FIRST NATIONS SOCIAL DEVELOPMENT POLICY

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1 Strategically Asserting the Voice of BC First Nations in Social Development FIRST NATIONS SOCIAL DEVELOPMENT SOCIETY FIRST NATIONS SOCIAL DEVELOPMENT POLICY AND PROGRAMS COMPARABILITY REPORT March 2012 Prepared by: J. Peterson Consulting

2 Intended Audience: Aboriginal Affairs and Northern Development Canada Ministry of Social Development BC First Nations Band Social Development Workers First Nations Social Development Society Board of Directors Prepared by: J. Peterson Consulting Telephone: (386) Exclusively For: The First Nations Social Development Society Telephone: (604) Suite Park Royal South West Vancouver V7T 1A2 This report will be available on the FNSDS website:

3 Note: This report is a summary, and may not include policies or practices beyond its purpose. By nature, social development policies and practices change over time. Please refer to the cited literature review material sources for the most up-to-date information. Information was predominantly obtained from the Aboriginal Affairs and Northern Development Canada (AANDC) Income Assistance Program National Manual, AANDC Social Development Policy and Procedures Manual BC Region and the Ministry of Social Development Online Resource. Thank you

4 PREFACE The First Nations Social Development Society has a mandate to promote and be a catalyst for positive social change in First Nations communities with the ultimate goal of assisting First Nations people with their self-sustainability aspirations. The First Nations Social Development Policy and Programs Comparability Report s purpose is to demonstrate factually where the income assistance programs and services offered by the Province of British Columbia via the Ministry of Social Development and Aboriginal Affairs and Northern Development Canada are not reasonably comparable. First Nations administering authorities are responsible for administering income assistance to their community members within the policy and guidelines set forth by AANDC at standards reasonably comparable to those found off-reserve. Unfortunately, there are many First Nations administering authorities that are struggling to meet the social development needs of their community members. On and off reserve social development policies, human resources, intake and assessment practices, programs and service, data management resources and research opportunities have been examined for this report. These areas have been identified as key components of successful program delivery in numerous other works. Special thanks to Michael Sadler, Rene Beauchamp, Nene Kraneveldt, Karen Lewis and Lyndale George for their assistance in the development of this report.

5 TABLE OF CONTENTS 1.0 INTRODUCTION POLICY Authority and Administration Eligibility Requirements Reviews and Reporting Payment of Assistance, Loss Management and Recoveries Rates HUMAN RESOURCES Case Management Hiring Training Career Growth Wages INTAKE AND ASSESSMENT Application Process Designation Requirements Appeals PROGRAMS AND SERVICES Hardship Assistance Employment Programs Special Allowances Supplements Health Benefits DATA MANAGEMENT Ministry of Social Development Data Management Aboriginal Affairs and Northern Development Canada Data Management RESEARCH Ministry of Social Development Research Aboriginal Affairs and Northern Development Canada Research SUMMARY

6 9.0 CONCLUSION

7 1.0 INTRODUCTION Under section 91 of the Constitution Act, 1867, Parliament has legislative jurisdiction over Indians, and lands reserved for Indians. The Indian Act, passed under this authority, and numerous court decisions in this area have established a complex legal system that applies to reserves and Status Indians. Aboriginal Affairs and Northern Development Canada (AANDC), formerly known as Indian and Northern Affairs Canada (INAC), has been the main federal organization responsible for meeting the Government of Canada s obligations and commitments to Aboriginal people (Office of the Auditor General of Canada, 2011). The Income Assistance (IA) program for First Nations on reserve is managed nationally by AANDC. AANDC leads in policy development and oversees program issues. First Nations, usually a First Nation Chief and Council, receive funding for programs and services to be administered on behalf of final recipients. Following the terms and conditions from Treasury Board, the Income Assistance program must be delivered at standards reasonably comparable to the reference province or territory of residence (AANDC, 2004). In British Columbia, the Ministry of Social Development (MSD) Employment and Assistance (EA) and Employment and Assistance for Persons with Disabilities (EA PWD) programs provide the standards to which the on-reserve system should be reasonably comparable. Statistics and research show that the basic standards available to persons living off-reserve in BC are not reflected on-reserve: Almost half (47%) of First Nations people on reserve live in poverty, with an income of less than $10,000; three out of five Aboriginal children under six live in poverty; Unemployment and poverty rates are three times those in the non-aboriginal community; Suicide is now among the leading causes of death among First Nations children and youth; Aboriginal children die at three times the rate of non-aboriginal children; and Canadians have one of the world s highest life expectancies but Aboriginal people can expect to live a decade less on average (AANDC, 2006). Many First Nations administering authorities simply do not have the capacity to meet the social development needs of their community members under the current circumstances

