Ontario Disability Support Program/
Social Benefits Tribunal
The Community and Neighbourhood Services Committee recommends the adoption of the following report (May
28, 1998) from the Commissioner of Community and Neighbourhood Services:
Purpose:
The purpose of this report is to provide an overview of the new Ontario Disability Support Program regulations, which took
effect June 1, 1998. This report highlights the key changes contained in the new regulations, and provides an initial
overview and impression of the cumulative impacts for Toronto. The recently released regulations governing the new
Appeal system proposed for Ontario Works and the Ontario Disability Support Program are also assessed.
Financial Implications:
The net financial impact of the new regulations will require further analysis and is therefore not known at this time.
Recommendations:
It is recommended that:
(1) this report be forwarded to the Minister of Community and Social Services; and
(2) the appropriate City officials be authorized and directed to take the necessary action to give effect thereto.
Background:
In June 1997, the Social Assistance Reform Act (S.A.R.A.) was tabled in the legislature by the Minister of Community and
Social Services (M.C.S.S.). S.A.R.A. created two new statutes: the Ontario Works Act (O.W.A.), which replaces the
General Welfare Assistance Act (G.W.A.), and the Ontario Disability Support Program Act (O.D.S.P.A.), which replaces
the Family Benefits Act (F.B.A.), and the Vocational Rehabilitation Services (V.R.S.) Act.
Through the O.D.S.P.A., the Province set out to create a new program solely for persons with disabilities, moving them
outside the conventional "welfare" system. The stated intent is to "take people with disabilities off welfare" and "to support
them towards the goals of independence and employment".
In July 1997, the Community Services Department reported to the former Metropolitan Council on the details of S.A.R.A.
(Clause No. 2 of Report No. 10 of The Human Services Committee). Based on the information available at the time, the
report assessed the impacts of the new legislative framework. At that time, the Department indicated it strongly supported
the Provincial direction with respect to the creation of the Ontario Disability Support Program, and commended the
Province for recognizing the inappropriateness of placing persons with disabilities in the existing social assistance system.
The O.D.S.P.A. was proclaimed on June 1, 1998. Information about the new program was provided to municipal officials
in a mid-May briefing session. However, the regulations were not available in final form until the end of May, with the
result that the Department is currently in the process of undertaking an in-depth analysis of the impacts for clients and for
program delivery. The information contained herein is drawn primarily from the Provincial briefing materials and
summaries, and from an initial review of the regulations.
This report describes the key features of the new program, and briefly discusses the implications for applicants and clients.
The report also assesses the program delivery impacts on the Social Services Division of the changes contained in the new
regulations.
On June 1, 1998, the new social assistance appeal system also took effect. At this time, the Social Benefits Tribunal
replaces the existing Social Assistance Review Board. Again, the regulations governing the appeals process have only
recently been made available. This report describes the main features of the new process, and a provides a preliminary
assessment of impacts.
Discussion:
(I) Ontario Disability Support Program Act: Key Features:
The O.D.S.P.A. replaces the former F.B.A. Passed in 1967, F.B.A. provided benefits on a long term basis to a range of
eligible clients, including single parents, blind, disabled or permanently unemployable person, foster child(ren) and persons
60 years and over. The special needs of F.B.A. recipients were met by granting Supplementary Aid through the G.W.A.
delivery system.
For some time, the disabled community and others have voiced their concerns about providing benefits to people with
disabilities and serious long term health problems through the "welfare" system. O.D.S.P. addresses these concerns by
establishing a separate program targeted at people with disabilities and people over 65 years of age. Of significant
importance is the fact that the new program recognizes that many people with disabilities can and do wish to work.
The new program has two primary functions: to provide income support to disabled people who are in financial need; and
to provide employment supports to clients who want to work. The new Income Support program provides financial
assistance to those who qualify, introduces new eligibility criteria and new approaches to the treatment of assets, income
and special needs, and establishes a centralized process for adjudicating disability. The Employment Supports program
replaces the V.R.S. Act, and provides services to support people with disabilities as they move towards employment. The
Province will continue to deliver the program. However, the City is required to cost-share Provincial staffing costs on a
50/50 percent basis as part of the downloading of responsibilities to municipalities.
The O.D.S.P. is substantially changed from the former F.B.A. and V.R.S. programs, and in many instances is significantly
improved. Having undertaken a preliminary review of the O.D.S.P. regulations, the Department reiterates its support for the
Province's approach to serving disabled people. The following section highlights the key features of the new program.
