Ontario’s social assistance system is in the midst of a “modernization” process that aims to “build a more responsive, efficient, and person-centred” system.
The modernization process essentially involves two parts – Social Assistance Renewal (SAR) led by the Ministry of Children, Community and Social Services (MCCSS) and Employment Services Transformation (EST), undertaken by the Ministry of Labour, Immigration, Training and Skills Development (MLITSD).
The foundational changes related to the SAR were laid out in Schedule 21 of the Supporting Recovery and Competitiveness Act, 2021 (previously Bill 276), which proposed a number of changes to the Ontario Works Act. Two years after receiving Royal Assent, several of the proposed changes have finally come into effect on September 1, 2023.
Here’s a look at some of the key changes, what they mean for the delivery of social assistance, and the ongoing concerns of community legal clinic clients, staff, and social assistance advocates:
Changes to the Ontario Works delivery system, broken down:
New: MCCSS now holds the power to designate itself as the delivery agent for a geographic area, allowing the Ministry to take over the role of overseeing eligibility for financial assistance in that area.
Old: In the previous structure, only a MCCSS designated municipality, District Social Services Administration Board (DSSAB), or First Nation Band served as delivery agents. The delivery agents were responsible for delivery of all program components, including financial assistance and case management.
New: In the geographic areas where MCCSS is the delivery agent, MCCSS shall “appoint an employee of the Ministry as administrator to oversee the administration of this Act and the provision of assistance in the delivery agent’s geographic area” (Ontario Works Act, 1997, Sec. 43 (2)).
Old: Previously, the administrator was only appointed by the municipality, DSSAB or Band to oversee the administration responsibilities in the geographic area of their operation.
New: MCCSS can now designate a municipality or a DSSAB as a “delivery partner” to carry out powers and duties relating to the administration of social assistance in geographic areas where MCCSS is the delivery agent. This essentially facilitates delivery by the municipalities and DSSABs of what has been called “life stabilization” support i.e. connecting clients to local supports they need. The desired outcomes of the approach include “more people exiting to employment”, “shorter stays on assistance” and “reduced child welfare involvement” (Recovery & Renewal: Ontario’s Vision for Social Assistance Transformation, 2021). The delivery partners will be accountable to MCCSS to meet its performance standards (Ontario Works Act, 1997, Sec. 50.1 (2)). Functionally, program decisions will be made by employees of a delivery partner (municipal or DSSAB staff) but legal accountability for decisions will rest with the administrator (a Ministry employee).
Old: Delivery partner is a newly introduced term.
New: In geographic areas where MCCSS is the delivery agent, MCCSS shall pay every delivery partner “an amount determined in accordance with the regulations for Ontario’s share of the delivery partner’s costs” (Ontario Works Act, 1997, Sec. 52 (1.1) (a)). Essentially, this change enables MCCSS to create a cost sharing framework with the delivery partners as well as with delivery agents. However, there is a lack of clarity on the funding arrangement and the distribution of costs between the Ministry (delivery agent) and the municipalities (delivery partner) at this point.
Old: The Ministry would simply fund every delivery agent, which would have been a municipality, a DSSAB, or a First Nations Band.
Why the changes?
The changes were made “to create an efficient, effective, streamlined social assistance system” (Recovery & Renewal: Ontario’s Vision for Social Assistance Transformation, 2021) with the Ministry now taking a greater administrative role. The new provisions essentially pave the way to gradually shift functions between MCCSS and municipalities, where MCCSS takes over the administration of eligibility and financial assistance, while the municipalities deliver life stabilization services.
What are the major concerns about the changes to the system?
Unproclaimed “Employment and life stabilization assistance”: Whilesome of the proposed changesin Schedule 21 of the Supporting Recovery and Competitiveness Act, 2021 have come into effect, some key parts of the Schedulestill have not. The sections (Schedule 21 – ss. 1-3, 17, 18 (1), (2), and 22) related to the introduction of the new term “life stabilization assistance” have yet to be proclaimed. “Life stabilization” refers to social support services related to housing, mental health, addiction counselling, and domestic violence supports, among others.