8 The purpose of demonstrating the inequalities between on and off-reserve income assistance programs is to: Provide insight on what would be needed to bring on-reserve social development policy, programs and practices up to par with what is available off-reserve; and Identify what is needed to reduce dependency on social programs on-reserve. In no way, does the intent include the assignment of fault to any party for the current state of any of the circumstances discussed within this report. One of the identified key elements of Active Measures is the development and maintenance of partnerships. The MSD and AANDC: policies human resources intake and assessment practices programs and services data management practices and research opportunities have been examined and compared. This report highlights the major disparities between the 2 systems. Information in point form can be found in the summary portion of this report

9 2.0 POLICY The following section outlines major disparities between the MSD and AANDC assistance policies. Information in this section has been collected from the MSD Online Resource, AANDC s Income Assistance Program National Manual and the AANDC Social Development Policy and Procedures Manual BC Region Volume Authority and Administration The authorities and administration are distinctly different on and off-reserve. The on-reserve system is complex and allows for some flexibility and varied interpretation. Funding arrangements between AANDC and a First Nation do not allow for real long-term planning. Currently, the longest term funding arrangement available to a block funded band is 5 years. The MSD program administration includes contracted employment and assessment service providers that the on-reserve system, for the most part, lacks. 2.2 Eligibility requirements Eligibility for employment and assistance with the MSD includes: A 3 week work search; 2 consecutive years of financial independence; Clients may not be in receipt of assistance for more than 2 of 5 consecutive years; and Applicants must resolve warrants for arrest prior to eligibility. Further, family members may receive reduced benefits until the warrant is resolved. The on-reserve system lacks these types of eligibility requirements. In many cases, assistance may be granted to a client before any work search has been attempted. This may be due in part to the remoteness of many reserves and the lack of employment opportunities in those locations. Under the current policy, a client may remain on assistance for extended periods of time. Income Assistance is not intended to be a principal source or first choice of income. 2.3 Reviews and Reporting The MSD has a branch dedicated to conducting reviews based on risk assessment and data matching from other provincial and federal government agencies. Employment and Assistance Workers (EAW) work with investigative officers and ministry investigators to detect cases of assistance abuse. On-reserve, the Band Social Development Worker (BSDW) is responsible for the majority of client reviews, reporting and detection of fraudulent activities. BSDWs are often overloaded with responsibilities and in some cases, in conflict of interest when it comes to administering - 3 -

10 assistance to close family members living in their community. Additionally, the AANDC onreserve policy does provide any specific support services or follow-up procedure when it comes to fraudulent cases. The band is left to its own resources to address the issue. 2.4 Payment of Assistance, Loss Management and Recoveries Payment of assistance with the MSD is predominantly by direct deposits, based on a yearly schedule, with tax services provided to assistance recipients receiving over $500 per year. Recoveries may be deducted from other agencies including Employment Insurance benefits, Workers Compensation Board payments etc. On-reserve the BSDW determines eligibility, issues manual cheques, is responsible for investigating and preventing fraud and collecting recoveries, which in some cases can be waived by the BSDW. In a small community setting, this can raise issues such as personal safety for the worker. 2.5 Rates Shelter rates on and off reserve are comparable, however on-reserve shelter allowance is restricted and dependent on homeownership and living arrangements. Rent is not covered for IA clients living situations where: The client lives in social and/or band housing that is without a mortgage; A room is being rented in a dwelling that is without a mortgage, with or without the homeowner living in the home; or The client lives in a home in which the owner also lives. Additionally, IA recipients on-reserve do not have access to funds for security deposits for rental housing or utilities. MSD clients have access to assistance for security deposits for rental housing and utilities such as electricity, natural gas and heating fuel. Lastly, it should be noted that on-reserve policy does not have any provision for rent to be paid off-reserve for cases in which a client may wish to transition off-reserve to pursue a job opportunity. Housing on many reserves in BC is very limited. Residences tend to be overcrowded and well below standards found off reserve. With a combination of sub-standard housing, limited availability and restricted assistance for accommodation, many First Nations IA clients live in what is often described as 3 rd world living conditions

