On Friday, June 28th, the Government released the draft regulations that will govern how the Canada Disability Benefit (CDB) works. These regulations are open for public feedback until September 23, 2024 (11:59 pm EST), offering Canadians the chance to voice their opinions on how the benefit will be implemented.
You can review the formal regulations in Canada Gazette 1 here. This is where you can provide your input and express your opinions. There is a plain-language summary available here and more information including scenarios here.
Get Involved: Give your feedback on the draft regulations proposed for the Canada Disability Benefit Act, which is set to be implemented by July 1, 2025. Unfortunately, the online submission process is not very accessible for many people with disabilities. To help, we are sharing our submission, which you can copy and paste into the appropriate sections of the feedback form. You are encouraged to add your own experiences and opinions.
Autism Ontario Submission:
Autism Ontario believes that the perspectives of autistic individuals and their families are crucial in shaping policies and programs that truly support their needs.
Responses for you to copy and paste start here:
Under the section "Issues," copy and paste the following response:
The Canada Disability Benefit (CDB) is a new initiative aimed at reducing poverty and enhancing the financial security of working-age persons with disabilities. This benefit comes at a critical time, as many Canadians with disabilities face mounting cost-of-living challenges. While the government's approach recognizes these important issues, several aspects of the proposed regulations raise concerns for the disability community.
Under the section "Description," copy and paste the following response:
Autism Ontario has a number of concerns that it will address in this section.
Concern 1: The Canada Disability Benefit is currently restricted to those who have the Disability Tax Credit, which limits access to the benefit. Not all disabled individuals have or qualify for the Disability Tax Credit, potentially excluding many who would benefit from this support.
1. This restriction is too narrow and needs to be broadened:
a) We are concerned that applicants for the Canada Disability Benefit must first be eligible for the Disability Tax Credit. The Disability Tax Credit is a non-refundable tax credit, meaning it does not benefit those without taxable income. Requiring Disability Tax Credit eligibility as a prerequisite effectively excludes many autistic Canadians and individuals with disabilities who are underemployed or unemployed and thus may not benefit from the Disability Tax Credit.
b) This approach fails to address the needs of those most affected by financial hardship. To make the Canada Disability Benefit more inclusive, we recommend broadening eligibility criteria. Specifically, access should be automatic for individuals receiving federal and provincial/territorial disability supports and tax credits, such as CPP Disability. Expanding eligibility in this way would ensure that a broader range of individuals can benefit from the program.
Concern 2: The benefit amount is set at $200 per month, which will not provide sufficient financial support for individuals with disabilities.
1. Although the Canada Disability Benefit is intended to complement other federal and provincial programs, the proposed monthly amount of $200 is insufficient. For instance, this sum is unlikely to cover basic expenses such as groceries for a single person for an entire month.
2. To ensure that the benefit amount remains relevant and sufficient over time, it should be indexed to inflation. This adjustment would provide ongoing support that aligns with cost-of-living increases.
3. It is crucial to ensure that receiving the Canada Disability Benefit does not lead to the reduction or claw back of provincial and territorial social benefits or private insurance disability payments. This safeguard would prevent the new benefit from inadvertently reducing other crucial sources of support.
Concern 3: Benefit Type
1. The Canada Disability Benefit is currently structured as a family benefit, meaning the income of all household members will be considered when determining the benefit amount. A preferable approach would be to provide individual benefits based solely on the earnings of the person with a disability.
2. If the benefit continues to be assessed on a family basis, the income threshold for benefit phase-out should be set higher to better reflect the needs of individuals with disabilities.
Concern 4: The Canada Disability Benefit is not sensitive to autistic realities.
