OANHSS Submission to the Standing Committee on Justice and Social Policy on Bill 128 - the 
Social Housing Reform Act

November 2000

Return to Position Papers

For over 80 years, the Ontario Association of Non Profit Homes and Services for Seniors has represented not-for-profit organizations across Ontario that are dedicated to meeting the housing and long term care needs of seniors. Member operations span the full spectrum of the non-profit long term care system including seniors housing, facilities, and community services.

More than 70 member organizations are involved in the ownership and management of non-profit housing for seniors in communities across Ontario. These include projects previously administered by the federal and provincial governments, some of which receive supportive housing and/or community service funding from the provincial government to deliver services.

OANHSS is pleased to have the opportunity to present the views of not-for-profit organizations across the province that serve seniors to the Standing Committee on Justice and Social Policy.

The Social Housing Reform Act is designed to facilitate the implementation of the policy decision that was previously made by the government of Ontario to download the responsibility for social housing to the municipal level. This presentation reflects and summarizes the position of OANHSS members on a number of specific program details in the draft legislation. However, we must begin with general comments on the policy direction underlying the legislation.

There is a continuing need for new affordable housing for a range of populations.

However, there is a fundamental reality that is at the root of the provisions of this legislation. The cost of providing decent rental housing anywhere in Ontario is far in excess of the rents paid in the market place for that housing. Further, the cost is beyond what is affordable for many people living on fixed incomes - including many seniors.

Ensuring that decent affordable housing is available for every household in Ontario is a difficult and costly challenge. It requires the commitment and contributions of all parts of the community, including locally based not-for-profit organizations such as OANHSS members. And it most definitely requires the ongoing commitment of all levels of government.

Ontario’s municipalities, with their limited tax base, will be hard pressed to meet the existing financial demands of the housing that will be transferred to them by this legislation. Moreover, other needs such as solutions to homelessness, housing for people living in substandard conditions, and for the rapidly increasing population of seniors will continue to be unmet without significant contributions from both the federal and provincial governments.

The Minister, in announcing this legislation, spoke of the advantages of housing programs being administered by local communities, which can be more responsive to local needs.

In fact, the responsibility for managing and owning most of the social housing in Ontario has always been in the hands of community-based not-for-profit organizations. Non-profit housing is made possible by large numbers of committed volunteers from a range of different communities, including ethnic, cultural and religious groups. OANHSS members agree that local communities can be more responsive and believe it is important that this legislation continues to support local delivery. At the same time, it is also critical that all three levels of government continue to financially support local groups in their delivery of not-for-profit housing.

iii) Potential for Cost Savings

Under Local Services Realignment, the provincial government transferred responsibility for funding in some areas to the municipal level and assumed funding responsibility in other areas. The intent was to maintain a balance of funding responsibility between the different government levels. Funding for social housing is now a municipal responsibility.

Over time, it is expected that the cost of subsidizing existing social housing will decrease as inflationary increases in rents exceed the increases in costs due to fixed mortgage payments.

If these projections are correct and, in the long term, there are savings in the cost of maintaining social housing, OANHSS believes that those savings must be reinvested in new housing or in enhancements to existing housing.

The province and the federal government have traditionally provided significant financial support to bridge the sizeable gap between social housing costs and affordable rents. They have, quite rightly, established standards and guidelines for the operation of the housing, based on that financial contribution. It is appropriate that, as municipalities assume financial responsibility, they also put in place standards and guidelines that will govern how their contribution can be used. At the same time it is important that the new guidelines respect the contributions of the community-based organizations that own the housing and permit them to operate the housing in a business-like manner.

The program changes taking place as social housing is transferred to the municipal level are possible because the legislation terminates the existing operating agreements for all provincially funded non-profit housing. This suspends all of the rules and protections that were included in those agreements. The legislation sets out standards that municipalities must adhere to, which replace some of the protections and requirements that were in the operating agreements.