Appendix A provides an overview of the major changes made under the O.D.S.P. regulations, and the impacts on clients.
Program Purpose and Objectives:
The O.D.S.P.A. contains a clear statement of purpose for the program which emphasizes the importance of providing both
income and employment supports to disabled individuals. A number of equally clear objectives have been articulated for
the program, to ensure that it now provides:
(1) clear and understandable new criteria for eligibility based on recognizing restrictions in the activities of daily living in
the home, in the community and in the workplace, supported by a new process for assessing whether a person qualifies;
(2) greater opportunities for independence by recognizing costs more fully within the program's policies regarding assets,
income, and gifts and loans; and
(3) additional emphasis on assisting people towards employment with practical employment supports that range from
employment planning assistance and skills development, through technological aids and devices, to interpreters and
ongoing job supports.
The Department supports these objectives and believes that they are largely accomplished through the regulations
governing the program.
Eligibility for O.D.S.P.:
A person is eligible for O.D.S.P. who is 18 years of age or older, has a disability that substantially restricts activities of
daily living, and is in financial need. Persons aged 65 years and older, who are not eligible to receive Old Age Security
(O.A.S.), are also eligible. For the first time, persons in receipt of Canada Pension Plan Disability benefits are eligible if
they meet the financial needs criteria. Previously, under F.B.A., such individuals had to undergo a separate medical exam
to qualify.
A positive feature of O.D.S.P. is that persons aged 60-64 who qualified for F.B.A. before January 1, 1998, will continue to
be eligible for O.D.S.P., as will permanently unemployable and disabled recipients eligible before May 1, 1998. The
Department strongly supports this provision. Current benefit levels, which compare favourably with levels provided to
disabled people in other provinces, are retained for all program beneficiaries.
Employment Supports:
Through a new Employment Supports program, the O.D.S.P. provides a range of services to people with disabilities who
can and want to work. These services will be provided to any person for whom a disability presents a substantial barrier to
employment, whether or not they are receiving income assistance under the O.D.S.P. Prescribed employment supports
include employment consultation and planning, employment preparation and training, job placement services, as well as
provision for the costs of various tools, equipment or aids necessary to secure and sustain employment. The Province has
indicated that the budget for the wider range of supports provided has been increased to about $35 million per annum,
versus $18 million under the former V.R.S.
Unlike F.B.A., persons who reapply for benefits within one year following an unsuccessful employment experience will be
rapidly reinstated without retesting, provided they qualify financially for the program. This is a positive step. Overall, the
new program increases incentives for, and expands services to, people who want, and are able, to work.
Definition of Disability:
The O.D.S.P. establishes a new definition of disability which refers to "substantial restrictions in one or more activities of
daily living such as personal care, functioning in the community, and the workplace." The disability, which may result
from mental or physical impairment, has to be major, continuous, or recurrent in nature, and must last for one year or
longer. This is a much more focused definition than was used under F.B.A. It consciously avoids labelling people
unemployable, a feature of the previous disability test that was considered unproductive by the disabled, and by advocates
and organizations working with the disabled community.
At the same time, people previously considered permanently unemployable who were eligible for Family Benefits,
including non-disabled people who had a serious employment barrier (e.g., drug or alcohol problem), will no longer be
considered disabled, and will not be eligible for O.D.S.P. These individuals must now apply for social assistance benefits
through Ontario Works (Appendix B highlights the implications of this change for singles and families). As the
Department has previously indicated, single parents and new applicants aged 60-64, who previously could receive F.B.A.,
will now only be eligible to receive social assistance through O.W.
The Department anticipates that the outcome of these changes will be a sizable decrease in the number of people who will
be eligible under O.D.S.P.A. compared with F.B.A. The degree that the new definition of disabled and the actual disability
test restrict eligibility will depend on the actual operation of the new disability adjudication process. The Department is
concerned that the impact of this change will be to increase the number of hard to serve clients receiving O.W. The
potential impacts for the Social Services Division will be delineated in section (II).
