rehabilitation and to provide them with supports to do so;
  • Establish an appropriate benefit structure that reduces barriers and helps people find employment;
  • Simplify income and asset rules to improve equity and make it easier to understand and administer social assistance;
  • Ensure the long‐term viability of the social assistance system; and
  • Define Ontario’s position in relation to the federal and municipal governments in providing income security for Ontarians.” (Workbook, pp. 8-9)

The Review’s Workbook goes on to ask a series of questions under reach of the preceding areas. But, at the end of each section, the Commissioners also invite participants to identify “any issues we have missed or misunderstood.” This PFO Bulletin offers some guidance to communities on the Commissioners’ line of inquiry and important additional questions central to the Commissioners’ task.

Reasonable Expectations: A Labour Market with a Basic Minimum Wage Above Poverty

Under the heading “Reasonable Expectations and Necessary Supports for Employment”, the Workbook asks five questions (p. 11) related to:

  • meeting the needs of employers and connecting social assistance recipients with employers;
  • developing the skills of social assistance recipients to better meet employers’ needs
  • making employment services more effective and accessible;
  • reducing multiple barriers to employment for recipients; and
  • connecting people with disabilities better to employment services.

People on social assistance and low income working people have consistently met their personal responsibilities with respect to taking employment:

  • In 2004, 60% of parents and single adults living in poverty were employed but with insufficient earnings to live above poverty.
  • One‐third of all Ontario children living in poverty in 2008 were in families with full‐time, full‐year hours of work (LICO-Before Tax).
  • In terms of education, 80% of low income parents in Canada had completed high school, 50% had some post‐secondary education (2004) and 45% of the unemployed in Canada had completed post‐secondary education studies (2010).

Their main problem is a low wage job market where a single earner working full‐time, full‐year still falls $1,064 below the poverty line.

Poverty in Ontario is a structural issue. Even the Commissioners acknowledge that “questions around what work should pay” is another approach to income security (p. 4). Employment services for people on social assistance, however, will help only if the labour market provides decent work with adequate ages and benefits to enable people to escape and stay out of poverty.

The Commissioners state that the adequacy of wages in the labour market “is outside the mandate of our review” (p. 4). Yet, any reforms proposed to the social assistance system, even improved employment services and supports, will depend on a labour market that provides jobs that sustain individuals and families above poverty.

Poverty Free Ontario recommends that the Ontario Government build on its previous positive action of raising the minimum wage in 75 cent increments over three years to reach $10.25/hour in 2010 by a second set of three annual 75 cent increases starting in March 2012. This would bring the basic minimum wage to $12.15/hour in 2014 and, indexed annually thereafter, would ensure that an earner working full‐year, full‐time would have an income 10% above poverty.

Poverty Free Ontario encourages participants in the community consultations to give the Commissioners permission to address the larger structural labour market issue in their proposals for serious social assistance reform. Let the Commissioners report out on all that they heard, whether within or outside their interpretation of their mandate.

Questions to Commissioners Lankin and Sheikh: 

  • Will you report concerns expressed in the community that the success of social assistance reform and investment in employment services to recipients will depend on labour market policies that provide jobs with adequate wages to ensure earners live above the poverty line?
  • Further, will you point out in your report that Government action to increase gradually the minimum wage since 2008 has started to bring low wage workers out of poverty and should be completed by three additional annual 75 cent increases starting in 2012 that would bring all Ontario earners working full‐year, full‐time above the poverty line by 2014?

Benefit Levels that End “Deep Poverty”

Under the heading “Appropriate Benefit Structure”, the Review’s Workbook asks five questions (p. 16) about:

  • setting social assistance rates;
  • designing benefits that deal with the trade-off between ensuring adequate income support and ensuring that people are better off working;
  • new benefits that could be provided to all low income individuals and families;
  • improving social assistance by changing asset limits and exemptions; and
  • designing and delivering benefits for people with disabilities

The Workbook suggests that there are trade‐offs to be made “between ensuring adequate income support” through social assistance and “ensuring that people are better off working” (p. 4). Unfortunately, this perpetuates the myth of the “welfare wall”, which holds that benefit levels approaching adequacy act as a disincentive to employment for recipients and is unfair to low wage working people.

