Position Statement

Some families have children with an intellectual disability. These families need income. They also need resources. Resources and income will give them a good quality of life. Resources and income will let them fully take part in their community. Sometimes a loved one with an intellectual disability needs support from their family. This support should not hurt the family’s finances. Families need access to income and disability supports. This would let them focus on being a family. It would let them build an inclusive life.

Policy

People with intellectual disabilities need support. In Canada, it is usually their families who support them. They do this for free. They do this out of love. They are committed to supporting their loved one.

Children with an intellectual disability need support from their parents. They need more support than children without a disability. They still need support when they become an adult. Adults with disabilities should have government financial support. This would let them live with dignity. But this usually does not happen. They usually need support and money from their parents. Sometimes one parent does not work so they can support their loved one. This can mean that they do not make enough money for their family.

We know this is a problem for Canadians. We do not know how big it is. There is not enough information or ‘data.’ We need to know more about children with disabilities. We need to know about their families. This will help make better policy decisions. We need data about certain groups and people. We need to speak to people with different disability types. We need to focus on children and families. We need to collect all this data.

We do have some data. This comes from research. It also comes from our own experiences. Here is what we know.

• Some people support a family member or friend with a disability or illness. They do not get much government support. Over 93% of them get no government help. Over 91% did not get any government tax credits.
• Many people who care for a child with an illness or disability say they have unmet needs. Almost 50% reported this.
• People who support a family member or friend with an illness or disability have unmet needs. They said government aid would help. So would financial support or tax credits.
• Parents of children with an intellectual disability often turn down jobs. Sometimes they work less hours per week. Sometimes they turn down promotions.
• Families of children with disabilities often live in poverty.
• Society expects aging parents to keep giving support to their adult family member.

Families are expected to take care of their loved one with a disability. This can cause them financial problems now. It can also cause problems in the future. It can affect families across generations. Parents may not be able to retire. Siblings may have to take on added responsibilities.

It is hard for families to find inclusive childcare that they can afford. They don’t have access to disability supports. This makes it hard for family members to have jobs.

Government programs do not provide enough money to raise a child with a disability. Programs that help families are also hard to access.

Discussion:

The Role of Families

We define a family as two or more people. They can live together. They can live apart. They can be related by blood. They can be related by marriage. They can also be related by adoption or a commitment to support each other.

Families of people with disabilities are not all the same. For example:

• They can have different forms.
• They can live anywhere. This can be urban or rural areas. It can be in remote communities. It can be in Indigenous communities.
• They may be part of a marginalized group. These are groups and people that are often left out or forgotten by most of society. This can include newcomers to Canada. It can include racial groups. It can also include gender minorities.

Different families have different financial needs. This paper cannot talk about every type of family. But we understand it is important to do more work to learn about them. Their voices need to be heard. This will help address their needs.

Being part of a family is very important for people with intellectual disabilities. It is the key to inclusion and a sense of belonging. Families are a loving place for people to learn and grow. They help their family members with disabilities to overcome challenges. They help them succeed in life. They foster dreams. They help make a better future for their family member.

It is harder to raise a child with a disability. It is more expensive. It takes more time every day. It can also take a longer time for the child to become an adult. It can be hard for families to include their loved ones in community life. This puts a lot of social stress on families. It also creates financial stress. Families need to know that their loved one’s wellbeing is protected. They need to know that they will have enough money to live. They also want these protections in the future.

The make-up of a family can change over time. This means their financial needs change over time. So do the types of support they need. Our Position on Financial Security and Income Support looks at this. It looks at the specific needs of adults with intellectual disabilities. These two documents can be used together. They explain how to support families throughout their lives.

Access to the Workforce

Being employed is important for families. It gives them financial security. It lets them meet their current needs. It lets them save for the future. In many families with two parents, both work outside the home. This is hard for parents of children with disabilities. They face added barriers when trying to get a job.

Childcare and after school care are expensive. They are usually not inclusive. Parents who cannot find childcare have to stay home. This makes it hard for them to hold a job. Children with disabilities often cannot be left alone. This is different from children without disabilities. Children with disabilities often still need care as they get older. Families of children 13 and older who need support have a tough time. There is not enough help for older kids. They cannot get disability support for adults.

It is hard for people who cannot work to be financially secure. Some families cannot meet their day-to-day expenses. This includes the added expenses that come with raising a child with a disability. It also makes it hard for families to save money. This puts their future at risk. They cannot save to retire. This is hard on single parents. It can also be hard on families with two parents. Sometimes only one of them can work. This can lead to stress. It can be hard on the parent that stays home. They may be left out of the workforce. They may be dependent on their partner who works.

Access to Financial Supports

Supporting a family member with an intellectual disability costs a lot. This is true even with improved access to jobs. There are tax credits that can help. There are also financial support programs. But none of these things are enough. They do not offer much help. They are also hard to access.

The Child Disability Benefit (CDB) is a monthly payment that is not taxed. It is for families who support a child under 18 years old with a disability. To get this benefit, a child must first be approved for the Disability Tax Credit (DTC).

The process to get the Disability Tax Credit is long and difficult. It requires proof of a ‘severe and prolonged impairment.’ A report from 2018 explains many of the problems people have when trying to get the Disability Tax Credit. Here are some of these issues.

• People with an intellectual disability find it difficult to get approved. This is based on their ‘limitations in mental functioning.’
• People with lifelong disabilities often have to reapply.
• Young children with disabilities are compared to other children. The impact of their disability on their daily lives is not taken into account. This can make it difficult for them to get the Disability Tax Credit.

Access to the Disability Tax Credit is critical. It is the gateway to other benefits. When approved for the Disability Tax Credit, families have access to the Child Disability Benefit.

The Child Disability Benefit is important to families. It gives money to parents raising a child with a disability. It puts money in the pockets of families. There are ways to make the benefit better. It should not be taxed. It should not be ‘clawed back’ by provinces or territories. The benefit is especially useful for low-income families. But other families can also benefit from it. It should be improved to help a wider range of families.

