Changes to the HSF : Open Letter to the City Signed by 21 Organizations
Many of you have been a part of the struggle to change the discriminatory policies underlying the Housing Stabilization Fund (HSF). To-date we have written two reports (accessible here and here) documenting in detail the issues with the HSF and its management. The outrage sparked by Laura Bardeau‘s case and the subsequent mobilization led to series of changes being announced by the City in December last year. Some of these changes were implemented immediately, such as the abandoning of the discriminatory eligibility formula, whereas others, we were promised, would be designed in consultation with us and other community advocates and legal clinics.
The consultation did not happen and instead TESS merely notified us, by way of a poorly organized ‘information session’ on June 28, of the changes it had already designed and which would go into effect a mere 3 business days later (on July 4). Now a coalition of 18 organizations, OCAP included, have penned an open letter to the Mayor and members of the Community Development and Recreation Committee outlining the issues with the changes and the resolutions we are seeking. The letter appears below.
July 17, 2017
Dear Mayor John Tory and Members of the Community Development and Recreation Committee:
As you are aware, the policies governing the delivery of the Housing Stabilization Fund (HSF) have been the subject of significant community concern and even public controversy. The HSF is money that people on social assistance in Toronto rely on to meet emergency housing needs; these include, but are not limited to: fleeing domestic violence, flood or fire, getting housing following homelessness, moving to affordable housing, disability related needs and bed bugs.
People on social assistance and their advocates have clearly and repeatedly communicated the need for changes to the HSF. Toronto Employment and Social Services (TESS) acknowledged this and process was passed by your Committee and City Council. A December 12, 2016, report to City Council offered a clear undertaking to develop new policies by way of ‘a series of consultations’ with ‘clients and community agencies.’
By way of a poorly communicated outreach effort by representatives of TESS, concerned agencies and advocates were invited, at very short notice, to a June 28 “Housing Stabilization Fund Information Session.” There they were briefed on changes to the HSF policies set to take effect on July 4. This does not comply with the commitment for consultation that was made not only to community advocates, but also to City Council itself. A hastily convened gathering, where people are told what has already been decided, hardly conforms to the collaborative model of policy development that had been promised.
We must stress that this failure to provide the opportunity for community input, in violation of clear undertakings, is not just a matter of an improper process. Significant concerns and issues remain with regard to HSF policies. We are attaching an appendix that includes the changes to the HSF that were made without consultation, some of the substantial concerns that arise with these policies, and the resolutions we are seeking. Problems still exist with regard to ensuring that the Fund meets the vital needs of homeless people and those threatened with homelessness and housing insecurity that have not been addressed because of how this matter has been handled.
We are calling on you, as members of the CDRC, to intervene and ensure that HSF policies are developed in a way that ensures that community needs are actually being met. We would be simply asking you to provide space on the next CDRC agenda for deputations on the HSF but, unfortunately, the summer schedule creates a delay. Accordingly, we are asking you to meet with us as soon as possible so that we can begin to work towards a viable solution that addresses the concerns with the policies and restores a means of reasonable community input when it comes to how the HSF is delivered.
Thank you for your attention to this issue and we look forward to hearing from you as soon as possible.
Aboriginal Legal Services
Advocacy Centre for Tenants Ontario
Chinese and Southeast Asian Legal Clinic
Downsview Community Legal Services
Federation of Metro Tenants’ Associations
Health Justice Initiative
Income Security Advocacy Centre
Industrial Accidents Victims Group Ontario (IAVGO) Community Legal Clinic
Injured Worker’s Consultants Community Legal Clinic
Kensington-Bellwoods Community Legal Services
Neighbourhood Legal Services
ODSP Action Coalition
Ontario Coalition Against Poverty
Parkdale Community Legal Services
Rexdale Community Legal Clinic
South Asian Legal Clinic of Ontario
Scarborough Community Legal Services
The Dream Team
Unison Health & Community Services
West Scarborough Community Legal Services
Yogi Acharya, Ontario Coalition Against Poverty
Vic Natola, Parkdale Community Legal Services
Appendix: Changes to the HSF and Issues with Process
Below is a synopsis of the problematic changes to the HSF that went into effect on July 4, 2017 and corresponding remedies being sought.
- Coverage for children in temporary care cut by 30%:
The change: Up until July 4, children in temporary care were eligible for a maximum of $800 when applying for HSF. This amount was cut 30% to $560.
The problem: Changing this benefit unit maximum entitlement was not authorized by Council. Furthermore, a 30% cut to an already low entitlement of $800 cannot be justified.