Disability Adjudication Process:
The program introduces a new standardized and comprehensive disability test, and clear criteria for retesting, which should
result in greater consistency in the assessment process across the Province. The newly formed Disability Adjudication Unit
will make decisions verifying that a person is disabled. The Unit will include a broader range of expertise than was
previously the case under F.B.A., and include Occupational Therapists, Nurse Practitioners and Physiotherapists, as well as
Physicians, Psychologists and Optometrists.
Once a disability determination has been made, clients will only be retested if and when the disability is expected to
improve. Persons with no expectation of improvement in their disability will not be retested. Under F.B.A., all clients were
required to undergo regular medical exams on an ongoing basis to qualify for benefits.
Treatment of Assets and Income:
The program contains revised financial rules (notably higher asset limits) than the former F.B.A. program, plus a range of
other changes which will allow people to access and retain income from specific sources. Clients with disabilities will be
able to keep more of their assets to cover the costs associated with a disability. Specific details regarding these changes are
contained in Appendix A. Overall, the impact of these changes is to increase the resources available to disabled persons and
their families to support a higher quality of life, and to expand their potential to seek employment if they wish to.
(II) Program Delivery Impacts:
The O.D.S.P. will have a number of impacts on the Social Services Division, and for the social services delivery system in
Toronto. As indicated previously, the new regulations have been received only recently. Consequently, this assessment is
based on an initial review of the regulations.
O.D.S.P. Service Delivery Model:
A key impact for Toronto's social services delivery system relates to the Province's decision to use Ontario Works as the
entry point for the majority of clients applying for O.D.S.P. While the Province initially indicated O.D.S.P. and Ontario
Works would operate independently, the relationship between the programs is in many ways similar to that which existed
between G.W.A. and F.B.A. In essence, there has been minimum disentanglement of the municipal and provincial delivery
systems.
Thus, any client in immediate financial need will be expected to apply for financial assistance through Ontario Works while
a decision is being made regarding eligibility for O.D.S.P. The Province estimates that over 80 percent of all applications to
O.D.S.P. will be made through Ontario Works. In most instances, cases can be expected to remain on O.W. for at least four
months before a determination of eligibility is made. It is also very likely that O.W. staff will be required to assist clients
prepare the information and materials necessary to make a disability claim.
The Department has two overall concerns. First, the application process for disabled clients needs to be further streamlined.
The application process will be discussed in greater detail below. Second, there will clearly be staff resource and
operational implications for the Social Services Division related to serving O.D.S.P. applicants.
O.D.S.P. Application Process:
As indicated, disabled clients in immediate financial need will apply for O.D.S.P. through the Ontario Works program. The
application process has a number of features:
(1) anyone who believes he/she has a disability has the right to apply for O.D.S.P.;
(2) financial eligibility for O.W. must be established immediately for all clients who apply for O.D.S.P. through the O.W.
program;
(3) applicants for O.D.S.P. who are receiving O.W. financial assistance will have participation requirements deferred
without medical documentation once in their lifetime;
(4) applicants who request immediate financial assistance through O.W. can use the substantially higher O.D.S.P. asset
levels once in their lifetime to establish financial eligibility for O.W. pending resolution of their eligibility assessment
under O.D.S.P.;
(5) in most circumstances, applicants must now request an application for disability determination directly from the
O.D.S.P. office, which will then be forwarded to them for completion;
(6) applicants have 90 days to complete the forms necessary for the determination of disability by the Provincial Disability
Assessment Unit, after which an application may be withdrawn; and
(7) when it is determined that an applicant has a disability and is eligible for O.D.S.P., financial eligibility must be
re-confirmed by the O.D.S.P. office.
The Department has a number of concerns related to potential impacts on clients of the new applications process. Formerly,
potentially eligible clients were required to apply to F.B.A. as part of the O.W. requirement to pursue all available sources
of income. This requirement no longer exists under O.D.S.P. In addition, Social Services Division staff will no longer be
able to make direct client referrals to the O.D.S.P. for clients who refuse to seek the medical attention necessary to
complete the disability determination process, as was occasionally the case under the F.B.A. program. These changes
restrict an O.W. caseworker's ability to assist disabled clients who may be eligible for O.D.S.P. and whose needs could best
be met through the program, but who do not, or cannot, initiate applications, possibly because of their disability.
The Division also recommends that the Province establish specific protocols for applications from vulnerable clients, such
as homeless persons, which waive the 90 day application limit, and which does not penalize such clients if an initial
application is not completed.