1. Many autistic people urgently need a Canada Disability Benefit that reflects their unique life circumstances. A significant majority of Canadian autistic adults (78%) are not employed, with 63% relying on government transfers like the Canada Disability Benefit as their primary income source. The average income for autistic adults is less than one-third of that of neurotypical adults (Jennifer Zwicker, Arezou Zaresani, J.C. Herb Emery, Describing heterogeneity of unmet needs among adults with a developmental disability: An examination of the 2012 Canadian Survey on Disability, Research in Developmental Disabilities, Volume 65,2017, Pages 1-11, https://www.sciencedirect.com/science/article/pii/S0891422217300999).
a) Eliminate the Working Income Exemption: The current benefit structure penalizes those with part-time or low-paying jobs, which disproportionately affects autistic individuals who are already underemployed or unemployed. This claw back should be removed to prevent further disadvantage for those who are employed but still struggle financially.
b) Remove the Disability Tax Credit as an Eligibility Barrier: Many autistic Canadians between the ages of 18 and 64 are either unemployed or underemployed. Using the Disability Tax Credit as a prerequisite for the Canada Disability Benefit creates a significant barrier for those who are most in need of financial support.
c) Reduce Administrative Barriers: The application process for the Canada Disability Benefit should not impose additional financial or bureaucratic burdens on applicants. This includes avoiding requirements for medical doctors to sign off on forms, which can be costly and cumbersome. Furthermore, the benefit process should not trigger requirements for guardianship or substitute decision-making when interacting with financial institutions on behalf of individual recipients.
Under the section "Regulatory Analysis," copy and paste the following response:
1. Autism is a life-long neurodevelopmental disability that affects the way a person communicates and relates to people and the world around them. It can affect body language and posture, social interactions and relationships, how you engage with your interests, and sensory processing capacities. Autism exists in all cultures, ethnicities, races, and gender identities. Autism is a spectrum condition, with every autistic person presenting differently.
Reference: https://www.autism.org.uk/advice-and-guidance/what-is-autism
2. Available Supports and “Aging Out”: After age 18, the autistic person “ages out” of funded options available for children, and there are few funding options for autistic adults provincially. Once autistic individuals age out of children's programs, they face a severe lack of adult support options, leaving many families in crisis as they navigate limited resources.
Reference: https://globalnews.ca/news/6535088/autism-adults-services-canada/
3. Adult autism assessment: Accessing adult autism assessments is very challenging through public channels, such as psychiatrists or OHIP-funded health providers. Accessing autism assessments privately is challenging and costly, often ranging from $3,000 to $5,000, making early intervention and support even more critical.
Reference: https://www.integratedautismconsulting.com/assessment/
Reference: https://autismcenterforkids.com/how-to-get-an-autism-diagnosis-in-ontario-canada/
4. Housing: Transitioning into community living and finding sustainable employment remains a significant challenge for autistic youth and adults, compounded by a lack of workplace acceptance and lower average incomes. Additionally, many caregivers face ongoing stress as their adult children continue to live with them into their senior years. The financial burden of not being able to hire support personnel for their loved ones, coupled with the loss of income from caregivers who may need to reduce work hours or invest less in their own retirement, exacerbates the challenges faced by both autistic individuals and their families.
Reference: https://globalnews.ca/news/8723098/canadians-autism-overlooked-employment-opportunities-report/
5. Employment and income: The vast majority of autistic adult Canadians remain unemployed or underemployed. Of those who do have jobs, the average income was lower than that of the average Canadian. Autistic adults report a number of challenges with workplace acceptance which prevent them from obtaining and maintaining employment.
Reference: https://cahs-acss.ca/wp-content/uploads/2022/04/CAHS-Autism-in-Canada-Considerations-for-future-public-policy-development.pdf (pg. 13)
6. Prevalence rates: 1 in 50 Canadians aged 1 to 17 are on the autism spectrum, with recent studies indicating that the prevalence rate may be even higher. This highlights the ongoing need for support and services for individuals across the lifespan, from childhood through adulthood.
Reference: https://www.canada.ca/en/public-health/services/publications/diseases-conditions/autism-spectrum-disorder-canadian-health-survey-children-youth-2019.html
7. A report from the University of Calgary’s School for Public Policy notes that many autistic people require supports throughout their whole lives. The report’s authors estimate that when an adult with severe support needs in Canada is placed into long-term care or supportive housing, the daily costs, including caregiver time, can amount to $400 a day or upwards of $150,000 a year. Furthermore, they conclude the “lifespan value of caregiver time alone to support a severely impacted individual with ASD to be approximately $5.5 million above the costs of a neurotypical individual.”
Reference: https://www.policyschool.ca/wp-content/uploads/2016/01/Emery-Autism-Costs.pdf
If you would prefer to copy and paste from a Word document, you can find it here: Responses to copy and paste