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Now and Tomorrow Excellence in Everything We Do Strategic Policy and Research Branch Summative Evaluation of the Canada Pension Plan Disability Program Final Report January 2011 January 2011 SP-983-02-11E

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Page 1: Final Report January 2011 - canada.ca · The program covers virtually all sectors of the labour market including the self-employed. Each year between 1998 and 2005, about two-thirds

Now and TomorrowExcellence in Everything We Do

Strategic Policy and Research Branch

Summative Evaluation of theCanada Pension Plan Disability Program

Final ReportJanuary 2011

January 2011

SP-983-02-11E

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Summative Evaluation of theCanada Pension Plan Disability Program

Final Report

Evaluation DirectorateStrategic Policy and Research

Human Resources and Skills Development Canada

January 2011

SP-983-02-11E(également disponible en français)

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Note: the departmental catalogue number is placed on the front cover, bottom left hand side.

You can order this publication by contacting:

Publications ServicesHuman Resources and Skills Development Canada140, promenade du PortagePhase IV, 12th FloorGatineau (Quebec)K1A 0J9

Fax: 819-953-7260Online: http://www12.hrsdc.gc.ca

This document is available on demand in alternate formats (Large Print, Braille,Audio Cassette, Audio CD, e-Text Diskette, e-Text CD, or DAISY), by contacting1 800 O-Canada (1-800-622-6232). If you have a hearing or speech impairment anduse a teletypewriter (TTY), call 1-800-926-9105.

© Her Majesty the Queen in right of Canada, 2011

PaperISBN: 978-1-100-18161-5Cat. No.: HS28-186/2011E

PDFISBN: 978-1-100-18162-2Cat. No.: HS28-186/2011E-PDF

Information contained in this publication or product may be reproduced, in part or in whole, and by any means, for personal or public non-commercial purposes, without charge or further permission, unless otherwise specifi ed.

You are asked to:

• Exercise due diligence in ensuring the accuracy of the materials reproduced;

• Indicate both the complete title of the materials reproduced, as well as the author organization; and

• Indicate that the reproduction is a copy of an offi cial work that is published by the Government of Canada and that the reproduction has not been produced in affi liation with, or with the endorsement of the Government of Canada.

Commercial reproduction and distribution is prohibited except with written permission from the Government of Canada’s copyright administrator, Public Works and Government Services of Canada (PWGSC). For more information, please contact PWGSC at: 613-996-6886 or [email protected]

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Table of ContentsExecutive Summary ..................................................................................................... iManagement Response ................................................................................................ v1. Introduction .......................................................................................................... 1 1.1 Evaluation Scope and Methodology .............................................................. 1 1.2 Some General Cautions and Limitations ....................................................... 2 1.3 Organization of the Report ............................................................................. 22. Description of the CPPD Pension ...................................................................... 3 2.1 CPPD Eligibility ............................................................................................ 3 2.2 CPPD Pension ................................................................................................ 4 2.3 CPPD’s Main Features .................................................................................. 4 2.4 Rationale for the Program .............................................................................. 6 2.4.2 Theoretical Perspective ...................................................................... 6 2.4.2.1 Equity ................................................................................... 6 2.4.2.2 Effi ciency ............................................................................. 6 2.4.2.3 Public Good ......................................................................... 7 2.4.2.4 International Standards ....................................................... 7 2.4.3 CPPD as First Payer ........................................................................... 8 2.4.4 Interaction with Employment Insurance ............................................ 9 2.4.5 Program Relevance ............................................................................ 9 2.5 Program Objective ......................................................................................... 9 2.6 Program Activity ............................................................................................ 10 2.6.1.2 Profi le of CPPD Benefi ciaries .............................................. 12 2.6.1.3 Application and Approval Rates .......................................... 13 2.6.2 CPPD Pension .................................................................................... 14 2.7 Program Logic Model ................................................................................... 153. Achievement of Program Objectives ................................................................. 17 3.1 Are Those in Need Being Reached? .............................................................. 17 3.1.1 Disability Defi nition........................................................................... 17 3.1.1.1 Legislated Defi nition ............................................................ 17 3.1.1.2 Prevalence of Disability ....................................................... 18 3.1.2 Are Those with Labour Market Attachment Being Reached? ........... 20 3.1.3 Experience of Denied Applicants ...................................................... 22 3.2 Assessment of Benefi t Levels ........................................................................ 23 3.2.1 Earnings Replacement Rate ............................................................... 24 3.2.2 Income Share ..................................................................................... 25 3.2.3 International Comparisons ................................................................. 26 3.2.4 Benefi t Levels May Not Meet the Needs of All Groups .................... 274. Impacts and Effects of the Program .................................................................. 29 4.1 Impacts on Prevalence of Low-Income ......................................................... 29 4.2 Impacts on Quality of Life ............................................................................. 29 4.3 Impacts on Work Incentives ........................................................................... 30

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5. Issues in Program Delivery ................................................................................ 33 5.1 Issues Related to Signifi cant Partners ............................................................ 33 5.1.1 Applicants .......................................................................................... 33 5.1.1.1 Learning about the Program ................................................. 33 5.1.1.2 Communications with the Program .................................... 34 5.1.1.3 Understanding of the Program ............................................. 35 5.1.2 Doctors .............................................................................................. 35 5.1.2.1 Awareness and Understanding of Eligibility Criteria .......... 35 5.1.2.2 Awareness of Return to Work Supports ............................... 36 5.1.2.3 Interactions with other Disability Programs ........................ 36 5.1.2.4 Communications with the Program ..................................... 36 5.1.3 Staff Members in Regional Processing Centres ................................. 37 5.1.3.1 Effectiveness of Communications with Applicants and Benefi ciaries .................................................................. 37 5.1.3.2 Issues with Changing Policies and Procedures .................... 38 5.1.3.3 Working Relationships with Other Earnings-Replacement or Income Support Programs ............................................... 39 5.1.3.4 Quality of Service Delivery ................................................ 39 5.2 The Application Process ................................................................................ 40 5.2.2 Adjudication ....................................................................................... 41 5.2.3 Reconsideration and Appeals ............................................................. 41 5.2.4 Automatic Reinstatement ................................................................... 42 5.2.5 Benefi t Payment ................................................................................. 42 5.3 Impact of Changes to Service Delivery on Client Service ............................ 43 5.4 Performance Measurement Framework and Quality of Administrative Data ................................................................................... 43 5.5 Cost Effectiveness of Program Administration and Delivery ........................ 446. Conclusions and Recommendations ................................................................... 47 6.1 Conclusions and Areas for Further Work ....................................................... 47 6.2 Recommendations .......................................................................................... 48 6.2.2 The Application Process Could be Reviewed and Simplifi ed ........... 48 6.2.3 Examine Return to Work Supports .................................................... 49Annex I - Evaluation Questions .................................................................................. 51Annex II - Legislative Changes/ Major Events ......................................................... 59Annex III - Proposed Logic Mode .............................................................................. 63Annex IV - Bibliography ............................................................................................ 65

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List of TablesTable 2.1 Stock and Flow of CPPD Benefi ciaries ....................................................... 11Table 2.2 Females as a Percentage of CPPD Benefi ciaries 1996-2006 ....................... 13Table 2.3 CPPD Pension 1995-2007............................................................................ 14Table 3.1 Disability Distribution by Age ..................................................................... 19Table 3.2 Distribution of Contributors Qualifying for CPPD by Gender and Year of Contribution ............................................................ 20Table 5.1 How First Found Out About the CPPD Pension by Granted and Denied .... 34

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List of FiguresFigure 3.1 Average earnings of benefi ciaries starting CPPD during 1990-2006 ........ 24Figure 3.2 CPPD as a share of income ........................................................................ 26Figure 4.1 Employment rates and earnings of benefi ciaries ....................................... 31Figure 4.2 CPPD applicants' average earnings (2001-2006) ....................................... 31Figure 4.3 Average earnings among 50-64 year olds .................................................. 32

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List of Abbreviations

CCHS Canadian Community Health SurveyCMA Canadian Medical AssociationCPP Canada Pension PlanCPPD Canada Pension Plan Disability ProgramCRA Canada Revenue AgencyHRSDC Human Resources and Skills Development CanadaLAD Longitudinal Administrative DatabaseLICO Low Income CutoffMBF Master Benefi t FileMQP Minimum Qualifying PeriodNATS National Automated Template SystemNGO Non-governmental OrganizationOAS Old Age SecurityOECD Organisation for Economic Co-operation and DevelopmentOCRT Offi ce of the Commissioner of Review TribunalsPALS Participation and Activity Limitation SurveyQPP Quebec Pension PlanSLID Survey of Labour and Income DynamicsWCB Workers Compensation BoardWSIB Workplace Safety and Insurance Board

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Summative Evaluation of the Canada Pension Plan Disability Program i

Executive SummaryThis report presents the fi ndings and conclusions for the summative evaluation of the Canada Pensions Plan Disability (CPPD) Pension. As a component of the Canada Pension Plan (CPP), the CPPD Pension provides income security to individuals and families in cases where a contributor experiences a severe and prolonged disability that renders the person incapable of regularly pursuing any substantially gainful occupation.

Evaluation Scope and MethodologyThe evaluation was organized around a set of evaluation questions examining the continued relevance of the program, objectives achievement, impacts and effects, program delivery and cost effectiveness.

This fi nal report presents a synthesis of over 20 technical reports covering the ten-year time period (from 1997 to 2007) since the last evaluation of the CPPD Pension (which was in 1996). The range of methods used by the technical reports include literature review, document and fi le reviews, analysis of trends in CPPD applicants and caseload, analysis of data collected by a survey of 2,000 randomly selected CPPD applicants (consisting of approximately 1,000 granted and 1,000 denied applicants), analysis of linked CPPD administrative data and Canada Revenue Agency income tax data for CPPD applicants, case studies of the national disability earnings replacement or income support programs in four other countries, focus groups and key informant interviews.

When interpreting the fi ndings and conclusions presented in this report, readers should bear in mind some general cautions.• Quebec administers its own plan. Therefore, the totals for most tables presented in this

report will only include the nine provinces and the territories.• The CPPD Pension and delivery process went through many reorganizations during the

study period (1997 to 2007), and this presented challenges for the evaluation process. For example, changes in the mode of delivery made it diffi cult to make meaningful comparisons of delivery cost data over time.

• Canada Revenue Agency income tax data were used to derive information on earnings and incomes. Therefore most annual data are on a calendar year basis rather than the usual government fi scal year basis.

• Due to the vastness of the CPPD Pension, many complex issues are only briefl y touched upon in this report. As well, the fi eld of safety net programs for workers with disabilities is complex and includes a large number of public and private programs. Therefore, this report should be taken as a summary of what is known about the effectiveness and delivery of the CPPD pension at the time the report was written, while also recognizing that many questions remain unanswered.

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ii Summative Evaluation of the Canada Pension Plan Disability Program

Continued RelevanceThe CPPD Pension was founded on a strong rationale. As well, the stated intent of the program, the economic effi ciency and equity considerations, the continuing role of the federal government in providing income support to those in need, and the degree to which CPPD Pension has become coordinated and integrated with other programs for workers with disabilities all point to its continued relevance.

Achievement of Program ObjectivesThe program covers virtually all sectors of the labour market including the self-employed. Each year between 1998 and 2005, about two-thirds of those covered had suffi cient labour market attachment (i.e. had made suffi cient CPP contributions) to be eligible for CPPD pension in the event they became disabled (as set out in the CPP legislation).

The CPPD Pension has become the single largest public long-term disability insurance program in Canada. Each year between 1997 and 2007, close to 60,000 new applications were received, close to 300,000 benefi ciaries received approximately 3.5 billion dollars in CPPD pension.