Hard to Serve Clients on O.W.:
As noted previously, people who no longer qualify for O.D.S.P. because of changes in the definition of disability, but who
still require financial assistance, will apply for benefits under the Ontario Works program. Many of these individuals may
not be employable because they have multiple barriers or health problems. Even with additional resources, it is not realistic
to assume that these individuals will be able, or should be expected, to participate in mandatory O.W. activities such as
Community Participation placements.
Therefore, the Department reiterates the request made in July 1997 that the Province ensure participation requirements can
be permanently deferred for people who clearly will not be able to take part in these activities.
Dependent Adults:
In families where the family head is disabled and in receipt of O.D.S.P., adult family members over the age of 18 who are
financially dependent as defined in the O.D.S.P. regulations are subject to O.W. participation requirements. It is the
responsibility of the local O.W. site to ensure that dependent adults establish service plans, meet the objectives set out
therein, and comply with OW participation requirements.
At this time, the number of adult dependents in receipt of benefits under the former Family Benefits program who will have
mandatory participation requirements is not known. Nor is it possible to estimate how many new applications for O.D.S.P.
will be made by families in which a dependent adult resides. However, any increase in O.W. participants resulting from this
policy will have implications for the Division, potentially affecting budgets, staffing and physical space requirements. Until
further information about the potential number of adult dependents with O.W. requirements is available, the Division is
unable to provide any reasonable estimate of possible impacts.
During the implementation of O.D.S.P. over the remainder of 1998, the Social Services Division will be required to
develop a plan with the Toronto Area O.D.S.P. offices to administer this component of the O.D.S.P./O.W. interface. More
information and clarity about the number of clients involved is one issue that will need to be investigated with Provincial
staff during the implementation of the new program.
Implementation Issues:
In certain cases, the detailed information necessary to begin to implement changes, and to administer the new functions
required at the O.W. office, have not yet been conveyed to municipal delivery sites. The Department is working with
Ministry officials to ensure that the new processes for referring clients with disabilities to the O.D.S.P. program are put in
place with minimum disruption to clients wherever possible. In fact, it is imperative that Ministry and Social Services
Division staff collaborate effectively over the next year to achieve this objective, not only with the introduction of O.D.S.P.
but with the ongoing implementation of O.W.
The Division also recognizes that it will be necessary to explore effective ways, with the assistance of key community
agencies, of helping disabled people apply for O.D.S.P. Given the scope of the new Provincial package that must be
completed as part of the new disability determination process, clients will likely require support from appropriate
community organizations, including community health clinics and agencies providing services to disabled persons. The
Division is concerned that if these community supports are not developed, certain disabled applicants, particularly the most
vulnerable clients, will not be able to fulfil the requirements of the new process.
Finally, the Department continues to be concerned about the speed with which changes are being made, and the lack of lead
time to review the implications of new regulations before they take effect. It has become increasingly difficult to
adequately inform and train staff, and inform clients and the community, about the wide range of changes occurring.
Substantial efforts will be required to prevent deterioration of service and to preserve program integrity during the
implementation period, and to ensure to the degree possible that the O.W. and O.D.S.P. regulations, and the new appeals
process can be introduced with minimum disruption to service delivery.
(II) New Appeals Processes:
As of June 1, 1998, the new appeal processes mandated within the O.W.A. and O.D.S.P.A. take effect. The Province has
indicated its intention is to streamline the process and make it more efficient. As part of the change, the Social Benefits
Tribunal (S.B.T.) becomes operational. All new appeals, with few exceptions, will be forwarded to the S.B.T., while the
existing Social Assistance Review Board is phased out. The basic features of the new appeals system are described below:
(1) all O.W. delivery sites must develop an internal review system which meets specific criteria laid out in legislation and
regulation (e.g., specific time frames and procedures for conducting all internal reviews). The purpose of the internal
review process is to ensure that all efforts are made at the local level to resolve issues before they are referred to the
Provincial appeals system;
(2) all appeals must be processed through the internal review system before they can proceed to be the Social Benefits
Tribunal, which replaces the Social Assistance Review Board as the final decision-maker within the social assistance
appeals system; and
(3) the mandate and scope of the S.B.T. is more focused compared to S.A.R.B.'s. A number of matters are no longer
appealable, as set out in legislation. The Tribunal will also employ a new case management approach to the hearing
process.
