Bill C-26: CCD Presentation to the Finance Committee on Enhancements to the Canada Pension Plan

Who are Canadians with Disabilities?

When we speak of people with disabilities, we are actually talking about people with impairments who are disabled by the environment and type of society in which they live:

• People may have impairments with hearing, seeing, communicating, walking, thinking, learning or doing any similar activities, but they are disabled often because of inaccessible information, inaccessible buildings, homes and apartments that are not designed for people with impairments, and public and private spaces which are inaccessible, lack of supports and services for employment, education and training, lack of services to remain in one’s home and stigmatizing attitudes.
• People with impairments are disabled often because of societal barriers, both structural and attitudinal which limit the types of activities that people can do in their homes, at school, at workplaces and other activities. In this sense disability, based on the United Nations Convention of Rights of People with Disabilities defines disability in terms of social factors not so much in terms of individual biology.
• People with disabilities want to be part of their broader communities, to be educated, to be trained, to have good paying jobs but this requires leadership and commitment from governments, the private sector and disability organizations to work together to bring about this change.

What are the employment realities for Canadians with Disabilities?*

We know that people with disabilities are less likely to be employed than people without disabilities.

• The participation rate for people without disabilities aged 15 to 64 years was 79.3%; for people with disabilities, this dropped to 53.6%. (Participation rate is employed + unemployed/total population.)

We know that people with disabilities have lower incomes than people without disabilities.

• The self-report median income in 2010 for people with disabilities aged 15 to 64 years was just over $20,000 while for people without disabilities, it was just over $30,000.

We know that many people with disabilities rely on government programs for income and social supports.

• Among the 204,700 people with disabilities who are completely prevented from working, 43.4% reported that they received CPP-D/QPP-D in 2011.
• Among the 632,600 people with disabilities aged 15 to 64 who are permanently retired, 39.9% reported that they received CPPD/QPPD in 2011.

Impact of Bill C-26

Due to known sporadic employment periods, a person with a disability who was unable to maintain workforce attachment throughout their adult working life potentially has a greater impact on the benefit of the enhancement as other Canadian citizens.  The impact for people with disabilities will likely be greater levels of disparity between disabled and nondisabled people in the amount received in CPP benefits. 

Additionally, it has the potential to further impact women and girls who are typically the care givers for both children and family members with disabilities.  Women with disabilities who are also caregivers will be hit with a potential double reduction in revenues, through these proposed measures, if their disability and caregiving drop out periods are in different years.

Analysis

It is the view of CCD that the implementation of the measures in Bill C-26 has the potential to negatively impact Canadians with disabilities in a manner that could increase the disparity in income levels between Canadians with disabilities and other Canadians.  The removal of the drop out options in the enhanced portion has the potential to further increase the disparity between disabled and non-disabled Canadians through a publicly designed pension scheme.  This would be in contradiction to the intent of the UN Convention on the Rights of Persons with Disabilities which Canada has signed and promised to uphold. Some of these protections are important to highlight here.

CRPD Preamble -  (t) Highlighting the fact that the majority of persons with disabilities live in conditions of poverty, and in this regard recognizing the critical need to address the negative impact of poverty on persons with disabilities,

Article 3 General Principles e) - Equality of opportunity, not being treated the same

Article 5 Paragraph 3 and 4 - In order to promote equality and eliminate discrimination, States Parties shall take all appropriate steps to ensure that reasonable accommodation is provided.

Specific measures which are necessary to accelerate or achieve de facto equality of persons with disabilities shall not be considered discrimination under the terms of the present Convention.

Article 28, Paragraph 2 b) - To ensure access by persons with disabilities, in particular women and girls with disabilities and older persons with disabilities, to social protection programmes and poverty reduction programmes;

Conclusions

The proposed changes to the drop-out provisions in the enhanced portion of the CPP and CPP-D have the potential to further marginalize Canadians with Disabilities. This includes those who have had to leave the workforce due to disability, those that experience potential discrimination in obtaining and maintaining employment, and those who because of disability have had to work sporadically throughout their working years.

CCD urges the Finance Committee to reconsider its acceptance of the current proposed changes to the CPP and CPP-D program.  No revisions to the CPP program, including the retirement and disability portions, should create further barriers and inequality to Canadians with disabilities. 

The government of Canada, through its commitment to the Convention on the Rights of Persons with Disabilities, has a responsibility to ensure that Canadians with Disabilities are not further impacted negatively due to life circumstances beyond their control.

All federal programs should ensure provisions for those Canadians known to be living in adverse poverty, particularly those eligible for CPP and CPP-D who would benefit from the inclusion of the drop out provisions to all portions of CPP disability or retirement pensions.

Thank you to the Committee for allowing us to bring light to these issues.

*Source of Statistics – Statistics Canada, Canadian Survey on Disability, 2012