11 3.0 HUMAN RESOURCES The following section outlines the MSD and AANDC human resources. Case management, hiring, training, career growth and wages have been examined. 3.1 Case Management There are few to no permanent contracts with 3 rd party program administrators for client services on-reserve. BSDWs may not always have the support needed to ensure clients are receiving the most suitable services and are often required to work well over full time. As well as administering the Income Assistance program, most bands administer Child Out of the Parental Home COPH, the National Child Benefit Reinvestment Program and Family Violence Programs within their job functions. Some include the health programs and also band membership (Campbell, 2009); and Most bands are using paper filing and have no specific social development software system in place for managing client information. Community isolation is a major contributing factor in the services and supports available to the BSDW and IA clients. 3.2 Hiring Hiring for an EAW position is a competitive, regulated process. Applicants have access to job specific information, are able to make an online applicant profile and apply for positions online. Currently BSDW s have a 35% -40% turnover rate, which creates an ongoing need for new staff and training services. The method of advertising vacant BSDW positions is generally at the discretion of the band chief and council and varies according to the existing circumstances. 3.3 Training EAWs are provided 6 months of comprehensive, paid on-the-job training. A new EAW participates in the Employment and Assistance Worker Core Training Program for the first 60 days on the job. The program combines online learning, observation, hands on experience, shadowing and coaching. On-reserve, three BSDW training modules total a combined 10 day program and there is virtually no on the job training. On-reserve staff may or may not be able to attend additional training due to lack of staff and/or funding at their band office

12 Staff training is essential to providing the client with the best possible service. Issues of accountability, documentation and reporting may partially stem from the differences in the length of available BSDW training. 3.4 Career Growth As EAWs broaden their knowledge and experience, they are able to develop their careers. There is no formal career enhancement of salary based on training, education and length of time on the job for BSDWs. On-reserve, the First Nations Social Development Society Resource Center Survey 2011 indicated that at least 30% Band Social Development workers had been in their position for over 10 years while almost 50% were relatively new (1-3yrs). This indicates that there are few career growth opportunities for BSDWs and that there is also a high turnover rate (Campbell, 2009). It should be noted that opportunities for career growth can provide incentive and acknowledgment of professional accomplishments. 3.5 Wages The following table illustrates compensation rates for MSD Employment and Assistance Workers (Glockzin, 2011): Growth Plan Level Current Bi-Weekly Compensation Rate Hours Accumulation Approximate Length of Time (Trainee) Level 1 $ hours 6 months (Trainee) Level 2 $ hours 6 months (Trainee) Level 3 $ hours 6 months Grid 15 Step 1 $ hours 1 year Grid 15 Step 2 $ hours 1 year Grid 15 Step 3 $ hours 1 year Grid 15 Step 4 $ hours 1 year Grid 15 Step 5 $ hours 1 year On-reserve, there is no province wide pay grid for on-reserve social development workers. Wages for BSDWs is set by the Administering Authority and vary by band. Currently, the average wage for a BSDW in a remote band starts from $12/hr ($840 bi weekly) and can range up to $22/hr for the few, more urban and larger bands ( $1540 bi weekly). It should be noted that, to keep an educated, dedicated staff in a band office, First Nations need to have comparable wages with what is available off-reserve

