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15 November, 2022

DWP Submits Brief in Support of Canada Disability Benefit

On November 11, 2022, Disability Without Poverty submitted the following brief to HUMA, the Government of Canada’s Standing Committee on Human Resources, Skills and Social Development and the Status of Persons with Disabilities, outlining our recommendations with respect to Bill C-22, the Canada Disability Benefit.

Please accept this as our follow up to the witness testimony we gave to the HUMA committee on Monday 31st October 2022. We very much appreciated the invitation to appear and to be able to respond to questions given our individual lived experiences of disabilities and our professional and academic expertise. In addition to that testimony, we would like to draw your attention to the following points:

Bill C22 is a lifeline for many people with disabilities who feel abandoned, who think our government just doesn’t value their lives. There is no more grace of time beyond this year to give them hope that there is help coming. In good faith, this bill needs to become law putting trust in the hands of people with disabilities and disability organizations who have been and will continue to be working hard to ensure that people with disabilities get what they need. We have been talking to and are bringing forward the voices of hundreds of people with disabilities, their families and allies across Canada who are dedicated to advocating for those whose voices are not heard or don’t reach the system.

A National Crisis
We feel the need to emphasize why the Canada Disability Benefit is needed by working aged Canadians, as they face poverty hardships that are insurmountable without additional assistance:

  • Pre-pandemic, the rates of poverty for working aged disabled Canadians far surpass those of non-disabled people and disabled seniors[1], with 28.3% of severely disabled working-aged people living in poverty, in comparison to 10% of people with no disability and 10% of severely disabled seniors. No one should live in poverty in Canada in 2022.
  • During the pandemic, disabled people found themselves excluded from CERB, because the previous income and numbers of hours worked requirements created barriers for them. They only received a one-off $600 payment if they were already signed up for federal benefits like CPP-D/QPP-D, DTC or Veteran’s Disability Benefits.
  • There is a housing crisis felt particularly by disabled people. We know you have heard testimony relating to this, and want to add our voice to this crucial concern.
  • Inflation continues to rise and yet the provincial benefits are not index linked. Food inflation, the one that affects disabled people living in poverty most keenly, is at 11.6%.

This is a national crisis and must be addressed as one.

Collaboration and Co-creation
We recognize that the framework nature of Bill C22 causes lots of concern and consternation amongst legislators and the disability community. It requires a leap of faith that the disability community will be treated with respect, and that promises made about the involvement of disabled people in the co-creation of regulations will be kept.

It is with concern, then, that we heard that plans have already been made for the engagement processes to be used, and that these plans have been made without consultation with the disability community.

We would like to refer you to the much-used IAP2 Spectrum of Public Participation[2], and we believe that the engagement for the regulations of the Canada Disability Benefit must happen at the “Collaborate” level. This is crucial to how this benefit will be built and delivered, and be a strong signal that the trust Minister Qualtrough believes she deserves from the disability community is warranted. We strongly advocate that the process be one of collaboration and co-creation with the disability community. Anything less would be to break rationale for this framework legislation and cause irreparable harm of relationships with the disability community.

The pandemic has taught us many lessons. Not least is that we have learnt to work in new ways. For many of us in the disability community, working online and virtually was our norm before this, so we welcomed everyone else into our way of doing things. These regulations must be co-created in this same spirit of doing things differently. We cannot fall back on old ways, of engagement and consultation. We must work in collaboration – openly – to ensure that this benefit actually benefits disabled people. We suggest that the government be open to co-creating regulations using deliberative public engagement approaches such as minipublics to get deeper involvement from disabled people on the ethical impacts of the regulations being proposed. This approach has already been used successfully in Canada[3], and we should suggest previous approaches can be modified to fit the needs of both the federal government and the disability community, to engage within the wider disability community.

An example – Access to employment
We need to make sure that those disabled people who can work, and within regulations for the Canada Disability Benefit, they must receive a generous earnings exemption to do that. In BC, changing from an earnings exemption that was calculated monthly to one that was calculated annually trebled the number of hours that were claimed – those who were able to work, were able to work more.

