December 24, 2002 - British Columbia€¦ · Web viewAsset accumulation through the Registered...

March 11th, 2014

Disability White PaperPO Box 9936, Stn Prov GovVictoria, BC V8W 9R2

SENT VIA E-MAIL [email protected]

Dear Sir/Madam:

RE: Access for Sight Impaired Consumers contribution to BC’s Whitepaper Consultation

Access for Sight Impaired Consumers (ASIC) is an independent, consumer-driven advocacy coalition that addresses issues which affect legally blind, sight-impaired and deafblind consumers residing in British Columbia. Many of our member organizations are affiliated with widely recognized provincial or national bodies that serve an even greater number than the 134,000 consumers who are legally blind or have significant vision loss residing in this province. Summary

Following extensive consultation with our members and community partners, we are pleased to submit their collective thoughts and ideas that we have honed down to 15 recommendations, including accompanying details, for consideration within this process. While we have numbered our recommendations in each of seven categories, the order of these recommendations does not convey an order of priority as each recommendation carries equal weight.

In 2005, Ontario enacted the Accessibility for Ontarians with Disabilities Act with the goal to achieve full accessibility by 2025. In 2013, Manitoba followed with their Accessibility for Manitobans Act. And now, given that Saskatchewan is also undertaking a consultation process to become the best place in Canada for persons with disabilities to live, the Government of

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MEMBER ORGANIZATIONS Alliance for Equality of Blind Canadians – Lower Mainland Chapter BC Association of the Deafblind

BC Blind Sports and Recreation Association BC Guide Dog Services Canadian Council of the Blind – BC/Yukon Division CNIB – BC/Yukon Division Western Association of Persons with Vision Impairment

75 – 6600 Lucas Road, Richmond, BC V7C 4T1Telephone: (604) 241-7499 E-Mail: [email protected] Website: www.asic.bc.cx

http://www.asic.bc.cx/

mailto:[email protected]

March 11th, 2014

British Columbia must adopt a leadership role for this Disability White Paper process to succeed. We appreciate the opportunity to contribute toward helping to make British Columbia the most progressive place in Canada for people living with disabilities. Thank you for seeking our input, for your consideration of the following recommendations, and we look forward to attending the White Paper Summit scheduled for June 2014.

Innovation in disability services and more accessibility for persons living with disabilities

Recommendation 1 - Accessing vision rehabilitation under the health agenda

In 1918, thousands of Canadian soldiers were returning home blind from World War I, having lost their vision in combat. This significant number of blind veterans, coupled with the devastating effects of the Halifax explosion of 1917, created a dire need for support for people who were blind in Canada.

Necessity is the mother of invention, and a national charity was established to support an unprecedented level of need at a time when an adequate social safety net was decades away from inception. It has now been 96 years since that national charity was founded, and they continue to serve veterans, children, working-age adults and seniors who are primarily dependent on this charitable organization that relies on public donations to provide the services they do. Along the way, of course, Canada has changed too. Our country now has a robust health care and social services system that supports people with a variety of physical conditions that require care and rehabilitation. That system serves as a model for success the world over. Yet still, after almost a century, the issues related to blindness and vision loss have never been absorbed within the national continuum of care. Remarkably, they remain almost exclusively the domain of a national charity.

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If a British Columbian has a serious health problem that affects their ability to be independent and mobile – a heart attack, broken hip, spinal cord injury or stroke – our health care system provides them with the services they need to recover, rebuild and begin to restore the quality of their lives. Whether it’s through a hospital, rehabilitation facility or home care service, they receive the help they need. But when a British Columbian loses their vision, things are different. The essential rehabilitation services they need to overcome the challenges of sight loss are provided mostly by a charitable organization funded in large part by public donations. Therefore, please consider the following points when assessing access to vision rehabilitation under the health agenda:

Support high quality vision rehabilitation services into the continuum of care so that every British Columbian has universal coverage of high quality, essential service in a timely manner.

- CNIB BC-Yukon Division currently receives only 8.44% of its funding from the BC government – the lowest level of support from all provincial governments.

- Rehabilitation services for those with vision loss enable confidence and independence and increase the likelihood of employment.

- People with vision loss have a right to receive high quality, timely rehabilitation services funded by the Ministry of Health.

