OASIS prepared a formal submission to the Bill 148 consultation process. To view the submission, click here.
Bill 148 arises at a point of tremendous uncertainty for the developmental services sector in Ontario. The sector is in crisis due to a lack of funding by relevant government Ministries. This crisis has been accurately reflected recently through the Developmental services system Select Committee report “Final Report: Inclusion and Opportunity: A New Path for Developmental Services in Ontario” in 2014; the Ombudsman’s Office report “Adults with Developmental Disabilities in Crisis” in 2016; and, unfortunately through two well publicized Coroner’s Reports. Bill 148, although laudable in its efforts to enhance working conditions, will significantly increase operational costs in the sector.
The Ministry of Community and Social Services has confirmed those increased costs for the developmental services sector will be unfunded.
This submission represents a comprehensive response to Bill 148 with particular consideration given to its impact on those individuals served by the developmental services sector. OASIS is a provincial association made up of over 195 member agencies that support people with developmental disabilities to live in communities across Ontario. Our mission is to advance the interests of the people the sector supports and the people it employs through a wide range of educational and professional programs, promotion of ethical best practices, and compliance with applicable employment laws and regulations. An essential part of the mission is to advocate for appropriate regulation of the industry and the efficient and effective enforcement of such regulations.
OASIS supports, in principle, the objectives that the Government identified in undertaking the Changing Workplaces Review and that underlie Bill 148. The developmental services sector has been underfunded for many years, resulting in lower than average pay and benefits. However, OASIS is concerned about provisions in Bill 148 in the context of the developmental services sector, its funding realities, the nature of its operations and in respect of the impact on client service to those with developmental disabilities.
Our member organizations support approximately 65,000 of Ontario’s most vulnerable citizens, while employing over 25,000 full and part-time staff. Based on input from those organizations, it is clear that without additional funding from the relevant Ministries, and primarily the Ministry of Community and Social Services, those employed in the sector and those served by the sector, will experience a loss if Bill 148 is passed without amendment. For the individuals employed in the sector, they will experience a loss in jobs and/ or a reduction in hours of work; for the individuals supported by the developmental services sector, they will experience a decline or possible elimination of the support available, and correspondingly, an impact on their standard of living.
Accordingly, absent a commitment by the relevant Ministries to fund the increased costs to the sector, OASIS cannot support Bill 148 as drafted. In the areas described below, OASIS asks the Government to reconsider the amendments proposed by Bill 148 or provide an exemption to the developmental services sector.