The profi le analysis showed a rising trend in females as a share of new and total benefi ciaries (increasing from 42.9 percent of all benefi ciaries in 1996 to 50.7 percent by 2006) – mirroring increased female participation in the labour market. The profi le analysis also showed that the majority of CPPD benefi ciaries are in the 55 to 64 age group (which is consistent with Canadian data sources showing that the incidence of disability increases with age). Nearly two-thirds of the CPPD benefi ciaries are married. As well, CPPD benefi ciaries have a higher incidence of low-income than the rest of the population (22 percent have an after-tax family income below the after-tax Low Income Cut-Off (LICO) versus 15 percent of all Canadians age 18 to 64).

Comparing the number of CPPD benefi ciaries with data collected by the Participation and Activity Limitation Survey (PALS) and Canadian Community Health Survey (CCHS) suggested that CPPD reaches between 15 and 32 percent of those self-identifying as having severe disabilities. The difference between the number of program benefi ciaries and the results of these two surveys is largely due to differences in disability defi nitions among the CPPD, PALS and CCHS, as well as the contributory requirements of the CPPD Pension.

Determining CPPD eligibility is a challenging task. The CPP legislation and the Department’s policies and guidelines are used to identify the characteristics of a person considered to be disabled for purpose of the CPPD legislation. The process places particular emphasis on determining whether a disability is “severe” and “prolonged” as per this legislation. In spite of the technical and theoretical challenges in defi ning disability, the program has maintained a high level of stability in its application of its defi nition over a long time period. However, it remains a major challenge to provide a reliable assessment of disability levels across jurisdictions and through time.

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Summative Evaluation of the Canada Pension Plan Disability Program iii

Stringent defi nitions are stringently applied. Between 2001 and 2006, the average approval rate at the initial stage of the CPPD application process was 45 percent. Of the denied group, more than 80 percent did not meet the CPPD medical requirements. For the group of applicants who were denied at the initial stage (i.e. 55 percent of the total applicants), about 35 percent requested reconsideration and of these 40 percent were approved. Very few cases arrived at the Pension Appeals Board (PAB), which is the last stage of the appeal process. It should be noted that new information can be introduced at any stage of the reconsideration and appeals process, which can affect the decision. However, it was not possible to determine in what proportion of cases new information was provided.

Impacts and Effects of the ProgramThe analysis showed that CPPD pension has a positive effect on the income and quality of life of the individuals who qualifi ed for CPPD. For example, on average, CPPD pension accounted for about 50 percent of benefi ciaries’ total income. In some cases, CPPD is the only source of income (e.g. the survey of applicants suggested that CPPD pension accounted for all of family income for 12 percent of benefi ciaries). Further analysis indicated that roughly half of the benefi ciaries who would have been in poverty, avoided it as a result of the program. In the case of quality of life, the survey of applicants indicated that 72 percent of the granted applicants felt that CPPD pension enabled them to live independently and 50 percent indicated that the pension let them live actively.

Two lines of evidence suggested that many of those not granted CPPD pension do not resume working even three or four years after their CPPD application is denied. For example, the survey of applicants showed that 60 percent had not worked since their application was denied about four years ago. Also, less than a quarter of the denied applicants were working when they were surveyed four years later. Similarly, an analysis of linked CPPD administrative data and Canada Revenue Agency income tax data showed that nearly half (49 percent) of the denied applicants had no employment earnings three years after being denied benefi ts. This raises questions for further study.

Although economic literature suggests that disability benefi ts may create a disincentive to work, studies prepared for the evaluation found that the disincentives to work appear to be less prominent than suggested by other research. For example, the studies found that employment rates and earnings among CPPD benefi ciaries begin to decline years before the start of CPPD pension. Also, as discussed above, many denied applicants do not resume working after their CPPD applications are denied.

The application process was found to be long, complex and stressful for clients. For example, the focus group participants and applicant survey respondents generally felt the application process was too long. The majority of focus group participants indicated that their ability to cope with their illness, disease or accident was severely impacted by being continuously asked to “prove” that they were as disabled as they claimed. As well, many focus group participants and applicant survey respondents indicated that they had to rely on family and friends for fi nancial and/or emotional support during the application process.

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iv Summative Evaluation of the Canada Pension Plan Disability Program

Program DeliveryThe overarching structure of how the program is delivered seems to work well. However, a number of areas were identifi ed where changes could improve the process for applicants. For example, the application form is perceived to be lengthy and complex by applicants as well as delivery staff. As well, many applicants with mental health disability felt the application form was geared to those with physical disabilities. In addition, discussions with doctors indicated their view of unnecessary duplication in providing medical documentation required for CPPD, the disability tax credit, long-term disability insurance and other programs.

The applicant survey, focus groups and key informant interviews indicated that the program is well known, but not all aspects are well understood. For example, knowledge of the return to work rules, the impact of receiving children’s benefi ts, and the consequences of applying late could be improved. As well, the majority of focus group participants did not understand the adjudication process.

Most managers and two-thirds of the medical adjudicators who participated in the key informant interviews felt that the current indicators are having the effect of encouraging easy fi les to be processed fi rst as one strategy for meeting performance targets, and therefore a more comprehensive framework for managing work be made visible that balances quality and speed of service performance indicators is warranted.

Cost EffectivenessThe cost effectiveness of program administration and delivery could not be assessed because substantial changes in the mode of delivery during the study period (1997 to 2007) made it diffi cult to make meaningful comparisons of cost data over time. However, qualitative information from program data and other sources indicated the major cost areas were administrative, adjudication, appeals and communications.

Comparing the CPPD Pension to those of national disability programs in four other countries (United States, Netherlands, United Kingdom, Australia) suggested that the program delivery cost of the CPPD Pension is relatively low and the program is cost effective.

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Summative Evaluation of the Canada Pension Plan Disability Program v

Management Response

IntroductionCanada Pension Plan Disability (CPPD) is the largest federal income security program for working-age persons with disabilities and Canada’s largest public disability insurance program. A Summative Evaluation, undertaken from 2007-2010, assessed the following aspects of the program for the 1997-2007 period: continued relevance; achievement of objectives; impacts and effects; cost-effectiveness and program delivery.

The Department of Human Resources and Skills Development Canada (HRSDC), which includes Service Canada, agrees with all of the report’s six recommendations and is pleased to present the following management response. As the fi rst major examination of CPPD in almost 15 years, this evaluation is integral to ensuring the program remains as relevant and responsive to the needs of working-age Canadians as possible.

HRSDC would like to recognize the signifi cant work required to undertake an evaluation of this magnitude and thank everyone who participated. We look forward to collaborating with our key partners (internal and external) as we work to advance these recommendations. In particular, we would like to thank applicants and benefi ciaries, physicians, HRSDC staff and offi cials from other government departments who generously shared their insights and experience to help inform this process.

Key FindingsOverall, the evaluation found that the CPPD program remains as relevant today as it was at inception. Disability that affects work capacity continues to be a key risk faced by working-age Canadians and public disability insurance remains an equitable and economically effi cient way of addressing this risk.

Over the years, the population served by the program has changed. Current benefi ciaries tend to be older with 55 percent in the 55-64 age group in 2006. They are also more likely to be female; women comprised 50.7 percent of the caseload in 2006 compared to 42.9 percent in 1996 due to their rising levels of labour market participation. Medical conditions have also changed and the largest disability categories are currently mental health issues, musculoskeletal conditions and neoplasms.

Yet the objective of the CPPD program has not changed: CPPD aims to provide a basic level of earnings replacement for contributors and their families when an individual can no longer work because of a severe and prolonged disability. The majority of workers who contribute to the CPP (about two-thirds) would meet the disability contributory eligibility requirements. However, the evaluation points out that this proportion (68 percent in 2005) is signifi cantly lower than the peak of 78 percent in 1997. Each year of the study period, CPPD

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vi Summative Evaluation of the Canada Pension Plan Disability Program

paid approximately $3.5 billion in benefi ts to almost 300,000 benefi ciaries, representing between 15 and 32 percent of all Canadians with severe disabilities (depending on the survey).

The receipt of CPPD has a positive impact on benefi ciaries’ incomes. On average, benefi ts comprise about 50 percent of benefi ciaries’ income, while 12 percent of benefi ciaries report it as their only income source. In the absence of CPPD, the prevalence of low-income among benefi ciaries would be almost double the current rate. CPPD also contributes to quality of life; in a survey of clients, 72 percent reported that receipt of the CPPD benefi t enables them to live independently while 50 percent reported it enables them to live actively.

In terms of areas for improvement, the evaluation identifi es disability determination as a challenging task for any national program, and one that warrants ongoing consideration to ensure consistency of decision-making across regions and over time. It notes that Canada can continue to learn from the experiences of other countries with publicly-funded long-term disability programs. It also raises concerns with the complexity applicants can experience in applying for benefi ts and suggests more be done to understand their experiences in order to improve program design and delivery. The evaluation also urges offi cials to explore options that maximize access to employment resources and services for both granted and denied clients in order to support their return-to-work efforts. The evaluation concludes with six recommendations that require action on the part of management in the areas of quality assurance, service delivery, and working with key partners and, it identifi es areas for further study. The recommendations and areas for study, as well as the departmental response, are outlined below.

RecommendationsDefi ne, Develop and Implement a Quality Assurance Framework

HRSDC agrees with this recommendation.

The evaluation affi rms that CPPD has maintained a high degree of stability in applying its medical eligibility criteria over time. Yet it also recognizes that determining whether an applicant’s particular disability meets the legislative defi nition of severe and prolonged is a challenging and complex process. While progress has been made in recent years to improve the clarity and transparency of this process, HRSDC concurs that more remains to be done to demonstrate that sustainable decisions are being made in a timely, and consistent manner.

Overall, HRSDC recognizes performance management as an essential component of organizational success and is committed to measuring performance, managing for results and reporting on progress. While the Department has established a strong performance measurement framework in recent years, it continues to be reviewed and strengthened as part of ongoing program improvement efforts. The performance measurement framework for CPPD is an integral part of this work.

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Summative Evaluation of the Canada Pension Plan Disability Program vii

Going forward, CPPD will ensure an appropriate mix of indicators for assessing timeliness (e.g. speed-of-service) as well as the quality of decision-making. These efforts will be part of the Department’s broader work to modernize Canada Pension Plan (CPP) and Old Age Security (OAS) service delivery. This multi-year modernization process will develop and implement a comprehensive strategy of service delivery improvement with a focus on achieving service excellence. As this strategy is developed, the Department will identify and report on its components.

As HRSDC works to develop an overarching quality assurance framework for the CPPD program, the tools that support disability determination including the CPP Disability Adjudication Framework will be key components. Developed in response to the last CPPD evaluation, the Adjudication Framework is a comprehensive package of policies and reference tools that supports CPPD medical adjudicators with the process of disability determination. Based on CPP’s legislation, this Framework lays out the set of criteria against which applications are assessed. The Framework is supported by a number of policies and reference tools on particular conditions (e.g. chronic pain, fi bromyalgia and multiple chemical sensitivities).

To support CPP modernization, work began in the fall 2010 to review the Framework in order to identify areas for improvement; this work will involve medical experts and stakeholders. An initial consultation with a key group of stakeholders took place in November 2010 and further consultations with health professionals and stakeholders will be undertaken as work proceeds. Additional research is also planned to better understand existing domestic and international best practices in this area. It is anticipated that this work will lead to a renewal of the supports to adjudication, including the Framework. As this work advances, the Department will provide updates to stakeholders and report on progress.

