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March 10, 2014
Disability White Paper
PO Box 9936 Stn Prov Gov
Victoria BC V8W 9R2
Re: Disability White Paper Consultation
To Whom It May Concern:
We are writing to provide comments to help inform the development of the Disability White Paper on how government, businesses and communities can better support people with disabilities. BC Public Interest Advocacy Centre (BCPIAC) is a non-profit, public interest law office that provides representation to groups that would not otherwise have the resources to effectively assert their interests. We regularly work with people with disabilities that face significant barriers to full participation in their communities. Our comments here will be limited to how the provincial government might alleviate such barriers.
One of the key questions identified in the white paper terms of reference[1] was: “Why do you think it’s important that we reduce barriers and increase accessibility for people living with disabilities in BC?” We believe the answer is in the question when asked in relation to government’s role. Where people with disabilities encounter barriers in accessing public services, there is a clear responsibility for government to help reduce these barriers and make services more inclusive.
Another key question in the terms of reference was: “What would B.C. look like as the most progressive place in Canada for people and families living with disabilities?” The answer to this question could take many forms, but the vast majority of responses could likely be reduced to a matter of inadequate resources – particularly where those persons with disabilities rely solely on financial assistance from government. To this end, we fully endorse the recommendations put forward by the BC Poverty Reduction Coalition (BCPRC), which focus on financial barriers people with disabilities face. We strongly encourage the government to take these recommendations seriously if its sincere objective is to determine what it can do to reduce barriers and increase accessibility for people living with disabilities in our province. Below, we reiterate the BCPRC’s recommendations, along with our own reasons for supporting these measures as government priorities.
1. Raise PWD benefits to $1200, index it to inflation, and establish a shelter allowance like the seniors SAFER program
The current rate for provincial disability assistance, Persons with Disabilities (PWD) benefits, is $906 per month for a single person (i.e., $375 for housing, and $531 for other basic living expenses). This is woefully inadequate, and does not reflect the increasing cost of living in British Columbia. The government cannot meaningfully encourage increased community participation and support people with disabilities in finding employment (where employment is possible) while many are struggling to meet basic needs such as food, housing (including utilities), and clothing. For more information on the disconnect between living costs and PWD rates, please refer to “Overdue: The case for increasing the Person with Disabilities (PWD) Benefit in BC,” a report published by the BC Coalition of People with Disabilities (BCCPD), in partnership with SPARC BC, Community Legal Assistance Society (CLAS), Inclusion BC and Canada Mental Health Association (BC Division).
If BC aims to be the “most progressive place in Canada for people and families living with disabilities,” a reasonable starting place would be looking to comparable benefits in other provinces. For example, Alberta’s equivalent benefit, “Assured Income for the Severely Handicapped” (AISH), provides a living allowance of $1588 per month,[2] an amount which was increased in 2012. Raising PWD benefits to $1200 per month would be a significant step in the right direction.
Rate increases should also be applied to regular income assistance, as there are many people with disabilities and serious medical conditions on regular assistance, which is clearly inadequate at $610 per month for a single person.
2. End the clawback of child support payments from PWD and income assistance benefits
In addition to the BCPRC, many individual organizations (BCCPD, BC ACORN, First Call, WestCoast LEAF, and CLAS) have also called for this change. Child support paid to the custodial parent by the non-custodial parent is currently deducted dollar for dollar from income assistance and disability benefits. This money rightfully belongs to the children for whom it is intended to provide; the intent of child support is to maintain the child’s standard of living that existed prior to the parents’ relationship breakdown. For families of people with disabilities, and specifically custodial parents that are unable to work, this money would provide critical assistance to children living in poverty—basic items many take for granted, such as nutritious food and properly fitting clothing.
To the extent that clawbacks continue to occur (whether this is child maintenance or spousal maintenance), we would urge the government to institute a system whereby recipients can elect to receive a consistent monthly PWD or income assistance benefit, and have the Family Maintenance Enforcement Program (FMEP) pay maintenance amounts received from the person’s former spouse directly to MSDSI. The current system requires that any payments FMEP receives from the payor be forwarded to the PWD/income assistance recipient, who must then report the payment to MSDSI; these amounts are then deducted from the next month’s cheque. These clawbacks affect everyone, but can present particular difficulties for individuals with cognitive disabilities, as inconsistent disability assistance amounts (and therefore, monthly income) can cause significant budgeting problems.
3. Commit to a poverty reduction plan for BC as it would include these important measures and much more
We fully support this recommendation, as it recognizes poverty as a complex issue, and one that needs to be addressed in a comprehensive and nuanced manner.
Sincerely,
BC Public Interest Advocacy Centre
Erin Pritchard
Barrister & Solicitor
[1] http://engage.gov.bc.ca/disabilitywhitepaper/terms-of-reference/
[2] Assured Income for the Severely Handicapped General Regulation, Alta Reg 91/2007, s.6(3).