In some key areas municipal service managers will be able to develop additional rules and requirements in areas that are left to municipal discretion by the legislation. For example, municipalities may establish additional eligibility requirements for geared-to-income housing, additional priorities for waiting list access, and additional reporting requirements.

There are a number of standards set out in the draft legislation that OANHSS members support, including:

• guarantee that the mandates of housing providers will be respected,
• that their ability to provide geared-to-income assistance to a specific number of households will continue,
• that their ability to provide housing to people with disabilities will continue at the same level, and
• that these standards can be amended only with mutual agreement.

The following outlines concerns and recommendations related to specific program details in the draft legislation.

The new funding model for non-profit housing is intended to enhance the predictability of funding, and give providers more autonomy and streamlined accountability. Our major concerns about the funding model relate to the adequacy of reserves for future capital replacements and the new benchmarking process.

As the buildings age, housing providers will not have enough money in their reserves to meet the need for major capital repairs. Municipal governments will not have the resources to deal with the capital requirements of all the social housing that they administer.

Subsidies in the new funding model will be based on revenue and expenditure benchmarks established initially by the province and on an ongoing basis by a province-wide body controlled by municipalities.

Given the years of funding constraint that have been experienced by all social housing providers, the benchmarking process must not be used to further reduce the funding available to manage social housing.

Under the draft legislation, municipalities must establish a co-ordinated access system for all social housing in the community using a single waiting list.

A separate co-ordinated access system will be established for housing for people with special needs who require support to maintain independent housing. OANHSS members are concerned that such a system must respect the mandate of housing providers and take into consideration a number of factors, including:

• the range of levels and types of supports needed
• the ability of housing providers to make support available
• the need to co-ordinate all housing for people with special needs including that which continues to be administered by the province through the Ministry of Health and Long- Term Care and the Ministry of Community and Social Services
• the ability of the municipality to make informed judgements about the needs of people with special needs

Some OANHSS members have expressed considerable frustration with existing co-ordinated access systems. They are questioning whether in fact co-ordinated access can effectively improve access to social housing.

Municipal Administration will be carried out by 47 service managers, each of whom will be responsible for making decisions in areas of local discretion, including, among other things, how financial testing and tenant selection will be administered and by whom. This includes the possibility of direct municipal administration of income testing and rent calculation.

OANHSS previously submitted comments on the consultation document entitled Report of the Joint Municipal/Provincial Working Group on Financial Testing and Access to Ontario Works, Child Care and Social Housing. We expressed our concern that central management of rent calculation will be detrimental to the well-being of seniors and persons with disabilities, particularly those who are less mobile or who rely on a familiar and supportive person to assist them with their financial affairs. Our position then, as now, is that the most effective scenario for seniors non-profit housing is to have the income verification functions remain with the individual non-profit seniors housing providers.

We would like to further stress that in many situations, seniors rely on non-profit housing staff and there may be a duplication of effort if staff are needed to help a senior compile and explain the necessary documentation to CMSM staff even if the official streamlined approach would have the senior supply information directly to the CMSM.

Some functions will be retained by the province or delegated to the proposed Social Housing Services Corporation for administration at a province-wide level (e.g. joint purchasing of goods and services). Our Association understands the value of volume purchasing arrangements as we have successfully offered them to our members for many years.

We appreciate that centralized mortgage financing does make sense as a way of achieving lower interest rates, as does centralized purchasing of insurance and other goods and services. However, given the experience and success of our Association and other similar groups in the area of group purchasing, we would urge the province to work with sector organizations when establishing the Social Housing Services Corporation, particularly with respect to this type of activity.

The organization responsible for pooling of capital replacement reserves should not become a gatekeeper of the use of those funds.

Once the legislation is in place, the municipal service managers will finalize the details of both the transfer and the program changes as they prepare to implement the new administrative approach.

All housing providers need to be given the opportunity to participate in discussions with the service managers to ensure that the new administration is sensitive to the needs of their tenants and that the approaches taken in areas of municipal discretion reflect the experience of housing providers. In particular, the new administration must understand the unique strengths and challenges of seniors and supportive housing, and the distinctive niche that this type of housing represents within the spectrum of social housing.