Social assistance is the main income for some families. This comes from provincial or territorial governments. These are programs of last resort. They are not made to help families raising children with a disability. These programs are also hard to get. They have strict rules about how people can get help. They limit how much money somebody can earn. They have policies that do not help families. They trap families of children with a disability in poverty. These programs need big changes. But there are some small changes that could happen now. For example, child support payments should not be taxed. Another example is changing the policy on who can live together and still get support. Adults with intellectual disabilities need access to good jobs. They need a federal income program. These would help their financial wellbeing. They must also have access to safe and affordable housing. They need access to disability supports. These things would also help families. Families need to know that their loved ones have financial help if they need it. This lets them take care of their own needs. This lets them save for the future.

Saving for the Future

Family members who cannot work are not able to save so they can retire. Parents who stay home to support their child cannot get the Canada Pension Plan (CPP) or similar programs. These parents provide needed support. Their efforts should be recognized and valued. Caring for a child should not mean being poor and unable to retire. Parent care takers need a way to retire. They need access to the Canada Pension Plan. There have been other groups who have been allowed to contribute to the plan. This should also be explored for family members who support somebody with a disability.

Inclusion Canada’s Call-to-Action

The federal government has a responsibility to the families of people with a disability. They need to make sure they are financially secure. Here are some ways they can do this.

Top Priorities

1. Provide access to childcare for parents of children with an intellectual disability. Make it inclusive. Make it affordable. Provide before and after school support for children over 12 years old.
2. Rename and improve the Child Disability Benefit.
   • Do not tax the Child Disability Benefit. It should also not result in a ‘clawing back’ of other benefits. This applies at the provincial and territorial or federal level.
   • Double the current benefit amount ($242.91 per month) for every eligible child. Let working people get the benefit. Allow an income of $98,040 before taxing the benefit. This will help low and middle-income families.
   • Extend coverage to include youth with disabilities above the age of 18. The benefit should go to at least age 21. Going to age 30 would be even better. This would reflect the reality of the support families provide to loved ones with a disability. Rename this extended benefit the Child & Youth Disability Benefit.
3. Make it easy to get the Disability Tax Credit. Access to the DTC is important. It allows access to other programs. Getting the DTC is hard. It is even harder for some people. This includes young children, people with an intellectual disability, and people on the autism spectrum. Make this process easier. People with lifelong disabilities should not have to reapply.
4. Help parents save for retirement. It is hard to care for somebody and work. This makes it hard to save money. We need to find a way to make sure caregivers can save money. They need to be able to retire. We need solutions to address this.

Systemic Priorities

5. Do a full review of federal government programs. Here are some things this should include.
   • Study the Disability Tax Credit as it controls access to the Registered Disability Savings Plan (RDSP) and the Child Disability Benefit (CDB).
   • Review the eligibility criteria for the Home Buyers’ Plan. Look at how it is used by families of people with disabilities. Review eligibility for the Canada Student Grant. Look at how it is used by people with disabilities.
   • Review the way funds can move between Registered Disability Savings Plans (RDSPs) and Registered Education Savings Plans (RESPs) without affecting grants and bonds.
6. Make the RDSP better. Make it help support families to save for the future. Provide grants and bonds. Let people get funds earlier. More ideas to improve the RDSP can be found in Designing a RDSP Homeownership Plan: Exploring the Canada Disability Savings Program for Homeownership.
7. Collect more detailed data about children with disabilities and their families. Break it down by type of disability. This may reveal new data. It will also allow data to be studied based on the type of disability.
   
   

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Inclusion Canada’s Position on Income Security

Position Statement

Families who have children with an intellectual disability must have the income and resources they need to secure a good quality of life and fully participate in all aspects of their community. Supporting a loved one with an intellectual disability should not negatively impact a family’s economic security and financial well-being. Families need access to income and disability supports that enable them to focus on being a family and building an inclusive life.

Policy

In Canada, families provide most of the support for their loved ones with an intellectual disability. This support is provided freely out of love and commitment.

Parents of children with an intellectual disability have to provide much more support than parents of children without a disability. This expectation continues even when their loved one is an adult. Although adults with disabilities should have access to sufficient support and income to live a life with dignity, this is usually not the reality. Often, one parent stays out of the workforce to meet the support needs of their family member. This has a significant financial impact on families.

The extent of this impact is not well documented. Lack of recent data collection focused on children with disabilities and their families has created a significant information gap. To best inform future policy decisions, it is crucial that disaggregated data, speaking to specific disability type and focused on children and families, be collected.

Based on available data and qualitative experience, we know that:

• 93.2% of people providing support to a family member or friend with a long-term health condition or disability did not receive any financial support from government programs.ⁱ 91.6% did not receive any federal tax credits.ⁱⁱ
• Almost 50% of people providing care to their child with a long-term health condition or disability reported they had unmet support needs.ⁱⁱⁱ
• Financial support, government assistance or tax credits are the most common unmet need among people providing support to a family member or friend with a long-term health condition or disability.
• Parents of children with an intellectual disability often have to turn down employment opportunities, work less hours per week, and decline promotions.
• Families of children with disabilities often live in poverty.
• Aging parents are typically expected to continue providing support to their adult family member.

Families are expected to risk their current and future financial security to care for their loved one with a disability. This has an intergenerational impact on financial security, as parents struggle to afford retirement and adult siblings take on added responsibilities.

Lack of access to inclusive, affordable childcare and appropriate disability supports keeps families out of the workforce or limits their involvement.

Financial programs that help families are difficult to access. Some of these programs don’t offer enough money to balance out the cost of raising children with a disability.

Discussion:

The Role of Families

We understand family to consist of two or more people, living together or apart, related by blood, marriage, adoption, or a commitment to support one another.

Families of people with disabilities are not a homogeneous group. Their financial needs may differ depending on where they live (urban, rural, remote northern, or indigenous community), their family structure, or experience as part of a marginalized group (newcomers, indigenous and racialized people, gender minorities, etc.). While this position paper cannot address the unique realities of all families across Canada, we acknowledge that more work is required to ensure the needs of these families are heard and addressed.

