Five ideas for the Ontario government to consider for its Employment Services Transformation planning process for Toronto

The Ontario Ministry of Labour, Immigration, Training and Skills Development (MLITSD) introduced a Request for Information (RFI) process to inform its Employment Services Transformation (EST) planning process for Toronto and northern Ontario. The RFI includes a number of questions, and the following provides Maytree’s insights and responses on five of the questions asked.

Here are five ideas for the Ontario government on how best to develop Toronto’s EST bid process so that it centres human rights, dignity, and equity.

1. Ensure that Toronto’s future Service System Manager (SSM) centres dignity and equity in service delivery. Potential SSMs should be assessed on their commitment and ability to deliver services through a human rights-based approach.

Q: For the Toronto catchment, are there particular considerations or approaches the SSM should be incorporating around neighbourhoods with high levels of unemployment that have traditionally been underserved?

To ensure that Toronto’s SSM can provide quality services to communities living in poverty and which are “traditionally underserved,” it will be important that the viability and success of the SSM are not only assessed on short-term performance measures (e.g., fiscal competitiveness and employment rates). Such short-term performance measures do not centre the service recipients. To ensure that equity and dignity is at the core of the operations of Toronto’s SSM, bids should be assessed on the ability of the SSM to deliver services through a human rights-based approach.

“Traditionally underserved communities” is often used as a euphemism for communities that have been harmed by systemic racism and discrimination. It is important to acknowledge this because historical violations of civil and political human rights have a direct impact today on who is experiencing infringements in their economic and social human rights. For example, Indigenous, Black, and other racialized groups are at greater risk of economic precarity.[1] Moreover, recent research by the Daily Bread Food Bank indicates that single individuals, people with disabilities, and individuals receiving social assistance are likely to be living in poverty.[2]

A human rights-based approach to social policy focuses on those in deepest need and works towards ensuring that everyone can realize their human right to an adequate standard of living. All governments in Canada have a role towards progressively fulfilling and protecting this right with their maximum available resources; by extension, this should also include Toronto’s SSM (whether it be a single or multi-party public, non-profit, or for-profit entity).

A rights-based assessment should be prioritized when assessing bids for Toronto’s SSM. This will help to ensure that the approaches that the SSM takes to delivering services are rooted in protecting and enhancing the dignity of service recipients. Such an assessment could include the following parameters[3]:

Principle	In practice
Accountability	Legislation, regulations, service standards, and performance indicators (e.g., client outcomes) are assessed to ensure fiscal responsibility, service quality, and contractor performance.
Participation	Individuals receiving Ontario Works and ODSP are consulted throughout the policy process (active/informed participation) and decision-making tables.
Accessibility	Services are attainable to individuals from all socioeconomic backgrounds without excessive effort and are delivered consistently regardless of background. There should be “no wrong door” to accessing support.
Transparency	Financial statements, progress reports, and data are readily available to both the public and oversight bodies at all stages of the SSM’s development (from bid to operations).
Compliance	Services are delivered in compliance with international and domestic human rights legislation and standards.
Quality of service	Services provided are of high quality; and they are of similar quality regardless of the type of service recipient (e.g., stream A, B, C).
Equity in operations and financing	Funding incentives do not persuade caseworkers to assist a certain stream of individuals more than another for financial gain (e.g., stream A and B versus C).

2. Meet people where they are. Do not assume that a “digital first” approach will be accessible for everyone requiring support, and be careful not to worsen inequities.

Q: How do you think the SSM in Toronto can best support their clients to access digital supports and be more prepared for the transition to a digitally focused economy?

The use of technology in public services is not new—the challenge is in ensuring that the use of technology, whether it be through apps on cellphones, computer programs, or service data dashboards, does not fuel inequities. This is a risk in Ontario’s plan for EST and social assistance transformation.