13 4.0 INTAKE AND ASSESSMENT The following section highlights differences between the MSD and AANDC intake and assessment procedures. The application process, designation requirements and appeals have been examined. 4.1 Application Process EAWs with MSD are required to review applicant s resume and work search efforts. The process includes a 3 week work search for most applicants. The EAW conducts an employability screen to identify client s needs and creates a client profile and an employment plan which is electronically accessible. Employment, homelessness, mental health, addictions and affordable housing shortages cannot be resolved by a single organization. The MSD supports an integrated approach to social development with partnerships between multiple ministries, agencies, businesses, non-profit organizations to provide clients with support. 3 rd party service providers are a key element to providing clients with the targeted supports they need. On-reserve, the application process, for most clients is immediate and contains no or very limited work search criteria often due to limited or non-existent employment opportunities. The BSDW is primarily assessing eligibility of IA and not for employment eligibility, though this employment search requirements are in the on-reserve IA policy. The BSDW is responsible for developing consistent procedures for collecting relevant information, verifying information and determining eligibility for assistance in accordance with AANDC policy and procedures. There is no integrated software system and no client tracking within the AANDC system. The BSDWs reporting responsibilities and maintenance of paper files can overshadow their true purpose of assisting clients movement along the employability continuum. Though there are many 3 rd party database programs available for on-reserve IA management, there are currently no permanent standard 3 rd party programs adopted province-wide. Funding capacity to buy and maintain such programs remains a significant issue. Additionally, most of these programs do not offer employment and assessment or client tracking features. 4.2 Designation Requirements For the most part these two policies are comparable off and on-reserve. With MSD, the Persons with Persistent Multiple Barriers (PPMB) designation is obtained by meeting medical criteria and some employment criteria. For PPMB, on-reserve clients must satisfy only medical criteria for the designation. Access to medical professionals and travel can be an issue with remote bands

14 4.3 Appeals If a person off-reserve is dissatisfied with the outcome of a request for reconsideration, they can appeal directly to the Employment and Assistance Appeal Tribunal. The tribunal is an independent entity that is responsible for the overall management and operation of the appeal process. A panel, appointed by the tribunal Chair, will decide if the ministry reasonably applied the legislation and if a reasonable decision was made based on the evidence that had been submitted (Province of British Columbia, 2011). The appeals committee on-reserve is comprised of: A person nominated by the appellant A person nominated by the Administering Authority A chairperson selected jointly by the nominees of the appellant and the Administering Authority (AANDC, 2006). On-reserve the process is very similar, however the client is often poorly represented due to the lack of access to adequate advocacy organizations. The exception may be in large urban centers

15 5.0 PROGRAMS AND SERVICES The following section outlines disparities between the programs, services, special allowances and supplements available to on and off-reserve assistance recipients. Benefits provided to Status individuals by the Medical Services Branch of Health Canada have also been examined. 5.1 Hardship Assistance The policy is similar for both MSD and AANDC clients. However, clients with the MSD may qualify for hardship assistance when the applicant has been disqualified for fraud or related offences. AANDC does not have a fraud unit and the policy contains no fraud or related eligibility criteria. Bands are therefore left to addressing cases of fraud as circumstances allow. If applicants, adult dependants or spouses have quit work, been fired, do not accept work or are not seeking work they deemed ineligible for IA. If they have no other sources of income, they may be eligible for hardship assistance under the AANDC framework. 5.2 Employment Programs In this area comparability between on and off-reserve programs varies greatly. The on-reserve IA program does NOT include comparable services offered by the: Community Assistance Program Bridging Employment Program Family Maintenance Program o On-reserve IA program does not have reasonable ability to enforce child maintenance payments There are no employment programs specifically targeted towards Persons with Disabilities onreserve. Components of MSD Employment Strategy for Persons with Disabilities include: Employment Program for Persons with Disabilities (EPPD) Self Employment Program (SEP) Ministers Council on Employment for Persons with Disabilities Disability Supports for Employment Fund Employment and training programs are integral components of the MSD EA program

16 On-reserve administering authorities must use limited, existing funding via the Work Opportunity Program (WOP) - IA transferred to the band as a wage subsidy, Aboriginal Social Assistance Recipient Employment Training Initiative (ASARET) - IA transferred to the Aboriginal Skills and Employment Training (ASET) service provider as a wage subsidy and the Training and Employment Support Initiative (TESI) - short term funding eg. tuition and books. Access to the existing employment and assessments provided by the BC ASETS services providers is limited, particularly for remote bands. Over the last few years, limited AANDC funding for on-reserve Active Measures Initiatives have begun to bridge the employment program gap, however much greater capacity and endeavour in this area will be needed to reflect employment, assessment and referral programs available off-reserve