In addition to the Adjudication Framework and policies/reference tools on specifi c conditions, HRSDC recognizes that further support could be provided to ensure that advances in medical knowledge related to disability are provided to CPPD staff involved in disability determination. Therefore, over the last two years, the Medical Expertise Division of CPPD Directorate has developed and offered staff in headquarters and regions a number of knowledge seminars on specifi c conditions. These learning events will continue and the Directorate will continue to build on this knowledge-sharing by offering more such seminars. The Department will also investigate best practices, domestically and internationally, to determine other mechanisms for sharing the latest medical knowledge, updating existing tools and developing additional tools to support disability determination.

The Application Process Could be Reviewed and Simplifi ed

Consider a two-step application process.

HRSDC agrees with this recommendation.

Under the legislation, CPPD eligibility has two components – contributory and disability. To meet contributory eligibility, applicants must have recent attachment to the workforce as signifi ed by a minimum level of CPP contributions in four of the last six years (or three

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viii Summative Evaluation of the Canada Pension Plan Disability Program

of the last six years for long-term contributors who have contributed for at least 25 years). In terms of eligibility related to disability, applicants must demonstrate a severe and prolonged disability as defi ned in the CPP legislation. “Severe” refers to being incapable regularly of pursuing any substantially gainful occupation while “prolonged” indicates the disability is long lasting and of indefi nite duration, or is likely to result in death.

Assessing contributory eligibility is a relatively straightforward process in contrast to the complexities of determining whether the applicant’s medical condition meets the legislated requirements for a severe and prolonged disability. The key issue is in relation to the impact of the medical condition on the individual’s capability, on a regular basis, to work at any substantially gainful employment. While the majority of CPPD applications received in a year (around 60,000) meet contributory requirements, just over 5,000 applicants do not have suffi cient earnings and contributions. Nonetheless, under the current process, medical information is required for all applicants – whether or not they meet the contributory requirements. For this reason, consideration of a staged process, in which contributory eligibility is assessed before medical information is requested, is an area the Department is actively exploring.

A staged application process would contribute to CPPD’s overarching goal of a more streamlined, client-centred application process which asks the right questions at the right time and minimizes the burden on applicants and the medical community. For this reason, the Department is investigating how best to accomplish this without adding another layer to the application process. A number of alternate approaches have been conducted in the regions that will contribute to knowledge gathering in this area. It is anticipated that the Department will be in a position to undertake additional alternate approaches in the next year, with a view to broader implementation of successful options.

Consider testing approaches for making the application more user-friendly

HRSDC agrees with this recommendation.

HRSDC is committed to ongoing improvement of service delivery in all programs, including CPPD, to ensure a more client-centred approach and achieve service excellence. In this context, the Department is currently exploring several approaches to make the CPPD application process more user-friendly. Early deliverables could include shortening the application form and providing revised and updated communications products to applicants so that the eligibility requirements (and documentation required) are more easily understood. In the longer-term, the Department plans to make greater use of technology and e-services as part of its commitment to developing comprehensive cross-channel approaches to service delivery that respond to the changing needs of individual Canadians. It is anticipated this will result in moving away from an entirely paper-based system.

To respond to the challenges of a particular client group, over the last three years, Service Canada has tested a shortened application form, supported by an outreach process, for gravely ill applicants in the Atlantic region. This shortened application has been well received by applicants, medical professionals and Service Canada staff, and won a 2010 Deputy

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Summative Evaluation of the Canada Pension Plan Disability Program ix

Minister’s Award for Program Design and Delivery. As work progresses on making the CPPD application more user-friendly, we plan to build upon this project and develop additional alternative approaches in order to provide a strong evidence base for program change.

The Department will explore other promising approaches to create a more client-centred approach, and will use information received from clients as part of the evaluation as well as continued contact with clients and key stakeholders to inform this work.

Consider how best to collaborate/coordinate with other programs

HRSDC agrees with this recommendation.

CPPD complements other measures which provide support to persons with disabilities (i.e. tax support and benefi ts, earning replacement and income support programs). HRSDC acknowledges the need to continue to collaborate with these programs with a view to exploring areas of common interest. For example, a new fi ve-year agreement was recently signed between the Minister of HRSDC and 41 private disability insurance companies with the goal of continuing to streamline service to mutual clients. In addition, work continues with the provinces and territories under the auspices of the Deputy Ministers of Social Services Forum to explore issues of common interest, including achieving an improved understanding of existing supports and services for persons with disabilities.

Nonetheless, the Department acknowledges that specifi c disability programs, benefi ts and services in Canada each has its own objectives (often legislated) and target population, and therefore, defi nes its parameters accordingly. While recognizing the importance of these existing defi nitions and program parameters, we will look for opportunities to collaborate wherever possible. For example, we will continue our work with insurers to explore other opportunities for effi ciencies, with the provinces and territories and the Canada Revenue Agency (CRA).

Enhance partnership with physicians

HRSDC agrees with this recommendation.

Physicians play a key role in the CPPD application process. In fact, the evaluation found that physicians are a key information source for most applicants when it comes to the CPPD program. The Department recognizes the need to continue to improve communications with physicians in order to provide them with up to date information on CPPD benefi ts and to work to minimize the administrative burden when it comes to the completion of required medical reports.

Over the past two years, steps have been taken to enhance the relationship with the medical community through ongoing contact with the Canadian Medical Association (CMA). This collaboration has led to several outcomes including: the formation of an HRSDC-CMA senior executive information-sharing forum; the creation of a CPPD communications strategy for CMA members, and the updating of the CPPD Physicians Guide.

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x Summative Evaluation of the Canada Pension Plan Disability Program

To further enhance communication, HRSDC recently developed a Web Portal for Health Care Professionals. This reference tool, launched in February 2009, assists health care professionals to better understand the requirements of CPPD and other federal disability programs, including the medical certifi cates/reports that may need to be completed on applicants’ behalf. To make this resource as effective as possible, focus groups were held with physicians, nurses, and occupational therapists in 2010. Respondents indicated that they found the information to be useful, but also suggested that ways be found to improve navigation to the site. The Department is actively pursuing this work.

To address the administrative burden presented by CPPD application forms, HRSDC is taking action on several fronts. In the short term, the fee paid to physicians who complete CPPD applications was increased by 30 percent from $65 to $85 as of 2010. In the longer term, the program will continue to examine the potential to gather medical information in a more targeted manner and explore whether other effi ciencies are possible (e.g., electronic information exchange) and utilizing medical information previously provided to other disability programs, although privacy considerations must remain paramount as these avenues are explored. The Department will also consult with health professionals in the renewal of tools to support disability determination and other areas of modernization.

Examine Return-to-Work Supports

HRSDC agrees with this recommendation.

There is a global consensus on the need for removing work disincentives and promoting active return-to-work measures for persons with disabilities in order to improve economic security, promote social inclusion and integration, and contribute to Canada’s productivity. HRSDC is committed to ensuring that CPPD applicants are provided with information on existing supports and services to support their efforts to join the labour force or return to work. The Department is also committed to ensuring that those clients who have expressed an interest in returning to work have access to information on supports within the CPPD program, including vocational supports.

As noted in the evaluation, Service Canada representatives regularly provide information and referrals to denied clients in order to advise them of the services and supports to which they may be eligible. This is integral to Service Canada’s mandate of providing Canadians with easy access to a full range of government programs and services in a reliable, convenient and cost effective manner.

These existing referral services will be improved through Service Canada’s evolving Client Segment Strategy for Persons with Disabilities. This strategy assesses the diverse needs of persons with disabilities in order to provide the most relevant and effective service offerings. This approach often entails “bundling”, that is providing information on the spectrum of employment-related programs and services available to people with disabilities whether they are provided by HRSDC, other federal departments, other levels of government or the not-for-profi t or private sector.

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Summative Evaluation of the Canada Pension Plan Disability Program xi

HRSDC is also working to improve and enhance existing CPPD return-to-work supports, including ensuring more clients with rehabilitation potential are accepted into the Vocational Rehabilitation (VR) Program. The Department will continue, as well, to examine the effectiveness of other initiatives to reduce disincentives to work (e.g. work trial, automatic reinstatement) with a view to helping clients who regain work capacity to return to the workforce for as long as they are able. The Department recognizes that disability can be dynamic and, over time, some benefi ciaries may experience improvements in their health that could enable a gradual return to the workforce with appropriate supports. Training for Service Canada staff on a strength-based approach to vocational assessment will be launched in spring 2011.

Areas for Further Study

The evaluation suggests that further research be undertaken to understand the circumstances and reasons why a large percentage of denied clients are not working in the years following denial. The information needed to understand this issue is currently not available as the survey undertaken for the evaluation did not allow for such analysis. The Department agrees that this is an important knowledge gap and will undertake further research in this area.

In addition, the Department will undertake analysis into the characteristics of clients in the appeal system and the role of new information in this process. We also agree on the importance of further analyzing the issues of program delivery costs, benefi t coverage, and the assessment of eligibility by disability type and will undertake further research and policy work in each area.

In closing, the Department is committed to continuous improvement of CPPD’s design and delivery in order to ensure that it responds to the needs of Canadians while ensuring administrative effi ciency, effectiveness for clients and consistency with our role as stewards for this important national program.

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Summative Evaluation of the Canada Pension Plan Disability Program 1

1. IntroductionThis report provides the fi rst full-scale summative evaluation of Canada Pension Plan Disability (CPPD) program since 1996. It is a synthesis of over 20 technical reports conducted over the period from 2007 to 2010. The fi eld of supports for workers with disabilities is vast and complex. This report refl ects a summary of what is known about program effectiveness and delivery at the time the report was written, as many questions admittedly still remained unanswered.

1.1 Evaluation Scope and MethodologyAs is the case with any formal program evaluation, the work was organized around a set of questions1 that were approved by an advisory committee in March 2007. The technical reports designed to answer these questions cover the period from 1997 to 2007, which corresponds to the ten-year time period since the previous evaluation of the CPPD Pension. These evaluation questions were developed in consultation with the program area, the Treasury Board Secretariat and other central agencies. The fi nal list is extensive and is included in Annex I of this report. This report summarizes what was learned from this process. It should be noted that there is much valuable information in the supporting technical reports.

The evaluation was undertaken at the same time that the Organisation for Economic Co-operation and Development (OECD) was preparing a major review of government involvement in the area of disabilities. Although the work for this evaluation was conducted independently of the work done by the OECD, the OECD work did have its infl uence at the planning stages of the project. As a result, the HRSDC evaluation focuses more on the program operational aspects.

This fi nal report presents a synthesis of over 20 technical reports. A mixed-method evaluation design, including both quantitative and qualitative evaluation methods, was used to inform the different evaluation questions. The range of methods used by the technical reports include qualitative analysis such as a document and literature review, case studies, a survey, focus groups, and key informant interviews, as well as quantitative analysis using data from CPPD administrative data, Canada Revenue Agency income tax data, Statistics Canada survey data and administrative databases. In synthesizing the technical reports, this fi nal report places particular emphasis on drawing from multiple lines of evidence to corroborate and explore the main fi ndings for each of the evaluation questions. The evaluation process also benefi ted from the valuable support and cooperation of the program area.

1 It is worth noting that the structure of the questions was based on the Treasury Board Policy on Evaluation in force at the time. Where possible attempts have been made to shift the emphasis in the direction of the 2009 policy.

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2 Summative Evaluation of the Canada Pension Plan Disability Program

1.2 Some General Cautions and LimitationsWhen interpreting the fi ndings and conclusions presented in this report, readers should bear in mind some general cautions. It should be kept in mind that the period of analysis (1997 to 2007) covered a period of years when the program and delivery process went through many reorganizations, and this presented challenges for this evaluation process. For example, for a precise assessment of program effi ciency, it is diffi cult to make meaningful comparisons of cost data over time. Also, as Quebec administers its own program, the totals included in most tables will only include the nine provinces and the territories. In addition, as the income tax data from the Canada Revenue Agency is used to derive information on earnings and incomes, most annual data is on a calendar year basis rather than the usual government fi scal year basis.