- Government has the responsibility to ensure that people who are blind or partially sighted have access to high quality rehabilitation services.

It is ASIC’s recommendation that high quality vision rehabilitation services be integrated into the continuum of care under the health agenda.

Recommendation 2 - Introduce a new BC Guide & Assistance Dog Act

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The current legislation fails to provide adequate access rights for guide and assistance dog users and for certified guide or assistance dog trainers. It fails to include appropriate penalties for violation of the Act, clear rules on certification and any provisions covering the injury of working dogs. Therefore, please consider the following points when assessing the introduction of a new BC Guide & Assistance Dog Act:

- The current BC Guide Animal Act is a weak piece of legislation and fails to address many of the issues relevant to guide dog handlers and/or training facilities in BC.

- The current Act does not provide any mechanisms for enforcement by a peace officer.

- Violations under the current Act can only be remedied via a complaint to the Human Rights Tribunal which is an ineffective remedy at the point when a guide dog users is being denied access to a service normally available to the general public.

- Ministry staff have no direction under the current Act as to which dogs are certifiable and therefore are obligated to issue ministry identification to any person with a bonafide disability who applies regardless of what degree of training their dog has received.

- The current Act fails to provide any protection as a result of third party injury or death of a guide or assistance dog.

It is ASIC’s recommendation that the Government of BC introduce a new BC Guide & Assistance Dog Act.

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Recommendation 3 - Implement an internet/telephone beta test to ensure the right to vote independently and privately for future provincial and municipal elections

A crucial aspect of participation in the democratic process for any citizen is the ability to cast a ballot in an election. Citizens who are blind, deafblind, or partially sighted often face unnecessary barriers when they attempt to participate in this part of the democratic process.

The rights of Canadians to vote in elections are set out in federal, provincial and territorial legislation. In addition to the right to vote, Section 164 of the Canada Elections Act requires that votes be secret. Simply having these rights, however, has not always meant that people with disabilities have been able to exercise their right to vote and to do so in secrecy. Where polling stations are not accessible, where officials lack awareness of how to accommodate voters with disabilities, and where voters who are blind, deafblind, or partially sighted must rely on third parties or the use of a tactile template to mark their ballot, the right of persons with disabilities to vote in complete secrecy has been undermined.

Election Acts at all levels provide for registered voters to appoint a designate or Election Official to assist in the marking of a ballot based on the voter’s instruction. However, the approach of having someone else mark the ballot for a person with vision loss does not respect the right to a secret ballot. Voters who are blind or partially sighted must tell someone else – possibly a total stranger – for whom they wish to vote. The voters must trust that person to mark the ballot in accordance with their wishes, to not intentionally or accidentally spoil the ballot, and to keep forever secret the voters’ choice of the candidate for whom they wished to vote. No other voters must systemically endure such significant violations of their rights.

Some jurisdictions – including British Columbia – require that a template be provided to electors who are blind, deafblind or partially sighted to assist them in marking their ballot. Unfortunately, the template does not provide a full and effective accommodation for such electors. Voters with vision loss

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cannot check to be sure their choice was correctly recorded on the ballot or that they did not accidentally spoil their ballot – not without showing the ballot to another person. If voters with vision loss show the ballot to another person, they have lost their right to a secret ballot.

Allowing individuals with vision loss to vote over the Internet or by telephone may constitute the best long-term solution to the above noted challenges presented by the traditional paper ballot. All voters could potentially benefit from the introduction of Internet/telephone voting. However, recognizing that any system would need to be properly tested and phased in over time, a beta test that extends Internet/telephone voting privileges only to those with accessibility challenges may be appropriate in the short term.

In the United Nations Convention on the Rights of Persons with Disabilities (CRPD), that the Canadian Government (with the support of all provinces and territories) ratified in March 2010, Article 29 states, in part, that parties will undertake to ensure that persons with disabilities can effectively and fully participate in political and public life on an equal basis with others, directly or through freely chosen representatives, including the right and opportunity for persons with disabilities to vote and be elected. This is to be accomplished by, amongst other things, ensuring that voting procedures, facilities and materials are appropriate, accessible and easy to understand and use, and by protecting the right of persons with disabilities to vote by secret ballot in elections and public referendums without intimidation.