From a policy perspective, while considering how best to develop Toronto’s SSM process, it is important that MLITSD also consider that EST transformation is deeply integrated with social assistance transformation. In social assistance, the Ministry of Children, Community and Social Services (MCCSS) has committed to uploading the delivery of income assistance to the province. This means that the Ontario government will be responsible for both the fiscal investments required for social assistance financial benefits, and for the delivery of these benefits. However, a fully digitized approach to financial benefits delivery in social assistance may inadvertently limit the role of caseworkers in helping to determine any changes in benefit amounts.

Put in another way, if a person receiving social assistance has questions about their benefit amount, would they be able to connect with their caseworker to provide answers? Or would they have to ask through another platform? If the latter, the promise of transparency and accessibility through digitization may be undermined as people receiving social assistance will need to navigate more systems to better understand their benefits. Given the multitude of research on the role that the digitization of services and AI have in worsening discrimination and inequities, a digital first approach to social assistance and EST delivery may impede access to some of the very groups that EST transformation aims to support.

From an operations perspective, it is important to not assume that digital first approaches work for everyone. Enabling technologies (e.g., cellphones with data, computers, and high-speed internet) are very expensive and difficult to access for people with low incomes. If the Ontario government is focused on undertaking a digital first approach, it will have to ensure that it is ready to make fiscal investments that enable service recipients to access and use digital technologies.

Ideally, if the Ontario government can address the policy and operational considerations identified above, a digital first approach to service delivery in social assistance and EST would enable service recipients to access information about the supports they receive, why they receive them, and what other services are available or being scheduled for them. However, this data should not be the property of private entities. Instead, a data authority or custodial agreements should stipulate that various orders of government and departments have access to the data (so as to enable integration of services and supports), and that service recipients have the authority to decide how their data is being used in informing policy and program delivery.

3. Toronto’s SSM—whether a single entity or multi-party consortium—should be able to understand the landscape of human services across Toronto, and ensure that dynamic access to care is available as people’s circumstances change.

Q: What do you think are the key capabilities, skill sets and approaches an SSM should possess to position them to successfully achieve client outcomes in the Toronto catchment?

The human services landscape in Toronto is vast and complex. Toronto’s future SSM should be able to:

• Expertly navigate this landscape through relationships with community organizations and public services/departments at the municipal and provincial levels. Many of these relationships should already be established for a smooth transition, and the future SSM should be able to identify how it plans to bridge relationships with organizations that it is currently not connected to.
• Ensure that high-quality services are delivered with the needs of service recipients centred in program delivery. This will require fiscal capacity to provide high-quality services, and the ability to shape rules/regulations that ensure that, after accessing supports, service recipients do not face harm or worse outcomes. At its core, this means the SSM needs to deliver services through a human rights-based approach.
• Understand the role of EST services within the broader human services landscape and labour market context. Promising low fiscal investment with higher rates of employment, without considering the type of employment (e.g., jobs with health benefits), may create gains in the short term but will create more challenges in the long term.

Taken together, this means that Toronto’s SSM should work collaboratively across human services providers, and not be motivated to overtake or replace existing services. This means that the selected future SSM has the fiscal and human resources capacity to navigate many human services departments and areas and is able to support service recipients based on their level of need. For example, to ensure that people who find employment can maintain their employment, the SSM will need to work with EST, social assistance caseworkers, and other human services to ensure that people have access to supports even once they are employed (e.g., housing and childcare). This type of dynamic, high-quality service provision requires caseworkers that can work together with service recipients, without trading off service quality for the achievement of performance measures. Furthermore, MLITSD should work to ensure that all SSMs are committed to ensuring decent work conditions for their workers.

4. Increase social assistance rates. Social assistance data illustrates that single adults receiving Ontario Works and ODSP make up the majority of social assistance cases. Work activation programs through the EST will not work if other investments that people need to live a life with dignity—namely investments in income supports—are not made.

Q: Please outline if you think there are any specific groups of clients who you think face a higher risk of long-term unemployment, may require additional supports to achieve successful outcomes or are not adequately served by the Integrated Employment Service model? a. What steps do you think the ministry could take to enhance services, supports and outcomes to these groups?