17 5.3 Special Allowances The on-reserve Special Allowances budget is a limited, yearly budget allocated to the band based on population. All special allowances are subject to the bands funding availability. Off-reserve these allowances come from a general source that is shared by all MSD offices and is governed by client individual entitlement (as related to IA policy) and their need. Table 5.31 outlines the specific policies where there exist disparities between available services to on-reserve assistance clients when compared to those available to MSD clients. AANDC Special Allowance Comparable to MSD Exception Incentive Allowance Community Volunteer Program Only one member of a family may participate at any one time Special Needs Allowance Work Clothes and Work Transportation Work Force Entry Benefit Moving Costs Special Transportation Crisis supplement/ Emergency/Disaster and Essential Utilities Supplement Confirmed Job Supplement N/A Moving, Transportation and Living Costs Transportation to Drug and Alcohol Facilities/Travel Supplement No utility security deposits available Not available for transient recipients or Hardship Assistance recipients Only moving within BC is covered, No repayable storage allowance, No transportation and living costs for required attendance in a child protection hearing, No transportation, living, and child care costs to attend a court hearing, a DNA paternity testing collection site, or an office of a notary public when the recipient is obligated No applicable escort expenses are covered 5.31 Special Allowance Exceptions to MSD Comparable Services

18 5.4 Supplements The AANDC framework does NOT include equivalencies to the MSD in the following areas: Co-op share purchase supplement Prenatal shelter supplement Special Transportation Subsidy for PWD clients where bus is unavailable Training Initiative for PWD clients Medical Services Only Specific health supplements provided to former recipients of assistance. Non status individuals on-reserve may not be covered under non-insured benefits as they move towards employment Identification supplement Security deposits for rental accommodation or utilities Essential Utilities (a crisis supplement) 5.5 Health Benefits On-reserve, Status IA clients receive health benefits through Health Canada. Eligible items are reasonably comparable to those available to EA clients. Health Canada s rates, however are frequently below the provincial Medical Services Plan and IA rates for non-status clients. This can create entitlement disparities between on-reserve IA clients. Medical travel on-reserve lacks several elements that are found in the MSD policy: MSD works with: Travel Assistance Program (TAP) which is coordinated by the Ministry of Health Services - Transportation partners agree to waive or discount their regular fees; and Health Connections Program: a regional travel assistance program that offers subsidised transportation to help with costs for rural residents who must travel to obtain nonemergency medical care. Non-status recipients with Medical Service Plan coverage may be provided with premium-free medical coverage to assist with specific individual health needs and circumstances. Specified health benefits may be provided to eligible non-status recipients and their families. These include a limited number of health-related services and supplies not covered by MSP

19 6.0 DATA MANAGEMENT Like all assets, data requires management to ensure that the maximum amount of benefit can be achieved by the owner. The following section outlines the data management resources and practices available to MSD staff and AANDC staff for managing IA and EA. The Ministry of Social Development uses a province wide, interconnected system to manage EA client s files, whereas many First Nations Administering Authorities use paper filing systems. This can make navigation difficult, particularly with high staff turnover; AANDC currently has no tracking mechanism to track IA clients from band to band through work programs or otherwise; and AANDC currently has no agreements with Employment Insurance, Health Canada, Canada Mortgage and Housing Corporation (CMHC), Medical Service Plan (MSP) or Canada Revenue Agency (CRA) for the sharing of client information, and has very few protocol agreements with other government organizations/departments for sharing information. 6.1 Ministry of Social Development Data Management The Integrated Case Management (ICM) system is a joint initiative between the Ministry of Social Development and the Ministry of Children and Family Development (MCFD) to improve the way both the ministries manage client information. The system replaced outdated technology that had become inflexible, increasingly fragile and difficult to adapt to policy changes. By replacing the aging computer systems, MSD and MCFD have improved their ability to share information and to manage individual case files between ministries. The implementation of ICM responds to calls for an updated information management system that better protects private information through enhanced security technology. The new province wide system enables both ministries to link public spending to client outcomes resulting in improved accountability and transparency (Gordon, 2010). The Ministry of Social Development research branch manages one of the largest income assistance datasets in the world, with nearly twenty years of detailed monthly client data. The branch is able to supplement this data with data from other sources, such as Records of Employment and Employment Insurance Records. The branch is currently expanding its basic reporting practices to include more analytical reporting. This progression is needed to uncover the meaning behind collected data (ACE, 2011)