In its final report to the Legislature, the Independent Panel on Internet Voting stated, “All voters could potentially benefit from the introduction of Internet voting. However, recognizing that any system would need to be properly tested and phased in over time, a pilot project that extends Internet voting privileges only to those with accessibility challenges may be appropriate in the short term.” It further states that “the panel believes that Internet voting has the potential to be an additional voting channel for voters with specific accessibility challenges in future local or provincial government elections.”

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It is ASIC’s recommendation that the Legislature instructs Elections BC to implement an internet/telephone beta test to ensure the right to vote independently and privately is afforded all British Columbians for future provincial and municipal elections.

Recommendation 4 - Supporting accessible library services

British Columbians with print disabilities have very limited access to alternate format materials (i.e. audio, large print or braille) through their public libraries. Yet, we contribute to the cost of operating these libraries through our property tax with little, if any, return. Forced to purchase a book in an audio format or having to rely on a charity to provide the same book in an alternate format is grossly unjust to those with print disabilities. Therefore please consider the following points when assessing Support for accessible library services:

- Nearly 10% of British Columbians have a print disability.- Approximately a mere 7% of printed materials are available in an

accessible format for people with print disabilities.- In comparison, sighted British Columbians have full access to publicly-

funded libraries. - The BC government is encouraged to work with the broader library

community, specifically CELA (Centre for Equitable Library Access), to ensure that accessible library services are funded by government and fully accessible, just as they are for sighted British Columbians.

- Ensure public libraries stock an adequate supply of DAISY players for patrons with print disabilities to borrow along with their audio books.

It is ASIC’s recommendation that the Government of BC supports accessible library services through the Canadian Equitable Library Access initiative.

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Recommendation 5 - Introduce regulations under the Health Professions Act requiring pharmacists to provide prescription information in alternate formats for patients with print disabilities

The proper identification and administration of prescription medications is very difficult for people with print disabilities and virtually impossible for people who are blind or partially sighted. The onus on pharmacists to provide proper patient counseling is included in the College of Pharmacists “Framework of Professional Practice” document that outlines the roles each Pharmacist must fulfill as a regulated health care provider who is a member of the College of Pharmacists of BC. The framework requires the pharmacist to verbally instruct the patient regarding the medication that is being dispensed and to provide written instructions to accompany the medication. Given the printed instructions are inaccessible to people with print disabilities, please consider the following points when assessing the Introduction of mandatory regulations under the Health Professions Act:

- Mismanagement of prescription medication leads to a large percentage of avoidable emergency room visits.

- Such ER visits places an additional strain on the health care budget.- Technology currently exists that will make prescription medication

instructions accessible in audio and large print formats.- Converting these instructions to braille format to accommodate those who

are deafblind could be coordinated through community partners.

It is ASIC’s recommendation that the Government of BC amends the Health Professions Act to include regulations that require pharmacists to provide prescription information in alternate formats for patients with print disabilities.

Recommendation 6 – Remove transportation barriers for people with vision loss

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While it is understood that people with vision loss are unable to operate a motor vehicle, their primary modes of transportation are HandyDART, public transit or vehicles for hire. Given the number of denied HandyDART bookings is increasing every year (39,000 in Metro Vancouver for 2012 and 43,000 in 2013), the accessible and affordable transportation options for people with vision loss is diminishing. When a request for a HandyDART booking is denied, the alternatives are often reduced to either public transit or taxi service – the latter is often the only choice when public transit is not time efficient or a spontaneous trip is required. However, taxis present a significant barrier for people with vision loss in that they cannot independently identify a driver, the taxi fleet identification number or the fare displayed on the meter. The lack of meters with audio output and inaccessible payment systems have all been identified as barriers that make people with vision loss vulnerable when taking taxis. Failure to regulate such requirements is seen as discriminatory in that regulations exist to ensure there are accessible taxis for people using mobility devices such as wheelchairs and scooters. Please consider the following points when assessing the need to remove transportation barriers for people with vision loss:

- Reduce a significant portion of HandyDART booking denials by funding trips to dialysis clinics by the Ministry of Health.

- Introduce regulations that would require the Passenger Transportation Board to ensure taxis are fully accessible to people with vision loss.

It is ASIC’s recommendation that the Government of BC removes transportation barriers for people with vision loss.