Employment for disabled people can be precarious. Disabled people need to make sure they can build some equity during periods of employment to pay for things they cannot afford in periods of unemployment. It sounds so obvious. But, with the additional costs of disability, moving between one health plan and another, for example, often leaves gaps and unexpected costs. Often we hear that benefits should not disincentivize disabled people to work. That’s incredibly insulting. We seem to be stuck in some bizarre belief that disabled people would prefer to have an income of $1000 a month, for example, struggling to pay for the necessities of life, than to go to work and be more economically comfortable. We are yet to meet that person. Instead, disabled people are left trying to balance the restrictions on each benefit within the patchwork system they are part of. These are not decisions made in wealth – these are decisions made below the poverty line. We know of a person on a ventilator who was offered a high paying job and had to turn it down because the supports needed to keep the ventilator functioning were no longer covered by the province once they were employed and would not be covered by their employees extended health plan, or any other work accessibility program that could be found – literally, they could stay unemployed and alive on the the ventilator or receive a high paying job and die. This is a prime example of intersecting systems, in this case employment and provincial services, that currently provides insurmountable barriers to the advancement of disabled people in our society.

We highlight these employment issues as just examples of the issues to be decided within regulations, and the value that lived experience brings to the development of regulations. Equally, we could have highlighted the amount of the benefit, “claw backs”, eligibility, individualization, barriers to apply, or any of the other details that must be resolved in regulations. Disabled people must receive an equal seat at the table to co-create regulations and the systems that will implement the CDB.

Bill C22 as a framework, and the nature of a supplemental benefit
We recognize that Bill C22 provokes anxiety within the disability community as it does require a leap of faith that the regulations will be created openly and fairly. However, we believe that Bill C22 already contains a variety of information that we are happy to see:

The preamble speaks to the values that will underpin this legislation, from the Charter of Rights and Freedoms, to the United Nations Convention on the Rights of People with Disabilities, to the Accessible Canada Act, to including the disability mantra of “nothing about us without us”. We have to believe that the introduction of these values bound by charter, convention and legislation means something to all of us.

Furthermore, the preamble also says that “Parliament recognizes the leading role that the provinces and territories play in providing supports and services to persons with disabilities and the importance of engaging with them in developing income supports and other support services”, while Section 8 recognizes the rights of the minister to enter into agreement with the provinces. We have heard repeatedly that this bill is a supplement not a replacement, and that its intention is to supplement the disability assistance that disabled people receive federally, provincially and territorially. Implicit in this, therefore, is the government’s acceptance that the federal, provincial and territorial programs that the CDB supplements are judging the eligibility of the people receiving it as sufficient for its purposes too. Therefore, it seems that a major part of the eligibility regulations has already been completed by these assertions already in Bill C22 and by the government’s public statements – the government sees the value of provincial and territorial work as stated in the preamble, the minister can enter into agreement with the provinces, and by the continual testimony from the government, this benefit is supplemental to those programs – and by these assertions, all of those currently receiving federal, provincial and territorial disability benefits are eligible for the Canada Disability Benefit. This work may be complex, but there are straightforward solutions to be found.

The Canada Disability Benefit is a test of our values as a country. Now is the time to eradicate disability poverty.


  1. Given that disability poverty, particularly amongst working aged disabled people, is a national crisis, Bill C22 must move speedily through all legislative steps to Royal Assent.
  2. The lived experience of disabled people is crucial for the co-creation of regulations, and their involvement must be at the highest levels of collaborative engagement throughout their development, and continue through the implementation of the Canada Disability Benefit.
    Thank you for reading our submission and for your time on this committee.

1 Statistics Canada, (2018), A demographic, employment and income profile of Canadians with disabilities aged 15 years and over, 2017, Catalogue no. 89-654-X2018002



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