1.3 Organization of the ReportThe second chapter starts the report with a description of the program from many different perspectives. This description ranges from the operational to the theoretical. Particular attention is given to the description of program objectives as they provide the metric by which program performance can be judged: the subject of the third chapter. The fourth chapter goes into the impacts and effects of the program. This section suggests that the disincentives to work appear to be less prominent than many other discourses on the subject have indicated and that the impact on poverty reduction is signifi cant. The fi nal major section discusses issues surrounding program delivery. The report ends with a set of recommendations. It is also important to note that many complex issues are only briefl y touched upon and suggestions for further research are provided at the end of the report.

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Summative Evaluation of the Canada Pension Plan Disability Program 3

2. Description of the CPPD Pension Introduced in 1966, the Canada Pension Plan (CPP) is based on contributions from workers and employers. It operates in nine provinces and the territories while the Quebec Pension Plan (QPP), a parallel plan, operates in Quebec. The CPP is best known for its retirement pension, but also provides survivor, death and disability benefi ts to CPP contributors and their families.

The 1964 White Paper on the Canada Pension Plan envisages the CPP as a compulsory and contributory social insurance scheme that will provide working Canadians, including the self-employed, and their families with “reasonable minimum levels of income available at normal retirement ages, and to people who become disabled, and to the dependents of people who die”. It describes “disability pensions” under the general heading “supplementary pensions” and states such pensions have to “meet situations that are fundamentally different from retirement pensions.”2

CPPD provides income security to individuals and families in cases where a contributor experiences a severe and prolonged disability that renders the person incapable regularly of pursuing any substantially gainful occupation. The person must be determined to be disabled at the time they last made suffi cient contributions to the CPP.

CPPD has become the single largest public long-term disability insurance program in Canada. Based on statistics between 1997 and 2007, annually about 60,000 new applications were received, and about 300,000 benefi ciaries received approximately 3.5 billion dollars in CPPD pension.3

There are a large number of other public and private programs which provide complementary benefi ts for persons with disabilities, such as Workers’ Compensation Boards, Social Assistance, private long-term disability insurance, Employment Insurance Sickness Benefi t, and auto accident insurance.

2.1 CPPD EligibilityAs defi ned by CPPD legislation, the program provides social insurance protection to its contributors throughout their working years in the event of a disability that prevents a person from pursuing any substantially gainful employment. It is not a universal plan, as is the case with Old Age Security, but is limited to labour market participants who meet the contributory requirements and the medical criteria.

There are important issues involved in defi ning labour market attachment and disability. The extent to which these issues are addressed determines the degree to which the program objectives are met. The mechanics of determining suffi cient labour market attachment are

2 Department of Health and Welfare (1964), p.15. 3 For more details on trends in applicants, benefi ciaries and program expenditure, see Section 2.6 “Program Activity”.

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4 Summative Evaluation of the Canada Pension Plan Disability Program

discussed in detail in Section 3.1.2. This is important as attachment is defi ned in terms of years of contributions above a certain minimum. Thus at any point in time, a certain percentage of contributors are not eligible for benefi ts as they are recent entrants or they have been detached from the workforce. The challenges in defi ning disability run throughout the report but are highlighted in Section 3.1.1.2, where a wide range of estimates are given from major surveys.

2.2 CPPD PensionA monthly CPPD pension is provided to individuals who are eligible, apply for, and have their applications approved. The amount of the benefi t is the sum of a fl at rate and a component which varies with the applicant’s insurable income. The fl at monthly rate was set at $405.96 in 2007. The income-related component is 18.7 percent of insurable earnings,4 which is 75 percent of the rate used for the retirement pension. A monthly benefi t is also available to benefi ciaries’ children who are under age 18 or ages 18 to 25 and attending school full time. The CPPD pension is indexed to the Consumer Price Index and is revised every year to refl ect infl ation.

In 2007, the maximum monthly payment was $1,053.77, and the maximum monthly benefi t for children of those who qualify for CPPD was $204.68 per child. The maximum actual annual amount of CPPD pension paid was $12,645.

2.3 CPPD’s Main Features CPPD has a number of salient features that have been stable throughout its history:• Inclusiveness – no Canadian worker is excluded because of her or his former medical

history as is normally the case with private insurance schemes;• Contributory – it is a contributory program and to be eligible for disability benefi t, the

individual must meet a minimum contributory requirement;• Non-risk based premium – the CPP premium is invariant with respect to medical risk; • Continuing coverage – the program provides coverage until improvement of the

disability,5 retirement or death;• Children benefi ts – a monthly benefi t is also available to benefi ciaries’ children who are

under age 18 (and also for children between the ages 18 to 25 if attending school full time); and

• Appeals – applicants have the right to appeal a decision at two successive levels: the Offi ce of the Commissioner of Review Tribunals and the Pension Appeals Board.

4 Insurable earnings include amounts reported on an earnings statement, or wage slip before any deductions are made for income tax, Employment Insurance, Canada Pension Plan, health care plans, loan payments, union dues.

5 An assessment is required to determine whether the disability has stabilized and/or whether there has been an adaptation to and/or improvement in the disability which has resulted in an increased regular capacity for work.

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Summative Evaluation of the Canada Pension Plan Disability Program 5

As summarized below, administration of the CPPD Pension has been enhanced over the years through initiatives such as the introduction of a return to work incentive, automatic re-instatement, child rearing provision, credit-splitting, and late-application provisions.

Late application provision – As long as a person had enough years of valid CPP contributions when he or she claims their disability began, and as long as the person is considered to be continuously disabled from that date up to the date the claim is adjudicated, he or she may be eligible for CPPD as described in Bill C-57 (Subparagraph 44(1)(b)(ii) of the Canada Pension Plan Act), even if the person did not initially apply.

Return to work initiative – CPPD supports benefi ciaries to return to work through a variety of measures such as:• allowing benefi ciaries to volunteer or attend school with no impact on their benefi ts;• permitting benefi ciaries to earn up to $4,300 in 2007 without having to report this amount

to the CPP (this amount is indexed to the Consumer Price Index and adjusted annually); • providing a paid work trial that allows CPPD clients to continue receiving benefi ts for

three months while working; and• providing vocational rehabilitation services and return-to-work supports to help clients

achieve their return-to-work goals.

Automatic reinstatement – Automatic reinstatement provides an extended entitlement to CPPD benefi ciaries who try to return to work. If the same or a related disability reoccurs within two years of returning to work and prevents them from staying at work, the CPPD pension can be reinstated without going through the usual reapplication process. There is no limit to how many times a reinstatement of benefi ts can be requested, providing all the requirements associated with automatic reinstatement are met. The children’s benefi ts will also be reinstated if the children are still eligible.

Fast-track reapplication – The fast-track reapplication process is designed to support applicants who do not meet the timelines or criteria associated with the automatic reinstatement provision. This simpler, faster application process is available for up to fi ve years from the date benefi ts are ceased, and the applicant must reapply within on year of stopping work. However, earnings and contribution requirements must be met as a precondition for qualifying and the disability must be due to the reoccurrence of the same or a related disability.

Credit splitting – When a relationship ends, the CPP credits that the couple built up during the time they lived together can be divided equally between them. The program permits the credits to be split even if one spouse or common-law partner did not pay into the CPP.

Child rearing provision – If a contributor has no or low earnings while caring for a child under the age of seven, these periods of time can be excluded from the calculation of the contributor’s benefi t. This provision could help a contributor qualify for a CPPD pension or increase the amount of pension received.

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6 Summative Evaluation of the Canada Pension Plan Disability Program

2.4 Rationale for the Program

2.4.1 Legislative PerspectiveA set of White Papers in July 1963, March 1964, and August 1964 laid the foundation for the introduction of the CPP. CPP was established in January 1966 by an act of Parliament (Bill C-136, titled “Act to Establish a Comprehensive Program of Old Age Pensions and Supplementary Benefi ts”). The fi rst disability benefi t was paid in 1970.

Since the introduction of this pension, CPP and its component benefi t CPPD have undergone a number of legislative changes. For example, in the 1970s, provisions for children’s benefi ts were augmented and child rearing was taken into account in calculating the contributory period; the 1980s witnessed further refi nement and extension of the CPP/CPPD legislation; and in the 1990s, changes were made to eligibility requirements.6

2.4.2 Theoretical PerspectiveThere are numerous academic studies that provide theoretical justifi cations and the rationale for public disability insurance regimes such as CPPD. These studies emphasize that in addition to long-term disability insurance run by private sector insurance companies, the government should play an important role in providing disability insurance.7

2.4.2.1 Equity

Equity is a cornerstone of public disability insurance programs. Individual premiums under public disability programs are not risk based, making such a program more affordable for those at lower income levels. Public disability programs do not discriminate against individuals on the basis of their risk history and profi le making them more socially equitable than their private sector counterparts.

The increasing participation of women in the labour force and fi ne tuning of the program with the inclusion of a child rearing provision have led to women comprising an increasing share of the CPPD applicants and benefi ciaries over the evaluation period.8 As a result the CPPD gender gap has largely closed over the evaluation period and this has enhanced the equity aspect of CPPD.

2.4.2.2 Effi ciency

When private disability insurance premiums are based on the average risk of the population, those with low risk are less likely to purchase insurance while those with high risk will strive to do so. As a consequence, the increased risk among the insured population will

6 For a list of major legislative changes and changes in eligibility criteria, see Annex II.7 For references regarding equity, effi ciency, and public good, see Aarts and Jong (1992) and Maki (1993). 8 Data Probe, (HRSDC 2010), p.19.

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Summative Evaluation of the Canada Pension Plan Disability Program 7

drive up the price of insurance. This is technically described as “market failure due to adverse selection”. Adverse selection will lead many workers to under-insure against the risk of earnings loss due to long-term disability.

A public disability insurance program can make everyone better off by requiring the purchase of insurance that refl ects the average risk in the population. A mandatory and larger insured population with diverse composition means a lower overall long-term disability risk for the average person in the insurance pool, leading to a lower premium rate than what would be possible for a self-selected smaller pool of covered individuals. Administering a program with a large insured population also results in economies of scale in administrative functions, thus further reducing the cost of program administration. This is another rationale for public disability insurance programs, based on effi ciency.

Arguments have been put forward that programs like CPPD can also adversely impact effi ciency. Some of these arguments make reference to “behavioural effects”. If individuals do not pay risk based premiums, the argument goes, this may encourage them to engage in more risky behaviours leading to a higher level of social insurance and more reliance on the social insurance than would happen in the absence of the program.

2.4.2.3 Public Good

In addition to individuals, the community at large can benefi t from public disability programs due to externalities. Under public disability programs such as CPPD, a large segment of the working population provides for its own earnings-protection under compulsory insurance coverage. The entire society can benefi t from such a program. It helps reduce cost of externalities such as homelessness, social assistance, and health care that can arise due to the collapsed earning ability of uninsured individuals when they became severely disabled. This can be described as a public or collective good, and is another rationale for a program like CPPD.

2.4.2.4 International Standards

Almost all developed economies provide their citizens with disabilities with some form of long-term disability benefi t. However, there are differences among nations in eligibility criteria, coverage, benefi t levels, tax treatment of benefi ts, and the funding mechanisms for disability income support programs. While many industrialised countries have models similar to CPPD, some countries such as Australia, operate programs based on welfare principles. These programs usually provide universal coverage, but payments are means-tested and benefi t levels are relatively low.9

9 Rideau Strategy Consultants Ltd. (HRSDC 2008a), Section 4.

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8 Summative Evaluation of the Canada Pension Plan Disability Program

2.4.3 CPPD as First PayerThe concept of CPPD as “fi rst payer” is consistent with the original intent of the CPP, which was to take into account CPP’s relationship with other payers, including private insurers, to be one component of a multi-tiered pension system.