Personal supports and aids and devices

Recommendation 1 - Extend and expand the Equipment & Assistive Technology Initiative

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March 11th, 2014

The Equipment and Assistive Technology Initiative (EATI) has benefited a significant number of British Columbians with disabilities. This initiative enables individuals with disabilities who are looking for work to receive funding for certain devices and the training needed to use such devices. Programs that offset the usually high costs of assistive technologies exist in other provinces including Alberta, Saskatchewan, Ontario and Quebec, and the EATI program was a much anticipated program when it was introduced.

Currently, EATI is restricted to only those British Columbians with disabilities who are seeking employment opportunities. There are many other people with disabilities whose lives could be significantly enhanced through the ability to access assistive technologies that are financially out of reach. Students, seniors, low and modest income earners, and those unable to work cannot always afford the high costs of assistive technologies. Such individuals are deprived of the many benefits assistive technologies create. They are also less able to contribute to their communities in ways other than working – such as through volunteering which can lead to employable experience. The EATI program is an effective program for those fortunate enough to qualify, but a truly progressive assistive devices program would be a much more inclusive one. Therefore, please consider the following when assessing the extension and expansion of the Equipment & Assistive Technology Initiative:

- Create a sustainable and comprehensive assistive devices program that serves as the gateway to BC’s employment programs for people with disabilities.

- Insist that all government and community programs for people with disabilities operate with the vision, values and principles of the Participation Model.

- People with disabilities rely on assistive technology to accomplish many of the tasks of daily living.

- The relatively small market for assistive devices means that they are often quite expensive and not affordable to people with disabilities.

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- The Equipment and Assistive Technology Initiative (EATI) is set to expire in March 2014.

- EATI is an effective program, but it is limited to those who are looking for work. It does not support those who are contributing valuable volunteer services which often leads to employment experience and opportunities.

- Many employed people with disabilities cannot afford the assistive technologies that could enhance their independence and increase their community participation.

- The government must consider renewing and expanding the EATI program so that it meets the assistive technology needs of all British Columbians with disabilities including seniors, students and adults who are employed.

It is ASIC’s recommendation that the Government of BC extend and expand the Equipment & Assistive Technology Initiative beyond March2014.

Work and contribution

Recommendation 1 - Supporting appropriate specialized employment services

The current employment services aimed at assisting the general population do not understand, address or consider the unique needs of people with vision loss. Employment counseling for people with vision loss requires extensive experience in assessing one’s capabilities, a comprehensive knowledge of the adaptive technologies available and, most importantly, a vast knowledge of living with vision loss.

There are a number of employment programs aimed at helping British Columbians who are looking for work. ASIC often hears accounts from the blind community that these programs are not set up to meet the unique needs of people with vision loss. For example, it’s often the case that younger individuals with vision loss have not acquired the work experience

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while in high school and university that their sighted counterparts have. This might mean that finding a job requires more of a focus on pre-employment skills – such as resume writing and interviewing. Additionally, people with vision loss must deal with unique questions: When is the most appropriate time to disclose a disability? What is the best way to disclose a disability? What sorts of questions is an employer allowed to ask a job applicant about his or her disability?

The staff working in employment centres for the general public simply do not have the expertise needed to successfully assist individuals who are blind or partially sighted to find work. Therefore, please consider the following points when assessing the support for appropriate specialized employment services:

- Approximately 65 to 70% of people with vision loss are unemployed.- The high unemployment rate costs the government millions in lost

taxation revenue.- The government should invest in specialized employment programs that

are tailored to assist people with disabilities, including people with vision loss.

- Investigate feasibility of employer requirements to gainfully employ PWD’s – such a program could be fuelled by tax incentives for the employer.

- Consider waiving or subsidizing the cost of post-secondary education for PWD’s subject to three years of full-time employment in British Columbia following completion of a diploma or degree.

- PWD Income Assistance should provide better supports when transitioning to part-time/full-time employment.

- Consider an allowance (or loan) for appropriate work attire when transitioning off PWD benefits.