Some OANHSS members own and manage housing that has traditionally been funded and administered by the federal government. This housing will also be transferred to the municipal level but with the existing operating agreements intact.

Members appreciate the fact that it may be possible for individual housing providers to negotiate arrangements with local service managers that will enable them to incorporate some of the program efficiencies being introduced through this legislation. However, these members who own and manage federally funded housing have communicated strongly their reluctance to enter into discussions to amend their federal operating agreements. They will do so only if there is a clear benefit to those projects and the people who call them home.

Some of the federal portfolio that is being devolved to the province now operates as long term care facilities. It is not clear how this housing stock will be dealt with and how it will relate to the Ministry of Health and Long-Term Care’s Bed Re-development Project.

In conclusion I want to say that OANHSS members, like the Ministry, are committed to a process for transfer of responsibility for social housing which has no negative impact on the people who live in that housing. Our Association is prepared to work with the province and municipalities to ensure that this is accomplished.

D. SUMMARY OF RECOMMENDATIONS

1. In conjunction with the introduction of the Social Housing Reform Act, the provincial government must pledge renewed support for funding new subsidized social housing.
2. The Social Housing Reform Act must require that service managers ensure that any savings in expenditures on existing social housing are reinvested in new housing or in enhancements to existing housing. The level of total government expenditure on social housing should be maintained at least at the current level.
3. The legislation must balance the need to protect the interests of the province and the municipality with the need to ensure that housing providers have the flexibility to exercise good judgement and to continue to be responsive to local community needs.
4. The Province of Ontario must require municipal service managers to involve the owners and managers of social housing in the development of any new rules related to that housing.
5. Both housing providers and municipal governments need to know how the province intends to deal with the likelihood that future capital replacement costs will exceed the reserves available.
6. We believe that it is critical that the benchmarks reflect the real cost of providing the supportive living environment that seniors need, including the sometimes less tangible social support provided by OANHSS members. As the costs of different projects are compared to one another, it is essential that the comparison involves projects that are similar; all of the factors that contribute to higher costs must be considered.
7. OANHSS members are concerned that a co-ordinated access system will not be sensitive to the unique character of certain housing projects or respect their historic relationship with their founding community. Co-ordinated access systems must respect the mandate of housing providers to address the needs of particular ethnic, cultural or religious communities, which in many cases have made significant contributions to the organization.
8. Development of a co-ordinated access system for people with special needs must involve collaboration with the provincial support ministries and sector associations like OANHSS which represent the organizations which provide housing and support.
9. Any co-ordinated access systems that are put in place must undergo a thorough evaluation after the first year, involving input from all stakeholders, to ensure objectives are being met.
10. The most efficient scenario for seniors non-profit housing is to have the income verification functions remain with the individual non-profit seniors housing providers.
11. If the centralized pooling of capital replacement reserves were pursued, we would strongly emphasize that housing providers must have unimpeded access to their funds when they are needed.
12. The province, in finalizing the transfer, must require that the service managers work collaboratively with the community-based organizations responsible for delivering social housing in their communities. These discussions need to include the process that the service manager will put in place to manage its responsibility for financial testing and co-ordinated access.
13. OANHSS members want assurance from both the federal and the provincial governments that the federal non-profit program will be flexible enough to allow federal stock that currently operates as long term care facilities to continue delivering much needed long term care services.

Ontario Association of Non-Profit Homes & Services for Seniors
7050 Weston Road, Suite 700, Woodbridge, Ontario L4L 8G7
(P) 905-851-8821
(F) 905-851-0744

Comments or questions about our site?
Contact Debbie Humphreys at 905-851-8821 ext. 233
 Media Enquiries
© Copyright 2008 OANHSS

OANHSS Privacy Policy

OANHSS members include not-for-profit providers of long term care, services and housing for seniors in Ontario.
Members include municipal and charitable long term care homes, non-profit nursing homes,
seniors' housing projects and community service agencies.