These amendments are important because life stabilization is a key component of the government’s modernization vision and a necessary precursor for social assistance recipients to access anything from transit to employment supports. It is important to note, though, that employment supports are in the process of being taken over by the MLITSD, a change which presents a different set of concerns.
ISAC has previously raised a number of concerns about life stabilization services, and strongly advocated that the new system ensure voluntary, not mandatory, client participation in life stabilization services, equitable provision of activities, and the setting of clear, realistic and fair benchmarks with regard to length of access and quality of services, all in consultation with participants with lived experience.
MCCSS has provided some assurance that this “life stabilization” approach will not simply push social assistance recipients into the labour market before they are ready, but the fact that this section is yet to be proclaimed raises concern about MCCSS’ commitment to providing this crucial support.
Funding arrangements for pre-employment and life stabilization supports still in question: As the lack of clarity in the funding arrangement between the Ministry and the municipalities persists despite the new amendments, concerns remain about inadequate funding or investment in “life stabilization” support.
Without substantial funding for the municipalities and coordinated arrangements for these pre-employment services, the new system might only create more bureaucratic hurdles for clients and leave them without any tangible supports beyond referrals to “life stabilization” services that do not yet exist. The province must provide a significant investment to ensure robust and quality services to which clients can be referred.
The co-designing process: Currently, social assistance modernization is in its second phase – the “renewal” period, which is expected to run until 2024. According to the province’s originally announced vision, this phase is supposed to strongly emphasize flexible and collaborative co-design of the framework, with clear roles designated between the delivery agent and delivery partners. The two year time period between Royal Assent and bringing the Act into force was intended to allow for flexibility and time to prepare for the administration of an Act. This was supposed to include consultations and preparing regulations and explanatory materials.
Yet the progress of this phase has been slow since the 2022 provincial elections and there is little information about stakeholder engagement and testing of new structures at prototype sites. This raises concerns about the status and accountability of the co-designing process.
For the new system to work, it is imperative that there are clear responsibilities, coordination, and functional processes in place so that MCCSS and municipalities can serve clients smoothly all along the way, from eligibility and financial assistance consideration to life stabilization. Without robust and transparent consultations with stakeholders in designing collaborative processes, more vulnerable clients are sure to fall through the cracks.
The digital application system: The social assistance modernization process involves a provincially-administered, centralized, digital application system. This centralization and digitalization process is moving rapidly ahead, with more than 80% of the social assistance applications from all 47 municipalities in the province currently being submitted online.
Yet Ontario’s 2014 initiative to digitalize social assistance system was marred with significant “data issues, defects and delays” (Annual Report of the Office of the Auditor General of Ontario, 2015). For social assistance clients in dire and immediate need of support, such shortcomings can be devastating. While the current digitalization effort might be informed by the past experiences, little information about the evaluation of the process has been shared publicly, and so concerns remain about the effectiveness of the fast-adapted centralized and automated system.
Where do we go from here?
In Ontario, a single individual is left $17,378 below, a person with disabilities $11,760 below (without accounting for additional costs associated with disability), and a couple with two children $21,894 below the Official Poverty Line after adding up all the provincial and federal social assistance they are eligible to receive. These dire numbers show that modernization of the social welfare system is surely a necessity in the province.
Administrative restructuring and digitalization is part of the process, yet social assistance modernization’s success will depend on the adequacy of investment into the program overall, ensuring appropriate and accessible life stabilization services and enough monthly income into the pockets of those receiving social assistance.
A clear, transparent co-designing process with meaningful participation of clients and deliverers cannot be merely lip service, but must be an essential principle in practice at all stages if the new system is to adequately provide for more than nine hundred thousand Ontarians who rely on social assistance for their livelihood.