The Department supports the requirement to develop an internal appeals system, and believes that embedding this
requirement in legislation, and providing clear parameters for the review process, will improve the quality and consistency
of decision making.
The Social Services Division has for some time utilized an internal review process, and intends to build on this process to
meet the new legislative and regulatory requirements. At this time, the Division is assessing what changes are required to
bring internal appeals process into compliance. For the most part, only minor modifications will be necessary. However,
given the fact that the new regulations governing the appeals process have only recently become available, significant
efforts and staff resources will be required to rapidly make the needed changes, and to inform staff, and clients, about how
the process will work.
Transition to the Social Benefits Tribunal S.B.T.:
The Province has recently indicated in a Bulletin from the S.B.T. that the transition to the new appeal system will be
gradual. According to the M.C.S.S., the two review boards will continue to operate for some time. Effective June 1, 1998,
all decisions regarding an individual's entitlement for O.W. or O.D.S.P. must be appealed to the Tribunal, and will be dealt
with under the new O.W.A. and O.D.S.P.A. However, S.A.R.B. will continue to hear all appeals filed before June 1, 1998.
In these cases, the appeals will be dealt with according to the former G.W.A. Act and the Family Benefits Act as
appropriate. As well, S.A.R.B. will continue to be the board of review for all decisions made regarding the ongoing
eligibility of sole support parents and foster parents under F.B.A.
The Division anticipates that the overlap between the two systems will be administratively complex to manage, demand
additional staff resources, and be confusing to both clients and staff. It is possible that a client could have appeals
simultaneously before both S.A.R.B. and the Tribunal. It is, therefore, critical that the Province provide municipalities with
the necessary information to clearly understand how the new S.B.T. will operate, and allow sufficient time for this
information to be absorbed and communicated to staff and clients.
Conclusion:
The Department believes the new O.D.S.P. represents a positive step in assisting eligible disabled people in Ontario. The
inclusion of enriched employment supports and the favourable changes made to the treatment of assets and income will
clearly benefit program recipients. A number of important operational and program administration issues must still be
worked out before the new program can be effectively implemented. The Social Services Division has had limited time to
review and analyse all of the information recently released by the Province related to the new program. Consequently, the
Division will continue to assess the impacts of the new regulations and further Provincial directions, and report back to
Council as appropriate.
Overall, the Division supports the approach adopted by the Province in developing a new appeals system, including the
emphasis on an internal appeals process governed by clear parameters and criteria. It is anticipated that the changes will
improve the quality of decision-making. At this point, additional information is required to more precisely determine the
program administration impacts of the new appeals system on the Division.
Contact Name:
Heather MacVicar
392-8953
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Appendix A
Summary of Ontario Disability Support Program Regulations
| Change |
Impact |
(1) Definition of Disability:
Substantial restrictions in one or more of the activities of
daily living, resulting from a major continuous or recurrent
physical or mental impairment which is expected to last one
year or more. |
More restrictive definition than under F.B.A.. Category of
Permanently Unemployable eliminated. |
(2) Dependent Adult/Child:
Dependent adult is defined as one who is 18 years of age or
older and financially dependent. Family members under 18
are considered to be a dependent child. Dependent adults
who are part of an O.D.S.P. benefit unit are required to
participate in the O.W. program. |
Monitoring and administration of dependent adult
compliance with O.W. requirements. Potential impact on
staffing and physical space.
Clarification required regarding deductions for
non-compliance and responsibility for completing an
internal review/appeal if filed. |
(3) Reinstatement:
O.D.S.P. clients are not required to undergo retesting for
disability status if they are in financial need, if they reapply
within one year. |
Eliminates retesting of people with disabilities. |
(4) Allowable Assets:
Allowable asset level increased to $5,000.00 from $3000.00
under F.B.A. for singles.
O.D.S.P. clients can retain all interest earned on liquid assets
such as Canada Savings Bonds.
O.D.S.P. asset levels apply to O.W. clients applying for
O.S.D.P. |
Higher allowable asset level. |
(5) Trust Funds and Inheritances:
Maximum amount that can be retained increased from
$65,000.00 to $100,000.00. Interest is deductible once the
trust is in excess of $100,000.00 if it is not required for
disability related exemptions. |
Higher allowable asset level. |
(6) Cash Surrender Value of Life Insurance Policy:
O.D.S.P. clients can keep a policy with a cash surrender
value up to $100,000.00 in combination with trust funds. |
Higher allowable asset level |
(7) Compensation Awards:
Clients can retain capital up to $100,000.00 (increased from
$25,000.00), however, interest earned is deductible. |
Higher allowable asset level. |
(8) Motor Vehicle:
No limit on value of primary vehicle.