Being part of a family is key to the inclusion and belonging of people with an intellectual disability. Families provide a loving, nurturing space to learn and grow. They help their family members with disabilities to overcome challenges and achieve success. They foster dreams and the means to realize a promising future.

Raising children with disabilities is more expensive, time-consuming, and lasts longer. Families often have to struggle to have their loved ones fully included in community life. This places significant social and financial pressure on families. They simply want the assurance that their financial and social wellbeing will be protected, now and in the future.

The financial and support needs of families change and evolve over the life cycle and as family composition changes. Our Position on Financial Security and Income Support explores the specific needs of adults with an intellectual disability. These two documents can be used together to best understand how to support families throughout the lifespan.

Access to the Workforce

Connection to the workforce is key to the financial security of many families. It allows them to meet their current needs and save for the future. For many two-parent households, this means both adults work outside the home. However, families of children with an intellectual disability experience added barriers to participating in the workforce.

Lack of inclusive, affordable childcare prevents single-parent, and two-parent households from fully participating in the workforce. Parents of children with an intellectual disability who are unable to secure childcare must often stay home as their child cannot be left alone, unlike pre-teens and teens without disabilities. This may begin during pre- school, and extend through to adulthood if inclusive, affordable before and after-school childcare is not available. For families of children 13+ who continue to require support, a significant gap exists in before and after-school care and access to disability supports.

The financial security of families is significantly impacted by this limited participation or absence from the workforce. Some families may struggle to meet day-to-day costs of living. This includes added out-of-pocket expenses associated with their child’s disability. Extended absences from the workforce also puts the long-term financial security of families in jeopardy, making saving for retirement almost impossible, particularly among single-parent households. In situations where one parent remains at home to provide support while the other is employed, economic vulnerability and financial dependency may also occur.

Access to Financial Supports

Even with improved access to the workforce, it’s clear that supporting a family member with an intellectual disability comes with added financial costs. While some tax relief measures and financial programs exist to help offset these costs, they are often difficult to access and limited in scope.

The Child Disability Benefit (CDB) is a tax-free monthly payment for families supporting a child aged 18 and under with a disability. To access the CDB, a child must be approved for the Disability Tax Credit (DTC). This process is often long and difficult and requires proof of a ‘severe and prolonged impairment’. The 2018 report, Breaking Down Barriers: A critical analysis of the Disability Tax Credit and Registered Disability Savings Plan, explains the many problems with accessing the DTC. It is often difficult for people with an intellectual disability to get approved for the DTC based on their ‘limitations in mental functioning’. People with lifelong disabilities often have to reapply. For young children, the program often assesses their disability by comparing their development with that of other children instead of looking at the impact of their disability on their daily activities. Because children all develop at different rates, this comparison can make it difficult to establish eligibility. As the gateway to the Child Disability Benefit and other financial benefits, ensuring access to the DTC is critically important for the financial wellbeing of people with an intellectual disability and their families.

The Child Disability Benefit itself offers important financial support to parents raising a child with a disability. This payment puts money directly into the pockets of families. To be effective, the CDB must be considered as exempt income, and not taxed or clawed-back at the provincial or territorial levels. While the CDB is most impactful for low- income families, it should be enhanced to offer greater financial security to a wider range of families.

For some families, provincial or territorial social assistance is their primary source of income. These programs of last resort are not designed to address the financial needs of families raising children with a disability. Strict eligibility rules, earning restrictions, and household policies mean that families of children with disabilities remain trapped in poverty. While these programs require significant reform, small steps like exempting child support payments or cohabitation policies should be implemented now.

Having access to adequate income through employment, and programs like a targeted federal income program, contribute to the financial wellbeing of adults with an intellectual disability. This must be supplemented with access to safe, affordable housing and appropriate disability supports. Although not focused on the family unit, the positive impacts of these programs are often felt by the family as a whole. Knowing that the financial security of their loved one is assured, families can focus their resources on meeting their own needs and saving for the future.

Saving for the Future

Family members who are absent from the workforce for long periods of time may find it particularly difficult to save for retirement. Parents who stay at home to support their child do not have access to government savings programs like the Canada Pension Plan (CPP). These parents provide essential support, and their contributions should be recognized and valued. Caring for your child should not mean compromising your future financial security. It’s clear that family members who provide support for their loved ones need a solution to save for retirement while continuing to provide this essential support. Innovative solutions have been developed to allow other groups (like self-employed individuals) to contribute to CPP. Similar options should be explored and tested for family members supporting a loved one with a disability.

Inclusion Canada’s Call-to-Action

The federal government has a responsibility to the families of people with a disability. They need to make sure they are financially secure. Here are some ways they can do this.

Maximum Impact Priorities

1. Provide access to inclusive, affordable childcare for parents of children with an intellectual disability. This must include appropriate before and after school support for children age 12+.
2. Enhance and rename the Child Disability Benefit.
   • The Child Disability Benefit should be considered as exempt income for the purposes of provincial or territorial income assistance. The Child Disability Benefit and other child or family tax credits should not result in a ‘clawing back’ of other financial benefits for families at the provincial/territorial or federal level.
   • Double the current benefit amount ($242.91 per month) for every eligible child.
   • Increase the threshold at which the benefit starts being reduced to align with the upper limit of the second federal personal income tax bracket ($98,040 in 2021). The current threshold for this benefit is a net family income of $69,395). This will provide the greatest level of support to low and middle- income families who need it most.
   • Extend coverage to include youth with disabilities above the age of 18. The Child Disability Benefit should extend to at minimum age 21. However, access up to age 30 would most appropriately reflect the ongoing support families provide to loved ones with a disability. This extended benefit could be renamed the Child & Youth Disability Benefit.
3. Simplify approval for the Disability Tax Credit. As the gateway to the Child Disability Benefit and other financial programs, access to the DTC is crucial. Getting approved for the DTC is particularly difficult for young children, people with an intellectual disability, and people on the autism spectrum. A simplified approval process, without the requirement to reapply, should be introduced for people with disabilities that are lifelong and stable in nature.
4. Support parents to save for retirement. When a parent is out of the workforce for an extended period of time to care for their child, it has a significant impact on their future financial security. We know a gap exists in retirement savings and investment mechanisms for these families. This gap must be recognized, and a commitment made to explore and test solutions.