Remedy Sought: The entitlement amount for children in temporary care should be moved back to the $800 maximum.
- Funds for replacement furniture following bed-bug infestation:
The change: The previous policy of limiting replacement furniture to beds is now amended, but not by much. Flat-rate funds of $250 for singles/couples and $300 for families are issued for “soft furniture,” (defined as furniture upholstered with fabric) in addition to funds for beds, along with funds for mattress encasements ($45 Twin, $60 Double/Queen) once every 24 months.
- Flat rates for beds out of touch with reality: The unjustifiably low prior flat-rates of $300 for twin beds and $500 for double beds remain unchanged. TESS claims that the rates were arrived at following a survey of retailers in the GTA, however, has refused to disclose details about the retailers contacted. A sample survey conducted by OCAP in November 2016 (see page 11 of our latest report) found the average twin bed priced at $420 and a double at $600.
- ‘Soft-furniture’ rates are arbitrary: No explanation has been provided as to how the soft-furniture flat rates were arrived at.
- Eligibility restricted to once/2 years: The allowable time between applications has been doubled from once every calendar year to once every 24 months. A further new restriction of needing to apply within 30 days of bed-bug treatment has been introduced.
- Align rates paid out for beds with up-to-date research that accurately reflect cost of purchasing beds in the GTA that include tax and delivery.
- There already exist maximum amounts for furniture for each benefit unit type – $800 for single/couple, $1000 for families with adult dependents and $1500 for families with children. These should be issued in cases where furniture replacements are necessary.
- Reinstate eligibility to once per calendar year up to the maximum amounts for the benefit unit. Remove the onerous requirement to apply within 30 days of treatment given people will naturally wait to check if the bugs are gone before disposing off their furniture. These changes, which are effectively cuts, were also not authorized by City Council.
- Flat rates for essential furniture and moving costs:
The change: When homeless HSF applicants request furniture funds to establish a new residence, they are granted the full furniture entitlement allowed to them under their benefit unit ($800 for singles/couples, $1000 for families with adult dependents, and $1500 for families with children). This is a welcome change and should, at least in policy, reduce the arbitrariness in decision-making that has historically plagued the issuance of furniture funds.
When it comes to moving expenses, the need to get quotes from moving companies has been eliminated, however, this comes with two caveats. First, a flat moving rate of $350 for singles/couples and $425 for families (with adult dependents or kids) has been introduced; and second, people who are establishing a residence (i.e., currently homeless) have been excluded from accessing moving expenses.
- The flat-rate moving amounts are unjustifiably low (and likely based on flawed data as outlined in our report).
- There is no reasonable basis to deny people who are establishing a residence access to moving expenses.
- Moving expenses paid must be tied to real-world costs, and if TESS contends that their flat rates match those costs, then it should reveal the research that backs up the claim. In any event, accommodations for disability-related needs that might push costs beyond a blanket ‘flat-rate’ must be put in place.
- People who are currently homeless and seeking HSF to establish a residence must be allowed access to moving expenses, as was previously the case.
Issues with process followed to implement changes in the HSF:
At its meeting on December 13, 2016, City Council adopted the following motion:
“City Council direct the General Manager, Toronto Employment and Social Services to revise the Housing Stabilization Fund eligibility policies to:
- eliminate the requirement for a separate income test to establish eligibility for the Fund;
- change the criteria for the replacement of furniture as a result of bed bug infestations to include soft furniture in addition to beds; and
- implement flat rates for the issuances of essential furniture and moving costs.”
The schedule and methodology to be used for implementing the changes endorsed above was outlined by TESS in its background report dated December 12, titled Clarifying current criteria and proposed changes to the Housing Stabilization Fund (HSF), and submitted to council as background information. In it, TESS promised to eliminate the discriminatory secondary income test for HSF eligibility as of December 15 and design and implement the changes identified in sub-points b and c by the second quarter of 2017 following “a series of consultations with stakeholders (clients, community agencies)” that will “help determine the specific needs of clients related to essential furniture and moving costs.”
While TESS followed through on its commitment to eliminate the income test, the consultations were never organized. It instead opted, in violation of its commitment to Council, to simply notify stakeholders of changes to the HSF policy. This was the case with changes to the bed-bug policy identified in sub-point b in the motion when stakeholders were sent an email on March 30 announcing changes to the policy that would come into effect on April 3. A similar process was repeated for changes to policies underlying sub-point c of the motion, whereby a poorly organized ‘information session’ notified stakeholders of changes merely 3 business days before the policies came into effect.