[homeles_ot-l] Fw: fyi

[Reuel Amdur]

This is a corrected copy.  Sorry about that.


Auditing the Ontario Auditor General

by

Reuel S. Amdur

Consider this an audit of the Ontario Auditor General's 2009 Annual Report. While most of my comments will be addressed to social assistance, let's begin with a reference to remarks about Canada Mortgage and Housing Corporation's Rental and Supportive Housing Program: ". . . more than half of the units in this program would still be unaffordable for households on the waiting lists, or eligible to be on the lists." This is an important observation, reflecting the actual situation of those in need of shelter. A parallel consideration of social assistance is totally lacking.

Is the level of assistance adequate to meet basic needs of individuals and families reliant on social assistance? In constant dollars, they have less money now than under Mike Harris, a remarkable thing considering that he cut Ontario Works (OW) rates by 21.6%. It is not as if the information on the health effects is not in. For example, we have University of Toronto Professor Valerie Tarasuk's study which shows that the Ontario Nutritious Food Basket is out of reach for recipients. Ontario governments of all stripes have refused to employ nutritionists and home economists to determine real need.

The grossly inadequate assistance ($572 per month for a single person on Ontario Works and $1040 on the Ontario Disability Support Program-ODSP) may have something to do with why the special diet campaign which was of such concern to the Auditor General (AG) was undertaken. The campaign involved getting medical reports completed so that recipients could come closer to a decent standard of living. The alternative to such a campaign would be rather simple: a decent amount of money for recipients in their regular monthly allowances.

Another question that the AG might have asked is why there is such a huge difference between OW and ODSP. When I came to Ontario in 1969, the rate for a single person was almost the same for the two programs. Now the ODSP rate is almost double, and rate increases are always percentage increases, increasing the gap between OW and ODSP ever more. Is the difference a matter of prejudice against the unemployed? Only the disabled are "deserving," it appears. Yet, the stomach size does not vary from OW to ODSP.

The headlines about the AG's 2009 report were all about overpayments. Some of the overpayments were fraud, but far from all. In fact, a great many are simply normal changes in financial circumstances, for example adjustments on heating bills. Overpayments also occurred due to error, both client error and error by the ODSP and OW workers. The amounts of overpayments listed by the AG are cumulative, from 2003. If one looks at just 2008-2009, the increase in ODSP overpayments for clients who are still active is $9.2 million, which would be about $20 per case (450,000 cases). For OW, the AG notes that $140 million is the accumulative overpayment. For 202,181 cases, that amounts to $70 per case. He does not tell us how much this year's overpayment is in excess of last year's. The question remains, is the rate of overpayment, aside from the minor changes in financial circumstances that arise, in an acceptable range? 

If one looks at fraud (not simply errors) on income tax or EI, for example, the rates and amounts dwarf the overpayments on social assistance. Perhaps the AG should look at fraud on provincial income taxes, for example.

One factor causing overpayments is the complexity of the system. There are so many rules, some completely incomprehensible, that it is a challenge for staff to apply them. In 1988, the Transitions report of the Social Assistance Review Committee called for the system to be simplified. Since then, the NDP government increased complexity exponentially, followed by Mike Harris who increased it astronomically. The AG complains that reviews required by the laws and regulations are not completed in a timely manner. What do you expect? He notes an average ODSP caseload of 266, with 351 in one office. 

The complexity of the system also leads to underpayments. Unlike overpayments, underpayments expire if not caught. It would have been interesting if the AG had studied underpayments thoroughly, to compare them to overpayments. At a macro level, underpayments exist when people are kept on OW when they should be receiving ODSP.

The AG repeats the lie that OW is a program of "temporary income support." I was a supervisor in an OW office in Ottawa, and one occasionally ran across cases with histories with the department going back 20 years. Shortly before I left, I saw two with 25-year histories. Transitions recommended that anyone on for over two years should be transferred to the provincial program, with higher benefits.

AG Jim McCarter gives detail about rates of approval of applicants for ODSP, time it takes, etc. The key issue, as indicated by the fact that many cases drag on and on, on OW, and that rates of acceptance for ODSP vary widely from adjudicator to adjudicator and from Social Benefits Tribunal member to SBT member-the key issue is that the system does a very poor job of distinguishing between the disabled and those not. And the purpose of the exercise is, in any case, simply punitive.

There are three other matters that this audit of the AG report will now touch on. First, the AG notes that in the internal review, which follows on request from the applicant who has been turned down, the decision of the Disability Adjudication Unit is sent to the applicant in writing. What the AG fails to note is that the written document is a totally uninformative form letter. Boilerplate.

The report also notes that an ODSP recipient can have trust funds up to $100,000. In fact, there is no limit to the amount that a recipient can have in a Henson Trust. And finally, a word about medical reviews that are required in many ODSP cases. The AG comments on the backlog and the failure to do reviews in a timely fashion. Perhaps the issue of workload and complexity have something to do with this. 

One might well ask why ODSP staff could not do a preliminary screening for medical reviews. If the situation has clearly not improved sufficiently, why involve a doctor again? Perhaps you have heard the rumor that it is sometimes difficult to get in to see a doctor to fill out ODSP papers, especially if you do not have a family physician. Of course that also raises the question about the practice in ODSP of promoting clerks to positions of handling caseloads, without additional training. 

AG Jim McCarter, for your next report we look forward to improvement in your analysis. You can do better if you really try.


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