20 6.2 Aboriginal Affairs and Northern Development Canada Data Management Today most First Nations communities have some internet connectivity. However, most do not have a permanent system in place to manage social development information. The First Nations Technology Council (FNTC) conducted a survey in 2009 that concluded 50% of surveyed communities use MS Excel to manage data. 25 Top Five Ways of Managing Data Excel Xyntax A.I.S. Tribal Systems Abernaki Table 6.21: Top five ways of managing data on 55 reservation communities (FNTC, 2009) Many First Nations are currently using paper copies and hand filing client information. First Nations are required to maintain records on all expenditures. This method of reporting is extremely time consuming and in many cases overshadows the workers ability to serve their clients. If a First Nation is unable to demonstrate how funding was used, they may be required to return funds to AANDC. Sto:lo First Nation has developed Unification as a system of managing human resources, social development, education and employment services. The system allows staff to access information quickly and easily, allowing staff to identify client s needs and suitably address them. In the near future, AANDC may be posed to purchase Unification for distribution to the First Nations that currently have no dedicated system and to those that may wish to change systems

21 7.0 RESEARCH For data to be useful information, analytics and research must be conducted. 7.1 Ministry of Social Development Research The Ministry of Social Development Research Branch, when fully staffed, employs 10 full-time employees. The Research Branch is composed of management, economist and research officers who are primarily organized around technology, analytics and administration. The branch conducts research on social issues with the goal of identifying where challenges are and finding suitable solutions. The branch has access to one of the largest income assistance data bases in North America with monthly data from 1980 to present. Access to such information allows the branch to quantitatively evaluate programs and policies. Areas of research interest include: prediction of populations at risk, reducing poverty, using the tax system as a tool to provide incentives to work, relationship between health and income assistance and transitions in the labour market (ACE Research Branch). Reporting is integrated into the provincial MSD database system. MSD is able to generate real time reporting and statistics. Research has made an impact in: Work First - Data matching with Statistics Canada s Longitudinal Administrative Databank (LAD) to analyze a client s employability and income potential. Demonstrated that the majority of expected to work clients had gone to employment and that their income increased over time, supporting the ministries focus on employment first. Adult Basic Education - The ministry s policy of a family unit being ineligible for income assistance when an adult in the family is a full-time student has been supported by research showing that ABE increases income assistance dependency in the short term and has no impact on the longer- term. Caseload forecasting - The branch predicts the Employment Assistance (EA) caseload out 4 to 5 years broken down by program designation (Expected to Work, PPMB, PWD etc) allowing for planning and budgeting. Impact Analysis - Predicting proposed policy change impacts such as estimated costs and savings and impacts on clients. Analysis of caseload market and social trends - The branch conducts caseload analysis to better understand clients. This may include family type, program designation, age distribution etc. to gain a better understanding of how clients move into and out of the system. Trends are monitored on a regional, office and community level, as well as a provincial summary (ACE, 2011)

22 7.2 Aboriginal Affairs and Northern Development Canada Research AANDC conducts a wide range of research on aboriginal and northern issues, such as education levels, average income and life expectancy of aboriginal people and northerners. The majority of research and statistics show that considerable work remains to be done in the social development field to improve the quality of life for persons living on-reserve. Although the need for more in-depth research is widely recognized, it has not received the level of priority and coordination which it deserves (AANDC, 2004). Research on-reserve tends to be more statistical and passive reporting. More emphasis on proactive analysis and long-term development needs to be in place to achieve comparability to the Provincial system. For this to be a reality, communication, planning, commitment, staff and funding need to be in place on an ongoing basis. Over the last few years, AANDC has begun to bridge the research gap by funding organizations and consultants to procure much of this needed data under its Active Measures initiatives. As this information is compiled it will add a valuable perspective on needed services and its target base

