Income Security Advocacy Centre

ISAC works to address issues of income security and poverty in Ontario

There’s still time to submit comments on how to improve the Canada Disability Benefit. Our Submissions Guide is here!

The Canada Disability Benefit Act was passed in the House of Commons in Spring 2023, but the details of the Canada Disability Benefit (CDB) are still being worked out by government staff.

We are currently at the point in the process where government staff has produced draft regulations that will determine the details of the CDB. Regulations are detailed rules that will guide how the CDB should be administered, who will be eligible, and all of the other important considerations that are not already outlined in the Act.

In addition to releasing the regulations, the government also released a Regulatory Impact Analysis Statement or “RIAS”, which includes a description of why the regulations are drafted the way they are, cost considerations, interactions with other government programs and benefits, positive and negative effects, and a summary of the Fall 2023 public consultation.

Both the RIAS and the draft CDB Regulations are posted to the Canada Gazette here. Individuals and organizations are invited to provide comments on both of these sections through comment boxes at the end of each sub-section. The government says they will consider public comments in making decisions about the final CDB Regulations.

ISAC staff have designed a Submissions Guide that includes comments/recommendations for several of the sub-sections of the RIAS and the draft CDB Regulations. Instructions on how to use the Guide are contained within the document.

CLICK HERE TO DOWNLOAD “ISAC’s Submissions Guide for Comments on the CDB Draft Regulations”. NOTE: Download will start automatically.

Our hope is that you will be able to open the Guide, open the Gazette website (same link as above), and simply copy and paste comments from the Guide into the corresponding section of the Gazette. The image below shows an example of how to do this.

This image is made up of screenshots of two computer screens. On the left is a screenshot of the ISAC Submissions Guide open in Microsoft Word, showing the General Comment section of ISAC's Submissions Guide with the words "General Comment" circled in red. On the right is screenshot of the Government of Canada's Gazette website, which is linked elsewhere in this website post. A red arrow has been added to the overall image, pointing from the text portrayed in the Word doc on the left side of the overall image, to the part of the Gazette website where you would add the text on the right side of the overall image.

We developed the recommendations in the Submissions Guide based on legal and policy research, feedback from community legal clinic staff, discussions with other advocacy organizations, and in consideration of public and ongoing conversations about the CDB.

ISAC is a specialty community legal clinic so some of our recommendations are very technical and refer to other policies, legislation, Acts, and legal precedents. Other recommendations we are endorsing are more straightforward. Above all, our recommendations are supported by the belief that the CDB must achieve its purpose of reducing poverty experienced by people with disabilities. The current regulations the government drafted fail to achieve this crucial purpose.

Please use and share the Submissions Guide and make sure to get your submissions in by Monday, September 23, 2024, at 11:59 PM (EST)! If you have comments or questions about our recommendations, get in touch with us at info@isac.clcj.ca.