Systemic Priorities

5. Undertake a comprehensive review of federal government programs, including:
   • An analysis of the Disability Tax Credit as the gatekeeper to the Registered Disability Savings Plan (RDSP) and the Child Disability Benefit (CDB).
   • A review of the eligibility criteria for the Home Buyers’ Plan and its use by families of people with disabilities.
   • A review of eligibility for the Canada Student Grant and its use by people with disabilities.
   • A review of the way in which funds can be moved between Registered Disability Savings Plans (RDSPs) and Registered Education Savings Plans (RESPs) without compromising grants and bonds.
6. Explore enhancements to the RDSP to support families to save for the future (through grants and bonds) and unlock funds earlier. Detailed recommendations for these enhancements can be found in Designing a RDSP Homeownership Plan: Exploring the Canada Disability Savings Program for  Homeownership.
7. Reinstate a mechanism to collect disaggregated data about children with disabilities and their families. This data should allow for analysis based on type of disability.
   
   

Watch the Our Take webinar!

Inclusion Canada’s Position on Income Security

Position Statement

This paper is about money for people with intellectual and developmental disabilities. This paper outlines what Inclusion Canada thinks and believes about being secure with money and income support.

What is the issue with money and income support?

People with intellectual and developmental disabilities need to have money and resources. They need money for their own needs. They need to have enough money so they can take part in all areas of life. They need money so they can live the same kind of lives as people without disabilities. Sometimes they need income support from government to do this.

Income support needs to give people enough money to live on. It must be able to change when people need it to. There also needs to be more than just income support. People with intellectual and developmental disabilities also need other things. They need other disability supports. They need help to figure out other programs and benefits. They need help so they can take part in society in a meaningful way and have a life with dignity.

Background Information

Many people with disabilities in Canada live in poverty. So do their families. This should not happen in a rich country like Canada.

People with disabilities are more likely to be poor than people without disabilities.

• Adults with intellectual disabilities living on their own are often poor. Their poverty rate is 73%.
• Similar adults without disabilities are less likely to be poor. Their poverty rate is only 23%.

Another issue they face is housing. People with intellectual disabilities do not have enough safe and affordable housing. They have a harder time finding homes than people without disabilities.

• Almost 19% of people with intellectual and developmental disabilities need better housing. This means their current home does not meet their needs.
• This is higher than other people in the country. Only 9% of them need better housing.
• This is higher than people with other disabilities. About 17% of them need better housing.

Some people do not have a home. There are 35,000 homeless people in Canada. Many of them have an intellectual or developmental disability. Research shows that they are more likely to be homeless than other people.

Work and money are also issues that affect people with intellectual and developmental disabilities. Many have to use income support from government. They have a hard time finding jobs.

• Only 26% of people with disabilities have paying jobs. This is much lower than the national average of 76%.
• When people with intellectual disabilities work, they don’t get paid much. They make about 33% of what people without disabilities make. This works out to about $16,000 compared to about $49,000.

People with a disability in Canada will probably end up poor. They do not have the disability supports they need. They do not have jobs. They do not get enough income support. This means they often live in poverty. They are also isolated. They are left out of society.

Financial programs that help people are hard to use. They are confusing. They do not always help the people who need it. They can be hard for people who have no family to help them. They can be hard for people who do not understand money and numbers.

Canada needs a new income support program. There is one being talked about right now. It is called the ‘Canada Disability Benefit.’ This program needs to include everybody. It needs make sure people with intellectual and developmental disabilities have enough income and support to live like people without disabilities in Canada. They need to have enough money and resources to take part in all areas of community life.

Discussion:

Impact of COVID-19 on Financial Security

It is hard to be a person with a disability during COVID-19. Some cannot afford to live. The pandemic showed how unfair things are for people with disabilities. Here are some examples.

• During COVID-19, the Canada Emergency Response Benefit was provided. The amount of this benefit was 50% more than disability income.
• During COVID-19, some jobs were affected more than others. Many lower wage jobs were lost or hours were cut back. This affected people with intellectual and developmental disabilities. They were more likely to lose their jobs during the pandemic. They were also most likely to have their hours cut. This pushed people further into poverty.
• During COVID-19, the use of internet and cell phones increased. Many services moved online. This was good in some ways. It helped to keep people in contact. But many people with disabilities could not afford the increase in cost. It showed how this cost can exclude people.

Lack of Information

There is not enough information about people with intellectual disabilities. The following information needs to be found out.

• What is their quality of life?
• How much money do they make?
• What are their poverty rates?
• How many people in Canada have an intellectual or developmental disability?

We do not know how many people in Canada have intellectual or developmental disabilities. Statistics Canada finds it hard to get a correct number. They usually estimate a number. It is usually lower than the real number. All levels of government need to work together to find out this information. They need to get a better understanding of the living situations of people with intellectual disabilities.

Road to Poverty

People with intellectual disabilities need income security. This is about more than just money. It is also about a lack opportunity. It is about not having a choice. Sometimes people have to choose between buying food or paying bills. Sometimes they have to buy bad food. Sometimes they have to ask doctors for free medicine samples. This is because they are poor. Poverty takes away people’s dignity.

There are many reasons that people with intellectual and developmental disabilities are poor or at risk of living in poverty. A solution needs to take in many factors. Here are some of the things it needs to address.

• There are not enough supports for people with disabilities.
• Sometimes people with disabilities do not understand money. They do not understand how to budget. They need to be taught. This is called financial literacy.
• People with disabilities need help finding jobs. Jobs need to be accessible.
• People with disabilities need more money to live. • Education needs to be more inclusive.