23 8.0 SUMMARY Yellow = Non Comparable/Lacking Elements, Green = Comparable, Red = Non Existent, Pink = Subject to Availability of Funding in Special Needs Budget MSD AANDC Yes Comparable No Policy Authority Administration Acts and Regulations under Provincial Parliament Complex System based in Ottawa & comparability with provincial policy No/Limited 3 rd Party Service Providers Funding Authority N/A Eligibility Requirements Reviews and Reporting Payment of Assistance Rates Loss Management Recoveries Case Management 3 Week Work Search, No Warrants, 2 yrs independence and 2 of 5yrs max Prevention and Loss Management Services Branch, Data Matching Direct Deposit, Tax Services Basic Rates, Deposits Available Prevention and Loss Management Services Branch Prevention and Loss Management Services Branch Ministry Staff and 3 rd Party Service Providers Human Resources Basic Dependent on residency only BSDW Cheque Restricted based on living arrangements, limited rental housing no utility deposits BSDW BSDW Fewer Staff in Band Office, Limited 3 rd Party Service Providers, BSDW does more than social development, Isolation affects case management

24 MSD AANDC Comparable Yes No Hiring Open, Competitive Public Service Process Based on circumstances and limited to available applicants Training 6 mo, mentoring 3 x 3 day Training modules Employee Resources Online Learning Center, Pacific Learners Program, Leading the Way, Employee Performance and Development Planning Online Resource, Online Training, training manuals and forms, line, FNSDS, AANDC Extranet Career Growth More Opportunities Limited Opportunities Wages Regulated Pay Grid Set by Band Intake and Assessment Application Process 3 week work search, resume review, Employability Screen and Profile Eligibility Assessment based on residency PPMB Eligibility PWD Eligibility Decisions, Reconsiderations and Appeals Hardship Assistance Community Assistance Program Bridging Employment Program British Columbia Employment Program Medical and Employability Criteria Independent Tribunal Medical Criteria Includes Appellant Nominated Panel Member, Poor Client Supports Programs, Services, Allowances and Supplements Client is eligible while disqualified for EA for fraud or other related offences May be eligible when quit work, been fired, do not accept or are not seeking work Direct Purchase

25 Non Ministry Funded Employment Programs and Services Work Opportunity Program (WOP) Aboriginal Social Assistance Recipient Employment Training Initiative (ASARET) Training and Employment Support Initiative (TESI) Comparable MSD AANDC Yes No Family Maintenance - PWD Employment Supports - Child in the Home of a Relative Ministry of Children and Family Development Ministry of Children and Family Development (03/12) Child Care Subsidy Ministry of Children and Family Development Ministry of Children and Family Development Bus Pass Camp Fee Camp Fee Allowance Christmas Clothing Supplement For People in a Special Care Facility Community Volunteer Program Confirmed Job December Supplementary Allowance Comforts Allowance and Clothing Allowance For People in a Special Care Facility Incentive Allowance Work Clothes and Work Transportation Co op Share Purchase - Crisis Special Needs Allowance

26 MSD AANDC Yes Comparable No Guide Animal Guide Animal Allowance Family Bonus Funeral Costs Identification - Moving Transportation and Living Costs Moving Costs Only Prenatal Shelter - Replacement of Lost or Stolen Cheques School Start Up School Start Up Allowance Security Deposits - Senior Supplements Supplementary Assistance To Old Age Security Pension Special Transportation Subsidy Training Initiative Supplement Transportation to Drug and Alcohol Facilities Special Transportation - - Travel Supplement Special Transportation Utility Security Deposit - Alcohol and Drug Residential Treatment Dental and Orthodontic Services* Emergency/PWD /PPMB Diet Supplements Extended Medical Therapies* Healthy Kids