EST transformation cannot be successful unless people living in deep poverty can access better benefits and services through social assistance.

Social assistance caseload data indicates that unattached working-age single adults—that is single adults without dependents or spouses—make up the largest household type accessing social assistance in Toronto. Their situation has gotten worse over the last two decades. A report from the Institute for Research and Public Policy indicates that in in the early 2000s, single adults represented just under 40 per cent of the social assistance caseload in Toronto.[4] By 2016, single adults made up more than 60 per cent of Toronto’s social assistance caseload. Single adults in Toronto are also receiving social assistance support for longer than other household types—almost half (47 per cent) of those receiving social assistance support for five years or longer are single.[5]

Social assistance rates are deeply inadequate. Single adults receiving Ontario Works can receive a maximum of $733 a month.[6] Given that about 90 per cent of single adults receiving social assistance in Toronto live in market housing, the benefit rate available through Ontario Works is deeply inadequate given the cost of living.[7] The average market rent for a bachelor unit in March 2022 in Toronto was $1,225 (167% more than the maximum Ontario Works amount) or $1,446 for a one-bedroom (197% more than the maximum Ontario Works amount).[8]

Single adults receiving social assistance are more likely to face higher risk of longer unemployment because benefit rates in social assistance are not enough to help them afford the basics needed for a stable life. To ask single adults to participate in a transformed EST service model, without raising benefit rates considerably, will not set them, nor the Ontario government, up for success. The Ontario government must prioritize benefit rate increases for single adults.

5. Align investments in human services to ensure wrap-around supports can be provided, and ensure that the regulatory environment does not undermine these investments. Simply moving towards greater competition in the delivery of EST, without parallel investments in other resources people need access to, will reduce the effectiveness of MLITSD’s goal for service transformation.

Q: For situations where a client requires simultaneous access to both employment services and other community-based supports (e.g., mental health and addictions services, housing, and homelessness etc.) and these other services are not readily available, how best do you think these clients can be supported?

The provision of enhanced, integrated, wrap-around human services is a promising idea in social assistance and EST transformation. However, the provision of better wrap-around supports, whether for people close or far from labour market attachment, depends on the way in which the Ontario government chooses to invest in them and manage other regulatory mechanisms that can support fiscal investments over the long term.

For example, EST transformation and the establishment of SSMs across Ontario may have significant fiscal implications for municipalities. In Toronto, funding for employment services is cost-shared with the provincial government. Under the current funding model, roughly two-thirds of the funding for employment services is cost-shared equally between the city and the province, while the remaining one-third is 100 per cent provincially funded.[9] The city receives about $175 million in program delivery funding from the province per year, of which over $58 million funds employment-related programs and benefits for Ontario Works clients. In 2021, the city noted that there is a risk with provincial funding related to the EST transformation process. Data from the three prototype SSM regions indicate that investments for program delivery are being reduced by 20 per cent initially.[10]

The province cannot suggest that it intends to support the development of enhanced wrap-around supports without the intention of making fiscal investments in them. Otherwise, the province risks exacerbating wait times and low service quality in human and health services, and reducing the idea of “wrap-around supports” to putting people on waitlists only. In the meantime, people in need of supports will go without, worsening the circumstances that make them in need of support.

To ensure that enhanced wrap-around supports can be provided, investments and capacity to raise revenues across all areas of government, not reduce them, are needed. For example, through Ontario’s newly introduced Bill 23, More Homes Built Faster Act, the province will be significantly eroding the ability of the city to raise revenues through development charges (DCs), the community benefits charge (CBCs), and parkland dedication. The proposed bill would remove “housing services” from the list of eligible DC services. This would significantly reduce the ability of the city to invest in shelter support for people facing homelessness and make progress against the city’s own affordable housing goals. The potential financial impact—based on the city’s initial analysis—is estimated to be $200 million per year (of which $130 million is related to the removal of the housing DC services) and an additional $30 million annually in anticipated lost DCs and parkland revenues.[11]

The Ontario government is not only impeding the city from generating fiscal revenues for housing support, but also undertaking regulatory changes that further limit the availability of affordable housing supply. For example, Bill 23 provides the Minister of Municipal Affairs and Housing with the power to intervene on rental replacement by-laws at the municipal level, and it is unclear why the province seeks to have such authority and how it will better support tenants.