Making education inclusive is important. A major reason why people with intellectual disabilities can’t get jobs is because they don’t have a good education. There are many issues with education. Here are a couple of examples.

• Students with disabilities are separated from others. They are put in special education classrooms. They are isolated from the rest of the school. They don’t learn the same information as other students. This sort of education will not help them get good jobs as adults. They are more likely to be unemployed. They are more likely to be left out of society.
• Very few adults with an intellectual disability can get more education after high school. When they can go to university or college or get training, they have better chance at 4 getting a job. One study showed that 80% who had education after high school got a job when they finished their studies.

Without a good education or job, living in poverty is the most likely outcome for most people with intellectual and developmental disabilities.

People with disabilities are also kept out of the job market. They have to rely too much on social assistance in Canada. Social assistance is supposed to be a last resort. It was not made to be long term support. This means it is not a good system to live on. People with disabilities in Canada need a better system. They need one made to meet their needs so they can live a good life.

Provincial and Territorial Programs

Across Canada, social assistance levels are too low. In every province and territory, social assistance amounts are below the poverty line. This means the programs do not give enough money to pay for basic needs like housing and food.

These programs are also affected when people get jobs. When people with intellectual disabilities do find good jobs, it can affect their income support. Some programs take away income support when people get a job. Sometimes they lose $1 from their income support for every $1 they make at work. 4 People with disabilities are treated unfairly for trying to make their lives better. Some governments even took back the COVID Disability Benefit money from people on income support.

Provinces and territories also provide other kinds of supports besides income. Here are some of those supports.

• Essential disability support
• Direct funding
• Health related benefits
• Training
• Employment

Many of these are linked to income support. Sometimes a person with a disability needs a lot of support. They might try to get support from the provincial government. They might also try to get support from the federal government. This can cause issues. Sometimes support programs conflict with each other. This means only one can be used at a time. This is not fair.

Government supports needs to reach the people that need them. One support program should not affect another. New programs should not affect old ones. Different levels of government need to work together to make sure this happens.

Inclusion Canada thinks that all levels of government need to maintain and improve these supports. They need to work together. They need to have agreements to reach this goal.

Federal Programs

Federal Income Tax and Easier Access to Benefits

The online system for filing taxes is very hard to figure out. People with intellectual and developmental disabilities can have a hard time using it. It is hard when they only have income support to report on their taxes. The pandemic made things even more difficult. Most free tax clinics were closed because of COVID-19. People with disabilities could not get the help they needed to file their taxes.

This could be fixed. There could be an automatic tax filing for people with low income. The federal government already has this information. This would help many people. It would help people who do not earn a lot of money. It will also help people on income support.

It would help make sure they do not miss out on any available benefits. This includes the Canada Child Benefit. It also includes the Guaranteed Income Supplement. There are many other benefits people could get if they file their taxes every year. There is over $50 billion available from these programs. These can help reduce poverty for people with low income.

The federal government said they will make an automatic tax filing system. They promised this in 2020. It will improve the financial health of many people with intellectual disabilities. It will lead to better outcomes.

Disability Tax Credit

The Disability Tax Credit (or DTC for short) is a financial benefit. It can help many people with a disability and their families. This tax credit is about the increased costs that come with having a disability. It can help people reduce the amount of taxes they have to pay.

But there are problems with the Disability Tax Credit. These have been shown in research and reports. Some people with disabilities have even given up trying to apply. These are the main problems.

• The application process is complicated.
• The application process is not the same across the country.
• A doctor or medical professional has to fill out parts of the application.
• There are fees to have a medical exam.
• The approval process is not the same across the country.
• The definition of ‘disability’ is not a good one.

Inclusion Canada wants a better definition of disability to be used. The one used in the Accessible Canada Act is better. This definition is also in the Convention on the Rights of Persons with Disabilities. It should be used in the Disability Tax Credit.

There are also other benefits linked to the tax credit. People need to be approved for the tax credit before they can get these. This means they miss out on those benefits.

The process to be able to get the DTC needs to be changed. The other benefits linked to the DTC must be available in other ways. Until these problems are solved, millions of people with a disability will not be able to get the Disability Tax Credit. They will also not be able to get other benefits that are linked to the tax credit. This includes the Registered Disability Savings Plan.

Registered Disability Savings Plan

A Registered Disability Savings Plan (or RDSP for short) is a way for people with disabilities to save money for the long term. People with low income can get federal grants and bonds to add to the savings. These grants and bonds are based on how much money the household earns.

But there are a lot of rules and conditions. The program is hard to figure out. Not many people with disabilities are using it. It is possible that they are missing out on many thousands of dollars in benefits.

The biggest problem with the disability savings plan is getting money out of it. First, there is a 10-year holdback rule. This means there has to be 10 years between the last time money was put into it and the first time money is taken out of it. Second, there are limits on how much can be taken out of the RDSP. If money is take out before a person is 60 years old then there will be a penalty to pay.

But many people with a disability do not live as long as other people. They may not get to use their savings when they need them. There needs to be fewer rules about using the disability savings plan. It needs to be easier to use. People with RDSPs should not have to live in poverty until they are 60 years old.

Canada Disability Benefit

Inclusion Canada is encouraged by the Canada Disability Benefit (or CDB for short). The federal government committed to this benefit. They said this in the 2020 Speech from the Throne. They said it again in the 2021 Federal Budget.

This benefit could help in many ways. It could help people with intellectual and developmental disabilities to get out of poverty. It could help them be more equal to others. It could help them to be treated more fairly.

Inclusion Canada has prepared a proposal. It is called Canada Disability Benefit: A Vision and Design Outline. It talks about the important things the new benefit should do. It talks about the guiding principles it should follow. Inclusion Canada wants to make sure the benefit greatly improves the lives of people with intellectual and developmental disabilities in Canada.