The CPPD is generally viewed as the “fi rst payer” by most private long-term disability insurance plans, which means that other insurance plans may take CPPD pension into account when calculating a claimant’s entitlement to benefi ts but not the other way around. This is based on a presumption resulting from how CPP is calculated rather than any statute, agreement, or guideline as pointed out by the Auditor General in his 1996 report:

“The Canada Pension Plan contains no provision concerning the treatment of disability benefi ts from other sources, other than provisions allowing for reimbursement of advances paid by other plans. As other programs’ benefi ts are not taken into account, this makes the Plan a fi rst payer.”10

Complementarity of CPPD and other long-term disability benefi ts is at the heart of the discussion of CPPD as “fi rst payer”. The CPP Act permits coordination of benefi ts between public and private insurance; and provides for the assignment of a one-time retroactive lump sum payment of disability benefi ts to government agencies and insurance companies under agreements in which a person is found to be eligible for both CPP benefi ts and private insurance and the plans are integrated.11 Under these agreements the CPPD pension is paid in advance to the person by the insurance company, which is then reimbursed by the CPPD Pension once the CPPD pension is payable.

The legislation, upon which provincial and territorial private insurance is based, sets out statutory conditions which form part of every insurance contract including long-term disability insurance. The uniform legislation contains provisions which allow for coordination of benefi ts between various income replacement programs.12

The coordination of CPPD and long-term disability insurance benefi ts limits the overall level of disability benefi ts available to claimants, reshapes the long-term disability insurance into indemnity contracts (that is, into contracts that require proof of actual loss rather than just occurrence of the event) and helps maintain quasi-universality of CPPD coverage rather than turning it into a “second payer” residual program.

While initially most workers’ compensation programs were fi rst payers, an increasing number of provinces have harmonized their workers’ compensation programs with CPPD over time. For instance, Ontario’s workers’ compensation legislation, “the Workplace Safety

10 Offi ce of the Auditor General of Canada (1996), paragraph 17.132.11 Canada Pension Plan Act, section 65(3) and section 76.1 of the Regulations.12 For example, Condition 4 under section 300 of the Insurance Act of Ontario provides for the partial coordination of

benefi ts where an insured is entitled to benefi ts under more than one contract of disability insurance.

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Summative Evaluation of the Canada Pension Plan Disability Program 9

and Insurance Act, 1997”13 that is currently in effect takes the CPP disability payments into account in calculating payments for loss of earnings, and as a result it treats CPPD as the “fi rst payer.”

During key informant interviews, the representatives of long-term disability insurance companies suggested that in the absence of the CPPD as the fi rst payer and without the coordination of CPPD and long-term disability insurance, their insurance premiums would be higher.14

2.4.4 Interaction with Employment InsuranceAn individual losing their job due to disability will fi rst become eligible for employment insurance under the sickness benefi t provision if they meet the eligibility requirements. Recognising that the two programs have different policy objectives, the eligibility requirements for employment insurance are less stringent than CPPD. It may often be the case that CPPD benefi ciaries will fi rst receive sickness benefi t from employment insurance which can be received for a maximum of 15 weeks, at which point these benefi ts are exhausted. After exhausting employment insurance benefi ts, the applicant may turn to CPPD.15

2.4.5 Program RelevanceIn summary, the CPPD continues to remain as relevant today as it was some forty years ago. As discussed above, economic effi ciency and equity considerations, as well as an aging population with its rising prevalence of disability, all point to the continued relevance of CPPD.

2.5 Program ObjectiveAs is the case with many programs, evaluators must have a statement of the objectives of a program to be able to form judgements about program success. This is not always straightforward, especially in the case of large, mature programs that are often described differently in different contexts, as is the case for CPPD. Hence for the purposes of the evaluation, program objectives are stated drawing on a number of different sources:• One source for defi ning the program objective is the enabling legislation. Unfortunately,

however, the CPPD objectives were not explicitly stated in the CPP legislation. A body of case law over the years has contributed to understanding of the CPPD as a distinct social insurance program providing partial income replacement, and focused on assisting eligible contributors who are incapable regularly of pursuing any substantially gainful occupation. However, case law has focused primarily on enhancing the understanding

13 Workplace Safety and Insurance Act (1997), S.O. 1997, c. 16, Schedule A.14 Rideau Strategy Consultants Ltd. (HRSDC 2008b), p.4.15 HRSDC, 2010, p.45.

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10 Summative Evaluation of the Canada Pension Plan Disability Program

of CPPD as a component of an array of public and private income security programs: somewhat different from the evaluation’s need for a clear and fully descriptive program objective.

• The August 1964 CPP White Paper portrays CPP as a compulsory social insurance scheme enacted to provide contributors and their families with “reasonable minimum levels of income available at normal retirement ages, and to people who become disabled, and to the dependents of people who die”. It describes “disability pensions” under the general heading “supplementary pensions”. It states that supplementary pensions have to “meet situations that are fundamentally different from retirement pensions” and that the CPPD was not intended to replace all income lost as a result of disability, but rather to contribute to a mixed system of income replacement.

• Finally, the program logic model (as presented in the Draft Canada Pension Plan Disability Performance Measurement Framework, last updated in February 2008) lists the long-term objective of CPPD as “Social and Economic Inclusion of Persons with Disabilities in Canadian Society”.

These sources taken together suggest a complex set of objectives that can be summarized in the following statement of purpose that was used for this evaluation exercise:

CPPD provides a basic level of earnings replacement for contributors and their families in cases where an individual cannot work because of a disability that is both severe and prolonged (as defi ned by the CPP legislation).

2.6 Program Activity

2.6.1 Applicants and Benefi ciaries2.6.1.1 Trends in Applicants and Benefi ciaries

During 1997-2007, some 676,000 individuals applied for CPPD pension, while another 150,000 requested reconsideration of their initial applications. Over 290,000 individuals received CPPD pension each year during this period (Table 2.1). Benefi ts for nearly 340,000 individuals were terminated over the same period due to death (29 percent), return to work (7 percent) and turning 65 (64 percent).

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Summative Evaluation of the Canada Pension Plan Disability Program 11

Table 2.1Stock and Flow of CPPD Benefi ciaries

Year

No. of Benefi ciaries

(annual average)No. of Initial applications

No. of Reconsideration

applicationsNo. of

Terminations1995 298,698 91,034 17,522 34,7151996 298,966 79,778 21,307 35,0321997 292,389 67,898 19,977 34,1061998* 287,740 68,895 18,675 32,6311999 287,709 58,619 16,434 31,8182000 283,508 56,802 13,051 31,4062001 279,352 55,625 12,575 29,8802002 281,263 57,010 11,837 29,2152003 286,717 58,762 10,907 29,4942004 290,557 61,531 10,384 29,5952005 294,537 62,962 11,965 29,8712006 302,288 64,453 13,082 30,2872007 306,686 63,443 11,403 31,3621997-2007 290,250 61,455 13,663 30,879Sources: HRSDC, CPP-OAS 2009 Stats Book; DSB Monthly Reports* 1998 reforms (tightened contributory eligibility requirements)

On average, over the eleven-year period of 1997-2007, annually 290,000 CPP contributors received CPPD pension. About 2.5 percent of the total CPP contributory population apply for and receive disability benefi ts.16

Over the same eleven-year period (1997-2007), on average, annually about 61,000 new applications (21 percent of the number of benefi ciaries) were received, 13,000 reconsideration applications (4.4 percent of benefi ciaries) were received, and 30,000 termination of benefi ts decisions (10.3 percent of benefi ciaries) were handed down.

In 1997, the number of benefi ciaries declined as compared with 1996 and 1995. In 1995 the program revised its medical determination guideline to ensure consistency in the determination of disability.

Bill C-2 came into effect in January 1998. The legislative provisions were designed to emphasize the importance of signifi cant and recent work activity (and hence contributions). In order to qualify for CPPD pension, this Bill made it necessary to have met minimum contribution requirements in four of the last six years when the person is determined to be disabled. That meant a tightening of the CPPD eligibility. Prior to 1998, the minimum contributory requirements were two of the last three years or fi ve of the last ten years.

16 For example, about 295,000 received CPPD benefi ts out of the total CPP contributory population of 12 million in 2005.

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12 Summative Evaluation of the Canada Pension Plan Disability Program

2.6.1.2 Profi le of CPPD Benefi ciaries

Gender – There is a noticeable increasing trend in the share of females among new benefi ciaries as well as among benefi ciaries as a whole. This in large part is due to the rising labour force participation of females. More women with disabilities are attaining suffi cient employment and are making suffi cient CPP contributions to qualify for and receive CPPD pension. For instance, whereas females accounted for only 42.9 percent of all benefi ciaries in 1996, they accounted for 50.7 percent by 2006, making the program more gender neutral (Table 2.2).

Age – The majority of the benefi ciaries are in the older age group of 55-64. For instance, in 2006, while more than 55 percent were in the age group 55-64, only 18 percent were in the age group 50-54.17 This is consistent with the fact that disability rates rise with age.

Income18 – CPPD benefi ciaries have a higher prevalence of low-income than non-benefi ciaries, 22 percent versus 15 percent.19

Marital status and family composition – Most CPPD benefi ciaries are married (over 60 percent). About 33 percent of applicants have children.

Type of disability – The largest disability categories of the applicants are disorders of the musculoskeletal conditions, mental health issues, neoplasms,20 and circulatory system.21 While there are not a lot of applicants with disorders of the respiratory or genital-urinary systems, their percentages have been rising in recent years. Rising trends in the number of applicants are also apparent for disabilities related to mental health. A recent OECD report on disability issues has also noted an increasing trend (regarding mental health conditions) in other countries.22

Benefi t duration – The overall mean duration of CPPD pension receipt by an individual is about 8 years.23 This duration varies considerably depending upon the medical condition underlying the disability.

17 HRSDC, CPP-OAS 2009 Stats Book, p.42.18 CPPD benefi ciaries are classifi ed as low-income if their after-tax family income is below the after-tax Low Income Cut-Off.19 Data Probe (HRSDC 2010), p.21.20 A neoplasm is a tumour or an abnormal growth of tissue. It can be benign (non-cancer), potentially malignant

(pre-cancer), or malignant (cancer).21 Gray and McDonald (HRSDC March 2010), p.39.22 OECD (2006-2010).23 Gray and McDonald (HRSDC March 2010), Table 14.

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Summative Evaluation of the Canada Pension Plan Disability Program 13

Table 2.2Females as a Percentage of CPPD Benefi ciaries 1996-2006

Year Females as % of New Benefi ciaries Females as % of All Benefi ciaries1996 45.7% 42.9%1997 46.3% 44.0%1998 47.4% 45.0%1999 47.5% 45.9%2000 48.2% 46.8%2001 48.3% 47.6%2002 48.5% 48.3%2003 48.3% 49.0%2004 49.6% 49.6%2005 50.2% 50.1%2006 50.0% 50.7%

Sources: CPP Master Benefi t File, Service Canada Reporting Database, CPP-OAS 2009 Stats Book

2.6.1.3 Application and Approval Rates

There has been a rising incidence of applications relative to the working age population in Canada. The application rate and approval rate also vary across provinces.24 Between 2001 and 2006, the average application rate (CPPD applicants relative to the working age population) for Canada was 0.110 percent. The highest rates were observed in Nova Scotia (0.136 percent), Newfoundland (0.122 percent), and Prince Edward Island (PEI) (0.118 percent), while the lowest were observed in Ontario and Saskatchewan (both at 0.095 percent). In terms of the approval rate during the same interval, there was a slight upward trend from 2001 to 2003, followed by a reversal in the following three years. The average approval rate for Canada was 56 percent over this period, with the highest observed in PEI (66 percent), Newfoundland (65 percent), and New Brunswick (63 percent), and the lowest observed in the Prairies (ranging from 45 percent to 51 percent).25

Between 2001 and 2006, the average approval rate at the initial stage of the application was 45 percent. Of the denied group, more than 80 percent were turned down for not meeting the CPPD medical requirements. Of the denied group of applicants at the fi rst round (55 percent), about 35 percent reapplied and of these 40 percent fi nally succeeded. However, very few cases arrived at the pension appeals board, which is the last stage of the appeals process.26

The application rate is found to be sensitive to labour market conditions. As unemployment rates increase in the general population, the application rates tend to rise. Adverse labour market shocks causing layoffs and reduced labour market opportunities (for lower-skilled workers) may encourage a growing fraction of displaced workers to withdraw from the

24 There are variations in disability rates across provinces and this may account for the observed differences in application and approval rates.