Taken together, Bill 23 alone will have a significant impact on the city’s ability to provide integrated, wrap-around supports to people in need, regardless of how close or far they are from the labour market. Even people who are deemed to be “work ready” will need access to housing support (hence the call for an SSM that can provide dynamic care to service recipients, see recommendation #3). Importantly, the fiscal risks inherent in the SSM process for municipal governments paired with legislation like Bill 23 have the most acute impacts on people living in deep poverty.

The Ontario government should undertake a genuine, all-of-government approach to wrap-around supports development. Otherwise, it feels like the province is hiding behind the promise of wrap-around supports, while undertaking actions that undermine the viability of critical public services that people living in poverty need access to.

Endnotes:

[1] City of Toronto. (2021, May 17). 2019-2022 Poverty Reduction Strategy Action Plan Mid-Term

Status. Accessed at: https://www.toronto.ca/legdocs/mmis/2021/ex/bgrd/backgroundfile-166970.pdf

[2] Daily Bread Food Bank. (2022, October). Research Bulletin: A Decade of Deep Poverty

2010–2021. Accessed at: https://www.dailybread.ca/wp-content/uploads/2022/10/DB-ResearchBulletin_Report-2022.pdf

[3] Adapted from Banh, J., Ramachandran, S., Flumerfelt N., and Triadafilopoulos A. (2022, November 4) Employment Service Transformation in Ontario: Ensuring the Application of a Human

Rights Approach to Policy-Making. Final Report submitted for PPG2017: Urban Policy at the Munk School of Global Affairs and Public Policy, University of Toronto.

[4] Herd, D., Kim, Y., and Carrasco, C. (2020, September 15). Canada’s Forgotten Poor? Putting Singles Living in Deep Poverty on the Policy Radar. Accessed at: https://irpp.org/research-studies/canadas-forgotten-poor-putting-singles-living-in-deep-poverty-on-the-policy-radar/

[5] Ibid.

[6] City of Toronto. (2022). Monthly Ontario Works Amounts. Accessed at: https://www.toronto.ca/community-people/employment-social-support/employment-support/employment-seekers-in-financial-need/ontario-works-rates/

[7] Herd, D., Kim, Y., and Carrasco, C. (2020, September 15). Canada’s Forgotten Poor? Putting Singles Living in Deep Poverty on the Policy Radar. Accessed at: https://irpp.org/research-studies/canadas-forgotten-poor-putting-singles-living-in-deep-poverty-on-the-policy-radar/

[8] Author’s own calculations using City of Toronto (2022). Current City of Toronto Average Market Rents & Utility Allowances. Accessed at: https://www.toronto.ca/community-people/community-partners/social-housing-providers/affordable-housing-operators/current-city-of-toronto-average-market-rents-and-utility-allowances/

[9] Capps, M., Dannetta, L., Guzman, P., and McCloskey, L. (2022, November 4). Fiscal Analysis of Employment Services Transformation. Final Report submitted for PPG2017: Urban Policy at the Munk School of Global Affairs and Public Policy, University of Toronto.

[10] City of Toronto. (2021, April 12). Ontario’s Social Assistance and Employment Service System Transformation Plans. Accessed at: https://www.toronto.ca/legdocs/mmis/2021/ec/bgrd/backgroundfile-165743.pdf

[11] City of Toronto. (2022, November 3). FYI – Bill 23, More Homes Built Faster Act, 2022. https://www.toronto.ca/legdocs/mmis/2023/cc/bgrd/backgroundfile-230056.pdf