This summer, individuals and organizations had the opportunity to provide feedback on the Canada Disability Benefit draft regulations. CASW sent a letter directly to complement the feedback provided through the Canada Gazette's portal, which can be read below.
The Honourable Kamal Khera, P.C, M.P.
Minister of Diversity, Inclusion and Persons with Disabilities
House of Commons
Ottawa, Ontario
K1A 0A6
October 1, 2024
Dear Minister Khera,
On behalf of the Canadian Association of Social Workers (CASW), the national professional association for social work in Canada – composed of ten partner federation partners across provinces and territories and representing over 22,000 social workers – I am writing to provide feedback and suggested direction on the draft regulations for the Canada Disability Benefit (CDB).
CASW was delighted to meet with you last September to discuss some of our association’s priorities and our vision for a fair, equitable, and accessible Canada for all – a vision we know you share. In this regard, the new CDB has potential to have a deeply positive impact on the lives of people with disabilities: a potential that will not be effectively met without necessary modifications.
First, we are concerned about the use of the Disability Tax Credit (DTC) as the gateway to the benefit as it is inaccessible and expensive for many people with disabilities: less than 40% of the 1.6 million people with disabilities who should be enrolled in the DTC are not currently[1]. A solution to this would be to automatically enroll anyone in the DTC who already receives disability payments from any level of government and provide an opt-out option after the fact.
That said, if as a starting point the DTC is to remain the entry point to accessing the benefit, in the interim, social workers should be added to the list of professionals able to complete and certify application forms. Not only do social workers have a holistic understanding of service users' well-being, but our accessibility in myriad community settings also enhances access. While applicants should be reimbursed fees charged by practitioners to complete the application forms, social workers would likely represent a more affordable option both in terms of the use of Canadians’ tax dollars and as an upfront cost for people with disabilities than the use of other health and social care professionals.
Second, the amount of the benefit should be increased to take into account both the poverty line and the added cost of living with a disability $200 is simply too low to have the intended impact on people’s lives. Further, the benefit should be individualized and not means tested against household income – this is not consistent with the GOC’s GBA+ approach as it requires that the person with a disability’s partner file their taxes, putting a critical part of the process out of the applicant’s control.
Additionally, we urge you to privilege the voices of people living with disabilities in your assessment of all feedback received on the draft regulations above other voices. One of social work’s core values is that people are experts in their own lives: people with disabilities are the experts in terms of how this benefit should be shaped.
Finally, instead of the addition of another program that further complicates the social assistance landscape, making it more onerous for governments and citizens alike, CASW is an advocate for the creation of a basic income. Introducing a basic income in Canada would create a stable floor upon which we can all stand that would result in significant cost savings down the line, from both fiscal and human perspectives. CASW’s policy statement on a basic income in the form of the universal demogrant model can be read here.
We would welcome the opportunity to meet with you or your office, at your convenience, to discuss these issues or CASW’s other policy perspectives in more depth. We know your government is committed to creating a better Canada for all those who call it home, and we look forward to continuing to support this work.
Barbara Whitenect, MSW, RSW
CASW President
[1] Dunn, Stephanie and Jennifer Zwicker (2018). “Why is uptake of the disability
tax credit low in Canada? Exploring possible barriers to access.” University of Calgary School of Public Policy Publications. 11 (2) https://www.policyschool.ca/wp-content/uploads/2018/01/Disability-Tax-Credit-Dunn-Zwicker.pdf