Provincial and Territorial versus Federal Responsibilities

Provinces and territories play a big role in income support. They provide most income support programs. We will work with our members and partners across the country. We will continue to 7 call on provinces and territories to do a better job. We will call on them to improve income and disability support programs.

But we still think the federal government has a larger role in this area. Our Calls to Action are meant for the federal government and federal areas of responsibility.

Inclusion Canada’s Call-to-Action

The federal government has a responsibility. They must help improve income security for people with intellectual and developmental disabilities. They must make sure they have enough money to live now and in the future. These are some actions that can be done by the federal government right now.

Maximum Impact Actions

1. Make a Canada Disability Benefit. It must give people with disabilities a liveable income. It needs to be accessible. It needs to respect people’s dignity. Inclusion Canada has ideas for this benefit. They are in a document called Canada Disability Benefit: A Vision and Design Outline.
2. Update and improve existing support programs. More people need access to support programs. This includes people who have chronic disabilities or disabilities that come and go. Use a more inclusive definition of disability in the Disability Tax Credit. Use the definition of disability from the Accessible Canada Act. An inclusive definition of disability is important. It will make benefits easier to access.
3. Make it easier to withdraw money from RDSPs. Make it easier for people to get their savings. Change the 10-year holdback rule. Let government contributions be owned by people after a certain amount of time. Change the formula for Lifetime Disability Assistance Payments (LDAP). Make it pay out more from the Registered Disability Savings Plan once these have begun.

Medium Impact Actions

4. Separate the RDSP and Disability Tax Credit. Anybody who qualifies for the Disability Tax Credit should also qualify for an RDSP. People with intellectual and developmental disability who get provincial and territorial disability support could be automatically put into the RDSP program.
5. Make it easy to apply for the Disability Tax Credit.
   • Remove all barriers to applying. It costs money to get doctors to help with the application. The federal government could pay for this directly. Or they could provide grants to cover the costs. The grants could go to non-profits in the poverty and disability areas to help people get the DTC.
   • There are many companies that have a service helping people with disabilities fill out DTC applications. They charge money for this. There are rules around how much they can charge. These rules need to be enforced so they are followed.
6. Increase the Disability Supplement for the Canada Worker’s Benefit. When people with disabilities find good jobs their disability benefit payments drop. This needs to stop. This will help encourage people with disabilities to find work.
7. Make sure everybody has internet and cell phone access. Everybody needs these in today’s world. Make sure people have access to internet they can afford. Give people affordable cell phone service. Providers across the country should give discounts to low-income earners.
8. Automatically approve specific populations for the Disability Tax Credit. Every person with a disability should get it. They should not have to apply for it. This will also automatically make them get other benefits. This will help people with a disability. It will help people who are injured from work. It will also help people who qualify for CPP-Disability or other programs.

Systemic Impact Actions

10. It is important to do Gender Based Analysis Plus or GBA+. This is a process of looking at how different groups of people are affected by different programs and policies. It is also important to use a disability lens. This will be used to look at the effect of government programs, policies and plans. It will also be used when collecting information about people with disabilities.
    • Government needs to collect better data about people with disabilities. They need information about their levels of income and their families. They need information about who they live with. They need information about what type of disabilities people have. Government should track this data over time. This will help make sure benefits go to people who need them most.
11. Change how people get government benefits. People with disabilities should not have to do a tax return to get the benefits that they are qualified for. The Canada Revenue Agency (CRA) needs an auto-file system. This will make sure people get their benefits. People need the Disability Tax Credit starting when they are 16 years old.
    
    

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Inclusion Canada’s Position on Income Security

Position Statement

People with intellectual and developmental disabilities must have the income and resources they require; to meet their personal support and income needs in order to secure a standard of life comparable to Canadians without disabilities; and fully participate in all aspects of community. Where income support is required to assure income security, it must provide a meaningful, responsive, and livable income. People with intellectual and developmental disabilities must also have access to the disability-related supports, assistance to navigate the provincial and federal benefits and programs, and income support and benefits necessary to fully participate in society in a meaningful and dignified manner.

Policy Context

Canadians with disabilities and their families face staggering rates of poverty that are inexcusable in a prosperous country like Canada. Canadians with disabilities are more likely to live in poverty than other Canadians.

• Seventy-three per cent (73%) of working age adults with an intellectual disability who live on their own are living in poverty, compared to 23% of those in the same age cohorts among the general population.

Access to safe and affordable housing is also an issue with a disproportionate number of people with intellectual disabilities in core housing need in Canada.

• 18.5% of persons aged 15 years or older with intellectual disabilities live in a household in core housing need in Canada – more than twice the average for all households in Canada (9.1%) and higher than persons with other disabilities (16.6%)
• Adults with an intellectual disability are over-represented among the estimated 35,000 homeless population in Canada – available evidence points to a much greater likelihood of being homeless than the general population

People with intellectual disabilities are far less likely than others to have access to paid employment and disproportionately rely on government sources of income assistance.

• People with intellectual disabilities earned 33 percent less than the average income of non-disabled people ($16,283 versus $49,235)
• Only 25.5% of working age people with intellectual disabilities have paid employment compared to the national average of 75.5%.

In Canada, poverty is the most likely outcome for someone with a disability. People with a disability lack the disability-related supports, employment, and income supports they need to live free of poverty, isolation, and exclusion. Financial supports that do exist are complicated to navigate and are often poorly understood and underutilized, especially for those people who do not have access to family and financial expertise to do so.

A comprehensive Federal approach to income security is required now. Recognizing that dialogue on a prospective Canada Disability Benefit is underway and with significant structural changes required, their remains much work to be done to ensure people with intellectual and developmental disabilities have the income and resources they need to secure a standard of life comparable to Canadians without disabilities, and to fully participate in all aspects of community life.