There is no evidence that social assistance recipients who can work avoid employment in order to retain their benefits. As noted earlier, the main barrier to becoming “better off working” is the quality of jobs at the low end of the labour market, which both denies opportunity for social assistance recipients to et a firm foothold in sustaining employment and also keeps low wage working people in poverty.

Set Rates to End Deep Poverty. At current benefit levels, people receiving social assistance live in “deep poverty”, defined as having incomes below 80% of Ontario’s official poverty measure (Low Income Measure – After Tax, LIM-AT).

Poverty Line
(LIM-AT – 2008)*

Annual Income (2008)*

Basic Income Gap

Single  Adult on OW $18,582 $7,352

$11,230
(39.6% of LIM-AT)

Lone parent with one child on OW $26,279 $16,683

$9,596
(63.5% of LIM-AT)

Single Adult on ODSP $18,582 $12,647 $5,935
(68.1% of LIM-AT)

* Using comparable data for 2008 as the latest year for which Statistics Canada has published LIM-AT figures.

In terms of setting social assistance rates, Poverty Free Ontario urges the Commissioners to propose a comprehensive plan to end deep poverty by 2015.

Further, Poverty Free Ontario believes that the Commissioners have a unique opportunity well before their final report date of June 2012 to address the serious hardship and hunger that almost 600,000 recipients are currently experiencing by calling for the immediate addition of a $100/month Healthy Food Supplement to the Basic Needs Allowance for all adults receiving OW or ODSP.

Questions to Commissioners Lankin and Sheikh: 

  • In your final report in June 2012, will you propose a comprehensive plan that would ensure no one receiving social assistance in Ontario is living in deep poverty by 2015
  • Will you issue an interim report or statement following your community consultations and prior to the provincial election that:
    • Expresses your intent to propose a comprehensive plan for social assistance reform to end deep poverty in Ontario by 2015?, and
    • Call for the immediate addition of a $100/month Healthy Food Supplement to the Basic Needs Allowance for all adults receiving OW or ODSP?

No Earnings Claw‐backs While Still in Poverty. In presentations and discussions in twenty communities between March and June 2011, Poverty Free Ontario consistently heard social assistance recipients express frustration at the low earnings exemption level before loss of benefits from employment earnings started and at the high rate (50%) of benefit loss for every dollar earned over the exemption limit. Participants enthusiastically supported the proposal that not one dollar of earnings should be clawed back through benefit reductions until an OW or ODSP recipient’s earnings reached the poverty line.

Benefits for People with Disabilities. Poverty Free Ontario supports the positions of the ODSP Action Coalition on benefit levels and employment expectations for people with disabilities.

Questions to Commissioners Lankin and Sheikh: 

  • Will you propose reforms recommending that no claw-backs or benefit reductions are applied against earned income for people on social assistance until they reach the LIM-AT applicable to their individual or family situation?

Caution on Potential New Housing Benefit for All Low Income People. The Discussion Paper indicates that one possible way to avoid treating social assistance recipients and low income workers inequitably is “to make some benefits available to all low income people, whether or not they are receiving social assistance.” (p. 4) Examples given include the Ontario Child Benefit and the National Child Benefit Supplement for low income parents.

Although not explicitly identified in the Workbook, it is expected that the Commissioners will explore community interest in a housing benefit for all low income people as a way to address the income support issue.

Poverty Free Ontario offers several important cautions on the notion of a housing benefit:

  1. It is critical that a housing benefit for all low income people assure coverage for the portion of the high cost of housing that drains money away from the low income household’s budget for food and other necessities of life. It is generally accepted in Rent-Geared-to-Income provisions that households paying more than 30% of their gross incomes for housing require subsidy in order to meet all their costs for basic living necessities. Housing benefit proposals that Poverty Free Ontario has heard discussed suggest that the 30% threshold is being considered for families, but a 40% threshold is being considered for individuals, which again imposes an artificial divide between the “deserving” and “undeserving” poor. Further, housing benefit models under discussion do not necessarily provide full coverage for the amount over #0% or 40%, but only about three-quarters of the difference.
  2. The introduction of a housing benefit must contribute significantly to moving people living on social assistance toward income adequacy for their overall necessities of life. Ontarians receiving social assistance are very familiar with claw‐backs on benefit programs applying to all persons on low income. Presumably, the Commissioners would recommend against a claw‐back for a housing benefit that is supposed to apply to both social assistance recipients and low income working people. Currently, however, a portion of the Basic Needs Allowance to social assistance recipients is designated for shelter costs. Unless, social assistance rates are also increased in the direction of adequacy for basic living needs, there is the risk that rates are also increased in the direction of adequacy for basic living needs, there is the risk that administration of a partial housing benefit will be offset with a loss or reduction in the shelter allowance portion of the OW and ODSP recipient’s overall benefit, leaving them only marginally better off.