25 Ibid, p.11.26 Ibid, pp.13-14.

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14 Summative Evaluation of the Canada Pension Plan Disability Program

labour force and seek disability benefi ts. Economic regions that have relatively high unemployment rates also have relatively large CPPD application caseloads. This has been confi rmed by rigorous analysis using CPPD administrative data.27

2.6.2 CPPD PensionThe program benefi ts have increased in line with infl ation and the number of program benefi ciaries as shown in the following table. The growth in the number of benefi ciaries over 1997-2007 has been moderate at 1.4 percent annually. The overall amount of benefi ts provided to CPPD benefi ciaries rose from $2.5 billion in 1997 to $3.2 billion in 2007, an increase of about 2.2 percent per year. It is also noteworthy that dollar-value infl ation adjusted average benefi ts have fallen by 0.2 percent and that the gap between the maximum and the average benefi ts has widened to about $2,000, suggesting a possible change in the pre-disability income distribution of benefi ciaries.

Table 2.3CPPD Pension 1995-2007

Year

Net Benefi ts (Excluding Children Benefi ts)

Net Benefi ts including Children Benefi ts

Flat Rate Portion

of Benefi ts

Maximum Annual

Benefi ts

Average Annual

Benefi ts

Net Benefi ts, Annual change

1995 $2,542,395,309 $2,799,081,432 $3,838 $10,257 $8,512 -2.9%1996 $2,528,008,105 $2,778,842,256 $3,907 $10,451 $8,456 -0.6%1997 $2,523,837,274 $2,769,838,799 $3,966 $10,597 $8,632 -0.2%1998 $2,546,112,708 $2,793,049,647 $4,041 $10,744 $8,849 0.9%1999 $2,585,630,391 $2,835,251,589 $4,078 $10,843 $8,987 1.6%2000 $2,522,054,852 $2,760,394,159 $4,143 $11,009 $8,896 -2.5%2001 $2,567,202,847 $2,804,184,751 $4,246 $11,221 $9,190 1.8%2002 $2,699,012,376 $2,939,824,631 $4,374 $11,473 $9,596 5.1%2003 $2,793,711,907 $3,043,442,198 $4,444 $11,655 $9,744 3.5%2004 $2,881,347,096 $3,133,498,782 $4,586 $11,914 $9,917 3.1%2005 $3,060,238,515 $3,325,538,204 $4,664 $12,123 $10,390 6.2%2006 $3,147,969,341 $3,423,897,407 $4,771 $12,373 $10,414 2.9%2007 $3,190,586,444 $3,463,817,404 $4,872 $12,645 $10,403 1.4%2008 $3,384,570,183 $3,661,200,461 $4,969 $12,930 $10,911 6.1%Annual average change 1997-2007

2.2% 2.1% 1.9% 1.6% 1.7% 2.2%

Source: HRSDC, CPP-OAS 2009 Stats Book; DSB Monthly Reports.

27 Ibid, p.18.

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Summative Evaluation of the Canada Pension Plan Disability Program 15

2.7 Program Logic Model One method of describing a program is by means of what is known as a logic model. There are many possible approaches to this and the one that is most appropriate depends on the perspective of the evaluation. As this program was more operational in nature, a very detailed perspective was taken in the development of the logic model. In order to develop this model, a one day workshop was conducted at the program area with a world class expert in performance measurement. The logic model developed as a result of this workshop is presented in Annex III of the report. A practical outcome of this process is that the underlying trade-off between speed of application processing and the quality of results was not well articulated in the performance measures by which the program has been judged. This issue will be discussed in greater detail in Chapter 5 of this report.

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16 Summative Evaluation of the Canada Pension Plan Disability Program

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Summative Evaluation of the Canada Pension Plan Disability Program 17

3. Achievement of Program Objectives This chapter summarizes what is known about the extent to which the program has attained its objectives. It starts with a discussion of the degree to which the program reaches its target population and ends with an assessment of the adequacy of the amounts.

3.1 Are Those in Need Being Reached?As mentioned earlier, there are challenges relating to the defi nition of disability and the defi nition of attachment to the labour market. The fi rst section below addresses these defi nitional issues, whereas the second section presents related empirical evidence.

3.1.1 Disability Defi nitionThis subsection will fi rst establish the context by describing disability from the perspective of administering the program. The second subsection will review empirical evidence that is for the most part in the public domain and widely known.

3.1.1.1 Legislated Defi nition

The CPP legislation defi nes disability indirectly in Paragraph 42(2)(a) of the CPP Act by identifying the characteristics of a person it considers disabled as follows:

“A person shall be considered to be disabled only if he is determined in prescribed manner to have a severe and prolonged mental or physical disability, and for the purposes of this paragraph, (i) a disability is severe only if by reason thereof the person in respect of whom the determination is made is incapable regularly of pursuing any substantial gainful occupation, and (ii) a disability is prolonged only if it is determined in prescribed manner that the disability is likely to be long continued and of indefi nite duration or is likely to result in death.”

The Department’s framework for adjudication28 clarifi es this paragraph as follows: Severe – Person is incapable of regularly engaging in any substantially gainful activity, and that inability must be by reason of a medical condition. “Incapability to regularly engage in any substantial gainful activity” is judged by the adjudicator on performance, productivity and profi tability. The key indicator of “severity” is whether the medical condition makes the person incapable regularly of pursuing any substantially gainful employment, which is defi ned by performance and productivity, as well as a dollar income amount that is set annually.29

28 The Canada Pension Plan Disability Adjudication Framework, available online at http://www.hrsdc.gc.ca/eng/oas-cpp/cpp_disability/adjudframe/cppadjud.shtm

29 The substantially gainful amount is the maximum monthly CPP retirement pension. The annual amount is equal to twelve times the maximum monthly CPP retirement pension. CPP payment rates are adjusted every January.

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18 Summative Evaluation of the Canada Pension Plan Disability Program

Prolonged – “Prolonged” does not refer to past duration. It is only considered after the “severe” criterion is met. When the evidence is conclusive that the disability is likely to result in death in the near future and there is no work activity at the date of application that prolonged criterion is met. Otherwise, the physical or mental disability must meet the Department policy that if the disability is likely to prevent employment for more than one year it is generally considered to have met the “likelihood of long continued” criteria. To simultaneously meet the requirement of “indefi nite duration”, it must also be determined that there is an uncertainty with respect to the length of time a severe disability is expected to continue into the future, beyond one year.

A number of issues have been identifi ed by participants of qualitative studies undertaken for this evaluation. It was believed that “severity” should focus on inability to do one’s own job, not any job.30 Some also raised concern about exclusion of waiting time and the treatment period in a determination of “prolonged”.31 Federal and external stakeholders expressed the concern that a gap may exists in the current criteria in regard to people with episodic disabilities.32 The gradual onset of disability was seen as another problem area.33 Furthermore, both the CPPD applicants and health care professionals questioned the incongruence of the “prolonged” criterion and the “return to work” initiative. That is, they questioned whether the requirement to demonstrate a total inability to work at the time of application is consistent with the encouragement to regain work potential upon being granted the CPPD pension.34

3.1.1.2 Prevalence of Disability

The defi nition of disability that is most useful depends on the context. Various sources use different defi nitions and subsequently provide a wide array of estimates for the number of individuals with disability and the extent of their disability. As a result, data from various sources are not strictly comparable. The evaluation examined several data sources to identify the number of Canadians with disabilities, including survey data and administrative data. The surveys examined generally do not cover those living in the territories or on reserves. As a consequence it lacks adequate information about whether the prevalence and trends in disability on reserves are similar to those experienced elsewhere in the country.

30 Whetstone Group Consulting (HRSDC 2008c), p.11.31 Ibid, p.10.32 Rideau Strategy Consultants Ltd. (HRSDC 2008b), p.9. 33 Ibid, p.5. 34 Whetstone Group Consulting (HRSDC 2008a), p.15; and (HRSDC 2010), pp.7-8.

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Summative Evaluation of the Canada Pension Plan Disability Program 19

According to the Participation and Activity Limitations Survey35 estimates, about 2.3 million or 12 percent of working age Canadians (20-64 year olds) had some kind of disability in 2006. This fi gure is up from 1.9 million or 11 percent of working age Canadians in 2001. The number of those with severe or very severe disability was estimated to be slightly over 940,000 in 2006, up from 803,000 in 2001.

The Canadian Community Health Survey36 includes a derived Health Utility Index, which ranges from 0 to 1 with a lower score representing a worse health situation. The evaluation used 0.7 as the cutoff for severe disability. For 2005, the survey fi nds that 2.0 million or 12 percent of working age Canadians had a severe disability.

The CPPD Administrative data from the Master Benefi t File (MBF) shows that about 302,000 working age Canadians who met the disability and contributory requirements received CPPD pension in 2006.

A comparison of the number of CPPD benefi ciaries and those with severe or very severe disability from PALS and CCHS suggests that CPPD reaches between 15 and 32 percent of those self-identifying as having severe disabilities. The divergence between the program coverage and the population of those with severe disability is largely due to differences in disability defi nitions among the CPPD, PALS, and CCHS, as well as the contributory requirements of the CPPD. Even though the quantitative dimensions of the prevalence of disability are not comparable, it is evident that the percentage of population with disability increases with age, irrespective of whether PALS or CCHS is used as a reference (see Table 3.1).

Table 3.1Disability Distribution by Age

% of Age Group % of Severe & Very Severe CPPD Benefi ciariesAge PALS 2006 CCHS 2005 PALS 2006 CCHS 2005 All 2006 New 2006

Under 25 1.5% 8.8% 3.2% 9.5% 0.0% 0.4%25-29 1.7% 7.3% 3.5% 7.2% 0.4% 1.7%30-34 2.1% 8.0% 4.5% 7.8% 1.3% 3.4%35-39 2.9% 10.4% 6.6% 11.1% 3.5% 5.3%40-44 4.7% 10.2% 12.6% 13.6% 8.1% 9.7%45-49 6.2% 10.6% 17.0% 12.6% 13.0% 14.4%50-54 6.7% 12.5% 16.4% 13.3% 18.3% 20.0%55-59 9.3% 15.3% 20.3% 13.8% 25.8% 27.0%60-64 9.7% 14.7% 15.9% 11.1% 29.5% 18.0%Total 4.9% 10.7% 100.0% 100.0% 100.0% 100.0%Sources: Participation and Activity Limitation Survey (PALS), Canadian Community Health Survey (CCHS),

CPP Master Benefi t File, CPP-OAS Stats Book

35 Participation and Activity Limitations Survey (PALS) – It is a post-censual national survey designed to collect information on adults and children with disabilities. The survey started in 1986 and was conducted every fi ve years until 2006. The survey sample size had increased to 47,793 in 2006. It uses the World Health Organization’s (WHO) framework of disability provided by the International Classifi cation of Functioning (ICF).