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It is ASIC’s recommendation that the Government of BC supports appropriate specialized employment services, particularly for those with vision loss. Employing more people with disabilities will improve their quality of life; reduce the amount of money spent on providing financial supports, and increase tax revenues. Housing and accessibility in the broader built environment

Recommendation 1 - Enact strong, effective, and enforceable provincial disability legislation through the creation of an Accessibility for British Columbians with Disabilities Act

Similar to Ontario and Manitoba, people with disabilities who reside in British Columbia would benefit from legislation that would develop, implement and enforce standards for accessibility related to goods, services, facilities, employment, accommodation and buildings. Such legislation would go a long way to ensure facilities and services offered greater accessibility for PWD’s in BC. Therefore please consider the following points when assessing the Creation and introduction of Accessibility for British Columbians with Disabilities Act: - The way the environment is designed has a tremendous impact on a

person’s mobility.- People with vision loss rely on items such as accessible pedestrian

signals, tactile walking surface indicators, braille/tactile signage, and sufficient lighting in order to travel more comfortably, safely and independently.

- BC needs provincial disability legislation to set clear standards for making all aspects of the built environment accessible to people with disabilities.

- Such legislation currently exists in Ontario and Manitoba.

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It is ASIC’s recommendation that the Government of BC enacts strong, effective, and enforceable provincial disability legislation through the creation of an Accessibility for British Columbians with Disabilities Act

Recommendation 2 - Ensure all government communications are accessible to everyone

All information and communications emanating from government ministries, crown corporations and/or their contractors must be accessible to every citizen including those with disabilities. Therefore we ask you to consider the following points:

- Ensure all information on Government web sites, including crown corporations and subsidiaries, meet standards set forth in the Web Content Accessibility Guidelines (WCAG) 2.0 level AA conformance.

- Establish an independent web site dedicated to disability programs, services and opportunities for PWD’s in British Columbia.

It is ASIC’s recommendation that the Government of BC establishes an independent web site dedicated to disability programs, services and opportunities for PWD’s in British Columbia and that all web sites managed by government, crown corporations and their contractors meet standards set forth in the Web Content Accessibility Guidelines (WCAG) 2.0 level AA conformance.

Social networks to support people in community

Recommendation 1 - Enhance social and recreational opportunities

Loss of vision often leads to shock, denial, severe depression, withdrawal, anger and isolation. Each of these emotions adds significant cost to our health care system. However, support groups, peer counseling, social interaction and recreational opportunities will help people reach that

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“turning point” and contribute greatly to a more positive outlook on what lays ahead.

Recreational activities contribute to the social aspect and encourage physical fitness, a positive attitude and enhanced self-esteem. Therefore, please consider the following points when assessing the enhancement of supports for social and recreational opportunities:

- The loss of vision can be very isolating.- Isolation can lead to depression and other mental health problems.- Promoting socialization and recreation can prevent illness and reduce

overall health care cost.- The government should actively support social and recreational programs

for people with disabilities.

It is ASIC’s recommendation that the BC government support social and recreational opportunities for people with disabilities. This can be done by adapting existing programs to make them more accessible. Community organizations like BC Blind Sports & Recreation Association work with other sports organizations to provide programs that are accessible to British Columbians with vision loss. The BC government should provide support to organizations like BC Blind Sports that ensure sporting activities are accessible. This investment in social and recreational programs will provide an excellent return on investment by increasing healthy living and reducing health care costs.

Asset accumulation through the Registered Disability Savings Plan

Recommendation 1 - Upgrade the Persons With Disabilities Benefit to $1,200 for a single person (proportional for couples) and make provision for an annual COLA increase as is the case with federal CPP disability benefits

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The Registered Disability Savings Plan (RDSP) is an excellent program for those who are eligible and who can afford to contribute to it each year. Unfortunately, given that nearly 65% to 70% of people with vision loss are unemployed, many British Columbians with vision loss rely on the Persons with Disabilities benefit (PWD) to provide them with their only source of income. With PWD providing just $906/month, after paying for such necessities as food, shelter, utilities and clothing, an individual has little left to invest for the future.

In Alberta, where the cost of living is much lower, the equivalent program provides an eligible person with a disability with $1,588 per month. It is time that the PWD benefit is increased to a more reasonable amount so that those who rely on it are not forced to live in poverty. Please consider the following points when assessing an update to the Persons With Disabilities Benefit to $1,200 for a single person (proportional for couples) and make provision for an annual COLA increase as is the case with federal CPP disability benefits:

- Many people with disabilities rely on PWD in British Columbia.- Unfortunately, increases in costs of living make it difficult to live on the

amount provided by PWD benefits.- Similar programs in Alberta provide over 50% more to individuals with

disabilities who are unable to work.- The government should undertake a full review of the PWD program and

ensure that the amount provided can allow a recipient to live with dignity in the community.