A second vehicle up to a net value of $15,000.00 is allowed
if required by spouse or dependent to
maintain employment. |
Increased client mobility, independence and potential
employment opportunities. |
(9) Second Properties:
A lien is placed on second properties after six months. The
second property may be exempt as an asset if it is for the
health and well being of the client. |
Improved quality of life. |
(10) Self-employment and Business Assets:
Maximum allowable business assets increased from
$10,000.00 to $20,000.00 plus the tools of the trade. |
May increase potential for self-employment. |
(11) Earnings Exemptions:
Increase in earnings exemptions for families from
$185.00 to $235.00. The exemption applies immediately
under O.D.S.P.. |
Employment incentive, increased family income. |
(12) Assistance from Family and Friends:
Assistance from family and friends up to a maximum of
$4,000.00 in a 12-month period is exempt as income. |
Provision of additional supports. |
(13) Loans:
Loans used for an approved purpose such as disability
related items or business expenses are exempt. |
Ability to obtain disability-related items that are not
otherwise available. |
(14) Dental Benefits:
O.D.S.P. clients over 60 years of age are now eligible for
basic dental care (the same as other O.D.S.P. clients). |
Eliminates discrepancy in eligibility for dental benefits. |
(15) Assistive Devices Program:
The Ministry of Health will pay 100 percent of allowable
costs. |
Reduction in cost to Municipality as 25 percent of cost was
previously paid by Municipality. |
(16) Special Diet:
Maximum allowance capped to $250.00 per month. |
Potential reduction in benefit to clients with requirements
exceeding $250.00. |
(17) Initial Benefit Payment:
Financial assistance will be pro-rated from the date all
information is received and the first payment will be made
during the month eligibility is determined. |
Elimination of "waiting period". |
(18) Employment Supports:
Replaces Vocational Rehabilitation Services.
Provision to provide funds directly to clients. |
Increased employment funds available. |
(19) Assistance for Children with Severe Disabilities:
Replaces "Children's Handicapped Benefit". No change to
benefit or how they are administered. |
No Impact. |
|
|
Appendix B: Case Examples
(I) Changes to Definition of Disability: Permanently Unemployable Clients versus Disabled Clients:
(1) Single Person:
|
Permanently Unemployable 1 |
Disabled |
| Program Eligibility |
O.W. |
O.D.S.P. |
| Entitlement Amount |
$520.00 |
$930.00 |
| Asset levels |
$520.00 |
$5,000.00 |
| Mandatory Requirements |
Participation in approved O.W.
activities. Participation will be restricted
or deferred if medical reasons
confirmed. |
None |
| Program Supports |
Supports limited to assisting client find
shortest route to employment. |
Wide range of program supports
available to client on voluntary basis to
find and sustain employment. |
(2) Family: Two Parents plus Dependent Adult:
|
Permanently Unemployable 1 |
Disabled |
| Program Eligibility |
O.W. |
O.D.S.P. |
| Entitlement Amount |
$1,066.00 |
$1,628.00 |
| Asset levels |
$1,40.00 |
$8,000.00 |
| Mandatory Requirements |
Participation of all family members in
approved O.W. activities. Participation
will be restricted or deferred if medical
reasons confirmed. |
Participation of dependent adult2 in
approved O.W. activities. |
| Program Supports |
Supports limited to assisting client find
shortest route to employment. |
Wide range of program supports
available to client on voluntary basis to
find and sustain employment. |
1 Previously eligible under F.B.A. Permanently unemployable category eliminated under new definition of disability.
2 Responsibility for providing service and monitoring participation requirements of dependent adults resides with
Municipal O.W. delivery agents. These families will be required to interact with both O.W. and O.D.S.P. programs.
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The Community and Neighbourhood Services Committee reports, for the information of Council, having received an
overhead presentation on the Ontario Disability Support Program by Ms. Heather MacVicar, General Manager, Social
Services Division, Community and Neighbourhood Services Department.
(A copy of the aforementioned presentation was forwarded to all Members of Council and a copy thereof is on file in the
office of the City Clerk.)