36 Canadian Community Health Survey (CCHS) – The Canadian Community Health Survey is a cross-sectional survey conducted by Statistics Canada since 2001. The objective is to provide regular and timely information on health status, health determinants, and health system utilization for the Canadian population. The survey collects data from a large sample of respondents and is designed to provide reliable estimates at the health region level.

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20 Summative Evaluation of the Canada Pension Plan Disability Program

3.1.2 Are Those with Labour Market Attachment Being Reached?

A useful way of examining the extent to which a social insurance program like the CPPD is attaining its objective is to examine the eligibility rate. This refers to the extent to which contributors to the program are able to obtain benefi ts.

To be eligible for CPPD pension, a person must have made valid CPP contribution for a certain number of years. This is referred to as the Minimum Qualifying Period (MQP). The Minimum Qualifying Period has changed over the years. Prior to January 1, 1998, a person must have made a valid CPP contribution in at least two out of the last three years, or fi ve out of the last ten years they worked. For the person to have made valid contributions, their earnings in each of the relevant years must have been above the level of that Year’s Basic Exemption, which was set at $3,500 in 1997. After January 1, 1998, to be eligible for CPPD pension, a person must have made a valid CPP contribution in at least four out of the last six years they worked. For long term contributors (25 years or longer) this period was shortened to three out the last six years as of 2006.

Table 3.2 presents trends in CPP contributors qualifying for CPPD between 1997 and 2005. As a result of the change in the qualifying requirement in 1998, the percentage of qualifying contributors declined considerably between 1997 and 1998. After 1998 the proportion of qualifying contributors stabilized and remained between 66 and 68 percent.

Table 3.2Distribution of Contributors Qualifying for CPPD

by Gender and Year of Contribution

Year of Contribution

Percentage of Contributors QualifyingUnder 4 out of Last 6 Years MQP % Change Year

to YearFemales Males Both Sexes

1997* 75.0% 81.0% 78.0%1998 61.7% 70.0% 66.0% -15.2%1999 61.8% 69.9% 66.0% 2.0%2000 62.2% 70.0% 66.3% 2.6%2001 62.9% 70.1% 66.6% 3.1%2002 64.0% 70.0% 67.0% 2.3%2003 64.0% 71.0% 68.0% 2.1%2004 64.8% 70.5% 67.8% 1.7%2005 65.0% 70.0% 68.0% 1.5%Source: Whetstone Group Consulting, Technical Report on Trends in CPPD Applicants and Caseload, HRSDC, 2008b, p.9.*1997 qualifying contributors’ estimates are based on 2 out of 3 or 5 out of 10 years.

The change in the qualifying requirement in 1998 resulted in a strong and immediate decrease in the number and proportion of CPP contributors who were eligible for CPPD pension. Younger workers, the self-employed and workers with a shorter contribution history, which disproportionately included women, were especially affected. For instance, there was a 35 percent decrease in the percentage of self-employed qualifi ers between 1997 and 1998, relative to a 15 percent decrease across all contributors. The age group

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Summative Evaluation of the Canada Pension Plan Disability Program 21

that incurred the greatest decrease in eligible contributors was persons under the age of 25, where eligibility dropped from 68 percent to 34 percent. There was also a 37 percent decrease in the percentage of qualifi ers with fewer than nine years of contribution history.37

In 2005, 68 percent of all CPP contributors were eligible for CPPD pension if they met the program defi nition of severe and prolonged disability. It may be useful to compare this with an indicator that is commonly used to assess coverage of the Employment Insurance (EI) program as a way of validating the number. This indicator is based on estimates of the percentage of paid employees (EI contributors) who would receive employment insurance if they had been laid off. This estimate is typically around 88 percent and varies little from one year to the next.38 Thus the eligibility for CPPD pension is lower in comparison to that of the Employment Insurance program. The gap in coverage between these two social insurance programs, as well as the noticeable drop of eligible CPPD contributors between 1997 and 1998, can be understood upon refl ecting on the concept of a recent and signifi cant labour market attachment as implied by the CPPD contributory requirements.

The majority of regional personnel interviewed as key informants stated that the new Minimum Qualifying Period negatively affects long-time contributors who become disabled with interrupted labour force attachment and young employees who have not had adequate time to establish a long enough contribution history to qualify for CPPD.39,40 The extent to which this occurs is diffi cult to determine empirically, as long term labour dynamics are only just coming to be understood with the maturation of databases which track the movements of individuals in and out of the labour market over long periods of time. However, it can be said with certainty that the movements in and out of the labour market are more frequent than initially supposed. For example, roughly 15 percent of the employed labour market at any point in time is considered a New Entrant or Re-entrant.41 Under the Employment Insurance system, most of these people are still eligible and meet the longer qualifying hours required for a New Entrant or Re-entrant, but under the CPPD system they may not qualify.

The requirement that an individual contribute for four out of the last six years implies that for the fi rst four years of an individuals working life, they cannot be eligible for CPPD. This inevitably contributes to a lower overall eligibility rate as a four-year period represents more than 10 percent of an individual’s working life. This also helps to explain why the move from a two out of three year requirement to a requirement that a worker contributed to CPP in at least four out of the last six years they worked would cause the eligibility rate

37 Whetstone Group Consulting (HRSDC 2008b), pp.10-12.38 For an example, see HRSDC (2005), p.58.39 Whetstone Group Consulting (HRSDC 2008c), p.12.40 It is important to note that, in 2008, one year after the timeframe of the current evaluation (1997-2007), the CPP

legislation was amended to ease the contributory requirements. The change applies to CPPD applicants with at least 25 years or more years of contributions and allows them to meet the contributory requirement for CPPD if they have made valid contributions in three out of the last six years, instead of four out of the last six years.

41 New entrants refer to workers who have entered the labour market for the fi rst time. Re-entrants refer to those who have limited work experience in the last two years. These two groups are known collectively as NEREs (new entrants/re-entrants). HRSDC (2010), p.71.

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22 Summative Evaluation of the Canada Pension Plan Disability Program

to drop. However, it is important to keep in mind other factors that may also be behind the decline. Such factors may include the way that work is organized in this century, with more people being self-employed, with more women coming in and out of the labour force, with greater numbers of young people entering the labour force later after remaining in school for longer, and with more boomers working later than was typical for previous cohorts. These are all believed to be factors behind the declining percentage of qualifying contributors. Further analysis is required to determine the relative importance of these various factors as well as their implications.42

Two caveats are necessary when interpreting the analysis in this section. First, the comparisons with the Employment Insurance system should not be taken too far. Since CPPD benefi ciaries typically receive benefi ts for far longer than the typical Employment Insurance benefi ciary, it is probably appropriate that the qualifying contribution period is also longer for CPPD than for Employment Insurance. Secondly, most individuals who collect CPPD pension start later on in life, so having to contribute for four out of the last six years rather than two out of three is likely less relevant to obtaining benefi ts for people in their 50s. Nonetheless, the perspective given in this section does yield useful insights that warrant further investigation.

3.1.3 Experience of Denied Applicants Applicants for CPPD were denied or accepted for CPPD pension depending on the extent to which they have been signifi cantly attached to the labour market and are disabled. One possible issue in program targeting could occur if those who are qualifi ed for benefi ts do not receive them.43 This section provides two lines of evidence on the experience of denied applicants: one avenue of enquiry for examining the extent to which CPPD may or may not meet the needs of the working age population with disabilities.

First, a survey of randomly selected 2,000 CPPD applicants (approximately 1,000 denied and 1,000 granted) who applied in 2004 and 2005 was conducted in 2008. Among the denied applicants, 60 percent had not worked since their application was denied, 17 percent had done some work since being denied, and 23 percent were working at the time of the survey. Of those who had worked since denial but who were not working at the time of survey, most (76 percent) had stopped working again because of a recurrence of disability or further illness.44 In order to meet their fi nancial need, denied applicants reported a variety of income strategies such as reducing living expenses and relying on other family income sources.45 The failure of 60 percent of denied applicants to secure employment three to four years after denial raises questions.

42 Whetstone Group Consulting (HRSDC 2008b), p.13.43 Another possible error occurs when individuals who are not truly eligible are deemed qualifi ed and receive benefi ts.

However, the evaluation does not offer any evidence on the extent to which this occurs. 44 TNS (HRSDC 2009b), p.34.45 Ibid, p.36.

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Summative Evaluation of the Canada Pension Plan Disability Program 23

Second, an analysis of linked CPPD administrative data and Canada Revenue Agency income tax data for CPPD applicants shows that nearly half (49 percent) of the denied applicants had no earnings three years after being denied benefi ts and an additional 24 percent had average annual earnings of less than $10,000.46 Once again, the failure of almost half of the denied applicants to secure employment and earnings three years after denial raises the concern that some individuals may not be capable of regularly engaging in any gainful employment and yet are not able to obtain help from the CPPD. It is important to point out that these estimates are highly sensitive to the assumptions made. If a subgroup is selected who are less than 55 years old and who have pre-disability earnings more than double the minimum requirement for a valid CPPD contribution (i.e., having suffi cient employment to qualify for CPPD pension), then the percentage who have no earnings several years later is slightly less than 20, which is far higher than would be expected for working age individuals.47

3.2 Assessment of Benefi t LevelsThe CPP legislation does not specify any benefi t adequacy threshold for CPPD. The objective summarized in Section 2.5 states clearly that the benefi t levels only need to be “basic”. As well, the 1964 CPP White Paper makes it clear that CPPD was not intended to replace all income lost as a result of disability, but rather to contribute to a mixed system of income replacement. As a result, this section will look at the extent to which CPPD contributes to the overall income situation of the claimants with some analysis of income shares.

The literature supports an even broader view of this issue. There are various approaches in the general social insurance literature specifying what could be considered an “adequate” income replacement rate after an event such as retirement or disability.48 However, it is useful to stress that there is little analysis directly related to a program such as CPPD. One approach deals with the level of income after the event compared to income before the event that would be considered “adequate”. Various studies suggest a 70 percentreplacement rate as adequate in general; though recommend higher replacement rates for those at lower income levels.49 Another approach strives to identify a level of income that is considered adequate to smooth consumption around the event so that consumption does not drop after the event in a fashion that imposes hardship on the individuals or their dependents. Finally, international comparisons are useful for assessing the adequacy of benefi ts.

This evaluation followed a three-pronged approach to assessing adequacy of CPPD pension based on the earnings replacement rate, income shares, and international comparisons. It must be noted at the outset, however, that data do not exist to support the analysis of consumption patterns recommended in a number of academic studies.

46 TNS (HRSDC, 2009a), Study 4, table 1.11.47 Ibid. Supplementary Analysis.48 Gunderson (HRSDC 2008), pp.7-9.49 For examples of studies that refer to an adequate income replacement rate at 70%, see Gower (1998), Horner (2006),

LaRochelle-Côté et. al. (2007), and Skinner (2007).

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24 Summative Evaluation of the Canada Pension Plan Disability Program

3.2.1 Earnings Replacement RateThe earnings replacement rate can be measured in a variety of ways depending on the choice of earning period and how earnings are measured. Earnings vary over the career of a person and therefore the length of the period covered can have a major impact on the replacement rate. Data for CPPD benefi ciaries over 1990-2006 show that earnings begin to decline about three years in advance of receiving CPPD as disability sets in and withdrawal from labour force begins. (Figure 3.1).

Figure 3.1Average earnings of benefi ciaries starting CPPD during 1990-2006

$0

$5,000

$10,000

$15,000

$20,000

$25,000

-20 -19 -18 -17 -16 -15 -14 -13 -12 -11 -10 -9 -8 -7 -6 -5 -4 -3 -2 -1 Years before receiving CPPD

Source: CPPD-CRA data.