- Other aspects of PWD benefits that require review include:a) Promoting vision health by including one eye exam per year and

covering the cost of new prescription eyeglasses resulting from that examination. Also, an additional subsidy is required when the cost of frames exceeds $75 as a result of heavier lenses.

b) Medical prescriptions, medical devices, orthotics and medical therapy or chiropractic adjustments if prescribed by a medical practitioner.

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c) Maintaining dental coverage at $1,000 over a two year period for adults and $1400 for children/youth for all forms of dental care. However, including two cleanings per annum would comply with recommended dental hygiene and promote better dental care.

d) The cost of retainers and braces for children/youth whose parents are on income assistance.

e) Better supports for special dietary needs as prescribed by a medical practitioner.

The current non-exempt asset value of $5,000 per individual and the parameters within which one can add to this asset needs to be reviewed. For example, many of our members who have experienced vision loss as a result of diabetic macular edema are unable to save more than the current limit for an insulin pump - a medical device that is not covered under Pharmacare. This is but one example as to why limits and parameters need review. It is ASIC’s recommendation that the Government of BC update the Persons With Disabilities Benefit to $1,200 for a single person (proportional for couples) and make provision for an annual COLA increase as is the case with federal CPP disability benefits. Further we recommend supplementary benefits undergo a review.

General

Recommendation 1 - Share information captured on CRA’s Disability Tax Credit form (T2201) thereby eliminating the submission of redundant information on provincial program/service application forms

Recommendation 2 - Appoint a Representative for People with Disabilities

At present, advocating for people with disabilities falls to charities and advocacy organizations. A dedicated Representative for People with Disabilities’ duties and responsibilities would include monitoring complaints, evaluating services, making recommendations to government, advocating

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for all citizens of British Columbia with a disability, protecting their rights, and improving the system for their protection and support, particularly those who are most vulnerable.

It is ASIC’s recommendation that the Government of BC establishes an office for and appoints a Representative for People with Disabilities.

Recommendation 3 - Establish an independent Provincial Resource Centre

Issues facing people with disabilities are often complex, complicated and confusing for many. It is not uncommon for a PWD to contact several ministries to obtain the information or services they require. For example, the ministries of Health, Education, and Social Development and Social Innovation all have huge roles to play when it comes to delivering services to British Columbians with disabilities. Additionally, the ministries of Children and Family Development; Community, Sport, and Cultural Development; Jobs, Tourism, and Skills Training; and Transportation are all responsible for creating policies that have a significant impact on the lives of people with disabilities. Other provinces, including Saskatchewan, Manitoba, and Quebec, have addressed and simplified this difficult quagmire by establishing resource centres.

In putting forth this recommendation, we suggest the Provincial Resource Centre:

a) work in concert with the Representative for Disability Issues;b) should be a “one-stop shop” for those needing assistance with

understanding what services are available and how to access them - having a single point of contact would greatly reduce that stress and confusion that people with disabilities experience when trying to secure the services offered by various ministries.

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c) would be responsible for liaising both internally within government ministries and departments and externally with community organizations and the private sector.

d) would develop and manage information on the previously recommended independent web site dedicated to disability programs, services and opportunities for PWD’s.

It is ASIC’s recommendation that the Government of BC establishes a Provincial Resource Centre as a focal point for people with disabilities.

In closing, Access for Sight Impaired Consumers appreciates the opportunity to participate in this consultation process. While some of our recommendations address the needs of all persons with disabilities, we have also included issues that are unique to those living with vision loss. Many of our members face significant problems related to unemployment, financial insecurity, isolation, and an inaccessible built environment. While we recognize these issues are significant challenges for governments, we trust we have identified specific issues that we can work together to resolve.

Public consultation is but the first step in this journey to make British Columbia the most progressive province for people with disabilities. It will take significant leadership and commitment of the part of Government to ensure these recommendations do not fall on deaf ears. We look forward to working with the Government of BC to ensure this goal is achieved.

On behalf of the ASIC membership,R. E. (Rob) SleathChair, ASIC

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