Discussion:

Impact of COVID-19 on financial security for people intellectual disabilities

During the COVID-19 pandemic, income security decisions were starkly exposed for persons with disabilities. Among many things, it illustrated the societal and government expectations that people with disabilities should survive on long-term disability income benefits at 50% or less than what the Canada Emergency Response Benefit provided. During the pandemic, workers in lower wage jobs suffered the greatest losses (reduction in hours, job losses, etc.) compared to those in other jobs. This increased the susceptibility of people with intellectual and developmental disabilities being pushed further into poverty. This period also highlighted the lack of affordable internet, cell phone usage, and access to information technology tools that have now become a necessity in an increasingly virtual, remote environment where most services and human contact have moved online. Digital or virtual access to services can be considered a positive step for our community but without access to low-cost broadband and accessible technology it has become yet another barrier.

Lack of Data

The data on tracking and reporting of people with intellectual and developmental disabilities needs major improvement. Canada is far behind other international jurisdictions in identifying the quality of life, income, poverty rates, and other outcomes among persons with intellectual disabilities. In fact, Statistics Canada struggles to even fully identify an accurate number of people identified as having intellectual and developmental disabilities and has historically underestimated the size of the population. Collective efforts from all levels of government is needed to properly portray the true economic situation of people with intellectual and developmental disabilities in Canada.

Road to Poverty

Income security for people with intellectual disabilities is not simply about money. Poverty results not only from the absence of money but the absence of opportunity. People with intellectual and developmental disabilities living in poverty lack real choice: having to choose between paying bills and buying groceries, having to rely on doctors for free medical samples and having to buy second rate food. Poverty strips people of their dignity.

Assuring financial and income security requires tackling the multiple factors that contribute to making people with intellectual disabilities disproportionately vulnerable to poverty; in particular, lack of disability-related supports, financial literacy, employment related supports, income support, and inclusive education.

Barriers to receiving quality inclusive education remains a factor in higher levels of poverty experienced by people with intellectual and developmental disabilities. The majority of students with an intellectual disability remain segregated and congregated in special education classrooms which have become a pipeline to exclusion, marginalization and unemployment in adulthood. Access to a quality inclusive education contributes to better employment outcomes. Few adults with an intellectual disability have access to inclusive post-secondary education. When inclusive post-secondary education is made available, as one study concludes, it leads to positive outcomes with 80% of participants gaining employment upon the completion of their studies. It is no surprise that poverty remains a likely outcome for the majority of people with intellectual disabilities.

As people with intellectual disabilities continue to be excluded from the labour market, there is an over‐reliance on social assistance in this country; a system never designed to address the real income needs of Canadians with disabilities. Built as a system of last resort, our current systems of income support are failing to provide people with intellectual disabilities the income supports they need to prosper.

Provincial/Territorial Programs

If a person with an intellectual disability is fortunate enough to secure a job, income derived from employment may cause a claw back of provincial and territorial income supports. This claw back or reduction rate can act as a disincentive to earning employment income. Specifically, where threshold rates are low and/or reduction rates are high, people with a disability are unfairly penalized for trying to improve their financial circumstances through employment. Where reduction rates equal 100%, people with a disability are no better off financially to work as they lose $1 in income support for every $1 earned through employment income. Further, social assistance levels across the country are vastly inadequate. If you are living solely on provincial/territorial assistance, you are living below the poverty line. According to the National Council of welfare, in all provinces and territories, benefit levels fall below the after‐tax low‐income‐ cut‐off.

In addition to providing income supports, the provincial and territorial governments are responsible for providing essential disability supports and direct funding; some health-related benefits; and other supports such as training and employment. Many of these programs are tied to eligibility for provincial or territorial income support programs. Although we see a greater role for the Federal government in providing targeted income supports for people with a disability, there remains a strong role for the provincial and territorial governments to maintain and improve supports for people with a disability.

Throughout the pandemic, the need for better cooperation between the levels of government was emphasized, whereby some jurisdictions saw it necessary to claw back the federal COVID Disability Benefit. In advance of discussions regarding a new disability income benefit, in order to be meaningful and effective, any new investments must not adversely impact existing benefits or eligibility for other needed supports. The Inclusion Canada Federation must hold both levels of government accountable to ensure that gains made for people with a disability from a targeted federal income support program must reach those people to whom it is directed. Strong federal and provincial/territorial bilateral agreements are needed to further this goal.

Federal Measures

Federal Income Tax and Easier Access to Benefits

For people with intellectual and developmental disabilities, navigating the filing of income taxes at the best of times is complex and a difficult process particularly when their income is only provincial income support. The pandemic served to heighten the awareness of this as most volunteer income tax clinics closed during this period and were unavailable. The value to having automatic income tax filing for low-income earners is good tax policy. Many people with low incomes miss out on benefits as a result of not filing a tax return. The federal government already has the information needed to get low-income people access to important tax-related benefits.

If individuals do not file their annual tax and benefit form, they do not receive significant government supports such as the Canada Child Benefit or the Guaranteed Income Supplement, which help reduce poverty. Dozens of other federal and provincial benefits also require annual filing: more than $50 billion of benefits for low and middle income people annually.

A free automatic tax filing system will help ensure millions of low-income and vulnerable Canadians, who face barriers to filing their taxes, receive the benefits they are entitled too. This measure, which was committed to in the 2020 Speech from the Throne, would serve to improve the financial positions of people with intellectual disabilities and could be an easy fix as one way to improve financial outcomes.

Disability Tax Credit

The Disability Tax Credit (DTC) can provide a financial benefit (in the form of a non-refundable tax credit) for many people with a disability and their families. The tax credit recognizes the increased costs that a person with a disability may face and also acts as a gateway for other federal benefits, tax credits, and programs including the Registered Disability Savings Plan. The importance of DTC eligibility in the role of income security can not be discounted.

Numerous studies and reports have highlighted the barriers to access the DTC for certain populations such as the complicated application process, the role of medical practitioners, and fees required to have a medical exam. As long as these barriers remain in place, millions of people with a disability will be unable to access the benefits tied to DTC approval.