Poverty Free Ontario recognizes that a housing benefit for social assistance recipients and low wage workers may well have a place in the overall income security reforms that the Commissioners will propose by June 2012. Under conditions where overall benefit levels bring social assistance recipients out of deep poverty and where minimum wage levels assure low income workers earn above the poverty line, a housing benefit can be an important complementary protection against variable high housing costs in communities across the province.

A full housing benefit is a complement to the core income of a low income individual or family, not a substitute for the basic income required to meet daily living requirements. It should be designed as a protection for household money for food and other necessities of life.

Questions to Commissioners Lankin and Sheikh: 

  • Should you propose a new housing benefit,:
    • will it be available to all low income individuals and families with housing costs above 30% of gross household income?
    • will it provide full or partial coverage of the difference between 30% of their housing costs and the actual costs of those in need?
    • will it reduce the shelter allowance portion of OW and ODSP recipients’ benefits?

Special-Purpose Benefits

The Commissioners will also seek input on eligibility for special-purpose benefits and inquire whether some may best be delivered outside the social assistance system. The Special Diet Allowance is one such benefit identified.

The Ontario Government’s 2010 budget proposed changes to the Special Diet Allowance (SDA) that threatened an important supplementary support to individuals and families with health-related dietary needs not adequately covered through existing benefits. Since an internal review of the SDA was completed, the eligibility process has been tightened up and the number of qualifying medically necessary conditions has been reduced significantly.

The Commissioners have a chance to serve the interests of OW and ODSP recipients in two ways through their Review:

  1. Distinguish the issue adequacy in benefit levels in general that enable access to affordable and nutritious food for all recipients from support for recipients with special dietary requirements; and
  2. Reinforce the importance of a supplementary Special Diet Allowance available fairly to recipients with medically necessary dietary requirements.

Clearly, the administration of a Special Diet Allowance in a way that would open its eligibility to low income working individuals and families would be beneficial in general to personal and community health.

Questions to Commissioners Lankin and Sheikh: 

  • Will you recommend that the Ontario Government retain and expand as required a Special Diet Allowance to ensure that OW and ODSP recipients and qualifying low income workers and working families will have access to food essential to medically prescribed special dietary requirements?

Federal and Provincial Jurisdictions in Income Security

The Commissioners also express the need for better integration of the federal and provincial provisions for income security in general. They point to the growing burden on social assistance as lower numbers of Ontario’s unemployed receive Employment Insurance. These are legitimate concerns and improved coordination and integration between the federal and provincial governments on income security issues are highly desirable.

Federal-provincial jurisdictional considerations and discussions for long-term income security reform should not, however, delay provincial action in the short and intermediate terms on the two clear areas of sole provincial responsibility:

  1. Basic incomes through social assistance which ensure a life out of poverty for parents and adults with limited access to employment; and
  2. Labour markets with decent work that enable full-time, full-year earners to live above poverty.

Poverty Free Ontario urges community participants to reinforce with the Commissioners the imperative that the Province of Ontario fulfills its obligations to both social assistance recipients and low income working people, regardless of the federal government’s position on income security.

Questions to Commissioners Lankin and Sheikh: 

  • Will you recommend action by the Ontario Government on social assistance reform and labour market policy regardless of any proposals or discussions with the federal government in the longer-term with respect to more integrated income security policy?

Conclusion

Poverty Free Ontario urges communities to affirm the opportunity that the Social Assistance Review Commissioners have not only to propose serious and comprehensive reforms to the social assistance system in Ontario, but also to make sure that the issue of poverty and poverty eradication is part of the policy debate in the upcoming provincial election. Currently, no political party is giving the issue of poverty any prominence at all in its party platform.

The Commissioners would best serve this issue with an interim report on their deliberations with the community by August or early September prior to the provincial election date of October 6.

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