27 Medical Equipment Hearing Aids* Life Threatening Health Needs MSD AANDC Yes Non- Status Comparable - Medical Equipment and Devices* Medical Services Only - Work Force Entry Benefit - No Medical Equipment Orthoses* Medical Services Plan and Medical Coverage* Non-status Non-Status Medical Supplies Non-status Medical Transportation Non-Status Monthly Nutritional Supplement Natal Supplement Nutritional Supplements Short Term Nutritional Supplement Optical Services* Non-Status Pharmacare Supplement for Drug and Alcohol Treatment - Tube Feed Supplement Non-Status Data Management Interconnected Information Management System - Data Warehouse - Research Opportunities More Fewer Outcomes Focused development of prog. and supports Recognition of FN not receiving adequate support *Non Status Health. Status benefits through Health Canada. Rates may be lower

28 9.0 CONCLUSION The on-reserve income assistance program is frequently not reasonably comparable to the offreserve, provincial employment and assistance program. From the findings in this report, it may be possible to conclude that on-reserve: A lack of coordination across the various levels of government, First Nations communities and industry resulted in fragmented program development and delivery; Moderate eligibility requirements and enforcement of policy and the lack of employment alternatives and programming has contributed to extended dependency on IA as a primary means of income; The social development program lacks resources, 3 rd party service providers are limited; The Band Social Development worker, in many cases, receives limited training, can be overburdened with paperwork and conflicted in the delivery of the IA program; Funding for training and travel is limited. Issues such as accountability, documentation and reporting may partially stem from the differences in the length and availability of BSDW training; Employment programming, essential to client progression along the employability continuum, is limited and lacks sufficient funding; Access to basic necessities such as housing and utilities is restricted and limited; Data management and communications lack coordination and interconnectivity. First Nations communities require access to up-to-date technology; Research modalities and opportunities are fewer; and The on-reserve reporting mechanisms are paper heavy, labour intensive and involve limited use of online Internet technology. It is evident that programs and services available to First Nations reserves are much poorer than elsewhere in the province. First Nations administering authorities are charged with a substantial responsibility towards some of the most impoverished communities in the province and expected to serve them with fewer resources. It also evident that in many incidences the on-reserve Income Assistance program is not providing the critical supports needed to be effective and is not reasonably comparable to the provincial system. It may be surmised that if any progress is to be made in creating the opportunities for effective reduction to First Nations dependency on Income Assistance, as has been observed off-reserve in the last 5 years, the appropriate and adequate basic support services, allowances and employment programs (as our found off-reserve) must be put in place

29 Literature Review AANDC. (2004). Income Assistance National Manual. Retrieved November 7, 2011, from AANDC. (2006, October). Social Development Programs. Retrieved November 09, 2011, from ACE, A. C. (2011). Better Decisions Through Research. Research Branch. Ministry of Social Development. Beauchamp, R. P. (2011, February 20). First Nations Social Development Society. Retrieved November 20, 2011, from FNSDS Resource Center Survey: Beauchamp, R. (2012, January 9). Program Manager FNSDS. FN SD Policy and Programs Research Initiative - First Edit Communication. Vancouver, BC, Canada. Campbell, K. (2009, March). Funding for First Nations' Social Development Administration. Retrieved December 19, 2011, from Council, F. N. (2009). Survey of Currently Used Systems. Vancouver: FNTC. First Nations Social Development Society. (2011, August ). Band Social Development Online Training. Retrieved November 15, 2011, from FNTC. (2009). Survey of Currently Used Systems. First Nations Tecnology Council. FNTC, F. N. (2006, November). Retrieved December 1, 2011, from Community Technology Toolkit Guide: Glockzin, D. E. (2011). Engagement and Workforce Development. Personal Communication. Gordon, S. (2010, February 12). NEW CASE MANAGEMENT SYSTEM TO IMPROVE SERVICE AND SECURITY. Retrieved December 23, 2011, from Ministry of Housing and Social Development: Office of the Auditor General of Canada. (2011). Status Report of The Auditor General of Canada to The House of Commons Chapter 4 Programs For First Nations On Reserve. Retrieved November 06, 2011, from Pathways to Technology. (n.d.). Connecting First Nations to the World. Retrieved December 22, 2011, from Province of British Columbia. (2011). Ministry of Social Development Online Resource. Retrieved November 09, 2011, from Province of British Columbia. (2011). Public Service. Retrieved November 12, 2011, from Employment:

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