Removing barriers to the application process would improve access to those who have given up on applying due to the complex process. Inclusion Canada supports improvements to the application process in order to make it accessible and easier for those it was designed for. We also support a broader social model definition of disability, as recognized in the Accessible Canada Act or by the principles of the United Nations Convention on Rights of Persons with Disabilities, which would allow all people with a disability equitable access to the benefits that DTC eligibility provides.

Considering that some individuals are not approved through an inconsistent application and approval process or are unable to apply as a result of the cost of having a medical practitioner complete the application, these issues could be resolved through revamping the DTC by creating a different eligibility process, and uncoupling the benefits tied to DTC eligibility. If the DTC process remains unchanged, other opportunities for eligibility for the RDSP must be explored.

Registered Disability Savings Plan

The RDSP is a savings plan specifically for people who have a disability to allow for long term savings supplemented by federal grants and bonds based on the household income. Similar to many benefits associated with disability, the rules and restrictions associated with the RDSP are complex, confusing, and uptake of the program is low. This results in potentially tens of thousands of dollars in sacrificed benefits for many people.

Under its current structure, the funds held in an RDSP are largely inaccessible because of the 10-year holdback rule and restricted withdrawals. The RDSP does not provide access to funds without significant penalty until age 60 in most cases. Many disabilities can result in shortened life expectancy meaning people may not be able to access their RDSP assets when they are able to use them. Rules around RDSP withdrawals should allow people to access their funds when they need them with fewer restrictions. People with RDSP assets should not be held in poverty until they are of retirement age.

Canada Disability Benefit

We are encouraged by the government’s commitment to implement a new Canada Disability Benefit as outlined in the 2020 Speech from the Throne as well as the 2021 Federal Budget. This benefit has the potential to significantly address the issues of inequality, poverty, and discrimination experienced by people with intellectual and developmental disabilities. Inclusion Canada has prepared a separate proposal titled Canada Disability Benefit: A Vision and Design Outline, which sets out the essential elements and guiding principles we envision must be included in a new Canada Disability Benefit. Our focus remains on ensuring the benefit is designed so that it will dramatically improve the lives of people with intellectual and developmental disabilities in our country.

Provincial/Territorial versus Federal Responsibilities

While it remains true that provinces and territories play the largest role in the provision of income support, the focus of this position statement is targeted towards measures the federal government has in its ability to improve the financial security of people with intellectual and developmental disabilities. Within our Inclusion Canada federation, our member associations will continue to call on their provincial and territorial governments to improve their social assistance and disability support programs for the financial security of the people in their community. The federal government has a larger role to play; the Calls to Action are targeted at the federal level jurisdictional responsibilities.

Inclusion Canada’s Call-to-Action

The federal government has a responsibility in improving income security for people with an intellectual or developmental disability and could act immediately to do so.

Maximum Impact Priorities

1. Implementing a targeted federal income program for working age people with a disability – The Canada Disability Benefit – that considers dignity, ease of access, and a livable income level for all people who have a disability in Canada. For a framework of the model Inclusion Canada is advocating for implementation, please refer to the Canada Disability Benefit: A Vision and Design Outline.
2. Modernizing the eligibility for federal programs for people with an intellectual or developmental disability either through a reworking of the Disability Tax Credit to account for both chronic and intermittent disabilities or by using the Accessible Canada Act definition of disability.
3. Loosening the restrictions for RDSP withdrawals to allow people more access to their funds. Specifically, change the 10-year holdback rule to allow for greater flexibility in making withdrawals. Permit government contributions to vest after a specified period even if further government contributions are received and changing the formula for Lifetime Disability Assistance Payments (LDAP) to pay out more from the RDSP once these have begun.

Medium Impact Priorities

4. Decoupling the eligibility for the RDSP from the Disability Tax Credit. This could include recognizing people with intellectual and developmental disabilities who are eligible for provincial and territorial disability support programs as being automatically eligible to participate in the RDSP.
5. Eliminating the barriers to applying for the Disability Tax Credit.
   • The cost for the application is the fee charged by medical practitioners to complete the paperwork. The federal government should also provide grants to non-profits in the poverty and disability space in every province and territory to subsidize the cost of applying or cover the cost directly.
   • Bring into force the Disability Tax Credit Promoters Restrictions Regulations, stemming from the 2014 Disability Tax Credit Promoters Restrictions Act. This sets a maximum fee that businesses and professionals can charge to assist someone in completing and submitting the Disability Tax Credit application ensuring that refunds from the Disability Tax Credit approval are returned to the people who need them most.
6. Increasing the Disability Supplement for the Canada Worker’s Benefit to reduce disincentives for employment and compensate for the high reduction rates in most provincial and territorial income support programs for people who work.
7. Recognizing that internet access is a necessity and provide adequate low-cost broadband access and affordable cell phone data plans to low-income people (not just families with young children) through major internet providers across the entire country.
8. Automatically approving specific populations for the Disability Tax Credit to reduce the effort that people who have a disability make to qualify for all federal disability benefits. This could include, but is not limited to, people who qualify for CPP-Disability, injured workers, or those who qualify for provincial or territorial disability support programs.

Systemic Priorities

10. Ensure that GBA+ analysis includes a robust disability lens for all government programs, policies, initiatives, and data collection, to understand the impact to people with a disability. For federal programs to be effective for people who have a disability, the impact of those policies must be assessed with a disability lens. More robust data about people who have a disability, their families and living arrangements, their incomes, and the nature of their disability must be gathered and tracked over time to ensure that federal benefits are reaching those most at risk of income insecurity.
11. Changing access to federal benefits so they are not dependent on filing a tax return. Have CRA auto-file simple tax returns to ensure that people get the benefits to which they are entitled. For those people who qualify for the Disability Tax Credit, this process should begin at age 16.
    
    

Watch the Our Take webinar!

Inclusion Canada’s Position on Income Security

At a rate of 75%, pervasive poverty exists among adults with an intellectual disability, significantly restricting income security and disability supports to ensure a good life in community.

Our goal is for Canadians with an intellectual disability to have the income and resources they need to secure a good quality of life and fully participate in all aspects of their communities.