The CPPD administrative data and the Canada Revenue Agency income tax data were linked together to examine the replacement rate of average CPPD pension based on earnings three years before receiving CPPD. This estimate was calculated for 1993-2004. The average replacement rate over this time interval was 48 percent. The replacement rate declined from 50 percent in 1998 to 43 percent in 2004, refl ecting a faster increase in pre-disability earnings over time than the average CPPD pension.50

Longitudinal Administrative Database (LAD) was also used to calculate an alternative measure of replacement rate. In this case replacement rate was defi ned as current CPPD pension divided by the infl ation adjusted reduction in earnings two years before the start of CPPD. This led to a replacement rate of about 39 percent and this rate remained fairly stable over time.51

In brief, CPPD pension replaces 40-50 percent of pre-disability earnings but this threshold is sensitive to the choice of the pre-disability earnings period and how earnings are measured (e.g., in constant dollar or incremental terms).

50 TNS (HRSDC 2009a), p.49.51 Data Probe (HRSDC 2010), p.29.

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Summative Evaluation of the Canada Pension Plan Disability Program 25

3.2.2 Income ShareCPPD pension plays a central role in the post-disability income of benefi ciaries. CPPD pension averaged about 50 percent of benefi ciaries’ total income over the 1992-2005 year, ranging from a low of 42 percent to a high of 53 percent.52 This attests to the importance of this income source to the recipients (Figure 3.2).

Results from the survey of CPPD applicants53 and from the Longitudinal Administrative Database54 also support the above fi nding and show that, on average, CPPD provides benefi ciaries with roughly 47 percent (in 2005) and 46 percent (in 2006), respectively, of the incomes they receive. It should be pointed out that although these data are very precise, this analysis probably slightly overstates the importance of CPPD because 20 percent of CPPD recipients receive some income from employer based long-term disability programs four years after application.

The CPPD as a share of income tends to fall with income level. For example, CPPD accounted for over 80 percent of the income of benefi ciaries with less than $15,000 income in 2006, but less than 19 percent of the income of those with incomes over $45,000.55

Over time, CPPD as a share of family income declined from 29 percent in 1992 to 20 percent in 2006 largely due to faster growth in other incomes sources, including the growth in income from a partner in two earner families (Figure 3.2).56 This also points to the signifi cant, yet declining, role of CPPD pension in the income profi le of the families of the benefi ciaries. The survey of applicants suggests that CPPD pension accounted for all of family income for 12 percent of benefi ciaries.

52 TNS (HRSDC 2009a), p.47.53 TNS (HRSDC 2009b), p.25.54 Data Probe (HRSDC 2010), p.27.55 Ibid, p.28.56 Ibid, Extension #2, p.14.

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26 Summative Evaluation of the Canada Pension Plan Disability Program

Figure 3.2CPPD as a share of income

0%

10%

20%

30%

40%

50%

60%

1992 1993 1994 1995 1996 1997 1998 1999 2000 2002 2003 2004 2005 20060%

10%

20%

30%

40%

50%

60%

CPPD/Beneficiary Income CPPD/Family Income

CP

PD

/Ben

efic

iary

Inco

me

CP

PD

/Fam

ily In

com

e

Source: CPPD-CRA and LAD.

3.2.3 International ComparisonsHow do benefi t amounts and earnings replacement ratios of the CPPD compare with disability programs in other countries? Four case studies of national disability earnings replacement or income support programs were undertaken as part of the Evaluation of the CPPD.57 The countries chosen were the United States, the Netherlands, the United Kingdom, and Australia.

The programs in these countries differ widely from each other and from the CPPD Pension in Canada. These countries collect contributions at different levels and cover different target populations. First of all, the disability requirements vary broadly across these countries. Canada, the US and the Netherlands have more stringent requirements, while the UK has the least stringent requirements. Australia has an internationally admired adjudication model that distinguishes between those who cannot work and those who have diffi culty working. Second, the contributory requirements also vary greatly. Both Canada and the UK require recent contribution, while the US requires contribution throughout one’s working career. The Netherlands’ disability program is solely funded by employers and there are no contributory requirements for employees. In Australia, on the other hand, the pension program is paid from general revenue and is not based on contribution at all. Third, coverage is also diffi cult to

57 Rideau Strategy Consultants Ltd. (HRSDC 2008a).

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Summative Evaluation of the Canada Pension Plan Disability Program 27

compare. Canada, the US and the UK provide coverage to a comparable percentage of the workforce, which is likely not as broad as in the Netherlands where there are no contributory requirements. The program in Australia offers much narrower coverage since benefi ts are only payable to low-income disabled persons. Given these (and other) differences, simply comparing benefi t amounts or earnings replacement ratios is not very useful.

The international case study report considered and analysed several measures of disability benefi t generosity under the various national disability income replacement programs for the purpose of learning from the practices in other countries. The most meaningful comparative measure was found to be an earnings replacement rate for an average individual who had been earning consistently at the average wage for his or her entire working life, and who ended up making a disability claim at the age of 50. On the basis of the available information, it would appear that the CPPD benefi ciaries who had consistently been earning at the average wage would fare better than their international counterparts, except the ones from the United States. In the US, social security contributors pay taxes on a much broader band of earnings and at a higher percentage of covered earnings, so the disability benefi ts they can then receive are higher than for Canada’s CPPD Pension.

3.2.4 Benefi t Levels May Not Meet the Needs of All GroupsThe benefi t levels of the CPPD pension may not meet the needs of several groups of the working age population. One evaluation study linked CPPD administrative data and Canada Revenue Agency income tax data to compare the extent to which benefi ciaries in different subgroups fall below the Low Income Cut Off in terms of family income after CPPD takes effect. The study fi nds that, compared to the 48 percent of all benefi ciaries who started receiving CPPD pension between 1993 and 2004 and whose family income was below the Low Income Cut Off two years after CPPD started, the following subgroups were more likely to be in this situation: those who had mental disorders (55 percent), those who developed a disability before the age of 34 (68 percent), those who were separated or divorced (63 percent), and single parents (73 percent).58 Another study, using the 2006 Longitudinal Administrative Data, also confi rmed that, the proportion of benefi ciaries whose family income was below the Low Income Cut Off was higher among single persons and lone parents than all benefi ciaries as a whole.59 However, it is important to reiterate that the objective of CPPD was never to be the sole source of income. Rather, it was intended to replace a portion of lost earnings.

58 TNS (HRSDC 2009a), Study 2, Table 5.1. 59 Data Probe (HRSDC 2010), p.36.

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28 Summative Evaluation of the Canada Pension Plan Disability Program

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Summative Evaluation of the Canada Pension Plan Disability Program 29

4. Impacts and Effects of the Program This chapter examines the impacts of the CPPD Pension that are pertinent in evaluating the program. The chapter is divided into four sections. Section one examines the impact of the program on the prevalence of low-income among the disabled. Section two reports on the program impact on the quality of life of benefi ciaries. Section three examines the impact of the application process has on clients. Finally, section four provides a discussion of a possible unintended effect of the program, namely, program impacts on work incentives.

4.1 Impacts on Prevalence of Low-IncomeThe CPPD legislative framework does not include the reduction of low-income as an explicit program objective. However, CPPD is designed to provide partial income replacement to workers who are incapable of regularly pursuing any substantially gainful occupation. Moreover, the provision of any fi nancial benefi ts to a target group can be expected to have a positive impact on the prevalence and the extent of low-income in the group. Therefore, in the context of impacts and effects of CPPD Pension, it is useful to consider the contribution of these benefi ts to the reduction of low-income among benefi ciaries.

CPPD benefi ciaries have a higher prevalence of low-income than the rest of the population.60 For instance, 22 percent of CPPD benefi ciaries had an after tax family income below the corresponding after tax Low Income Cut Off level versus 15 percent of all Canadians 18-64 years old. In the absence of CPPD pension, the prevalence of low-income among CPPD benefi ciaries would have been almost double (40 percent instead of 22 percent).61 Moreover, among those who remain in the low-income group, CPPD helps reduce the gap between their income and the Low Income Cut Off by more than half (from $11,300 to $4,800 in 2006).62

4.2 Impacts on Quality of LifeThe CPPD pension has impacts on many aspects of benefi ciaries’ lives including their capacity to live actively, to live independently, to obtain needed services, and to provide for dependents. In a survey of 2,000 individuals (approximately 1,000 granted and 1,000 denied) who applied for CPPD in 2004 or 2005, 72 percent of the granted applicants agreed that without CPPD pension they would not have been able to live independently, and 50 percent indicated that CPPD pension allowed them to live actively. Sixty-six percent of

60 For a discussion of incidence of low-income among those with disability see for instance Burkhauser et al. (2009).61 It is based on the assumption that individuals will not adjust their behaviour in the absence of CPPD benefi ts. 62 Data Probe (HRSDC 2010), p.35.

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30 Summative Evaluation of the Canada Pension Plan Disability Program

the granted applicants indicated that without the CPPD pension they would not be able to support their dependents, while 64 percent reported that without CPPD pension they would not have been able to obtain the items and help they needed because of their disability.63,64

In terms of CPPD’s impact on benefi ciaries’ health and quality of life, the survey results showed that 15 percent of the granted applicants felt that CPPD pension helped improve their quality of life. It was also noted that the denied applicants were more likely to return to work earlier than anticipated and against their doctor’s advice.

4.3 Impacts on Work IncentivesEconomic literature suggests that disability benefi ts may create a disincentive to work. The bulk of research concerning the impact of disability benefi ts on labour supply focuses on older male workers and uses a variety of regression analyses to show there is a negative correlation between disability benefi ts and labour supply.65 These correlations are used to conclude that disability benefi ts have an adverse effect on labour supply.66 However, little is known about the effect of disability benefi ts on labour supply in the Canadian context.

Several studies prepared for this evaluation examined the pattern of labour supply and employment earnings of CPPD applicants before and after the decisions on their applications were made. The fi ndings from these studies offer a number of insights into the debate on disability benefi ts and labour supply.

First, employment rates and earnings among CPPD benefi ciaries begin to decline years before CPPD pension starts. According to a study using linked data from CPPD and the Canada Revenue Agency, average employment earnings of CPPD benefi ciaries start to decline about three to four years before CPPD begins, and the earnings declines become more signifi cant two years before the start of CPPD.67 Another study using the Longitudinal Administrative Database also found that, substantial decreases in both employment rates and earnings take place years before the start of CPPD. The employment rate of the CPPD benefi ciaries declined from 93 percent fi ve years before the receipt of CPPD to 73 percent one year before the receipt of CPPD. The average employment earnings of CPPD benefi ciaries declined from $36,800 fi ve years before the receipt of CPPD to $28,200 one year before (Figure 4.1).68 Since up to the decision date these individuals had not received CPPD pension, reductions in their employment and earnings cannot be attributed to CPPD pension. The reductions are likely due to gradual onset of disability and withdrawal from the labour force.

63 TNS (HRSDC 2009b).64 It is worth noting that the survey also provides meaningful evidence on a wide variety of income strategies persons

with disabilities used to help meet their fi nancial needs. For example, many have used their savings (59%), took out loans or used credit cards (56%), cashed in RRSP’s or other investments (38%).

65 For example, see Autor and Duggan (2007).66 For an example of such research see the OECD (2006-2010).67 TNS (HRSDC 2009a), p.48.68 Data Probe (HRSDC 2010), Extension #1, p.6.

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Summative Evaluation of the Canada Pension Plan Disability Program 31

Figure 4.1Employment rates and earnings of benefi ciaries

Em

ploy

men

t rat

e

Aver

age

earn

ings

0%

20%

40%

60%

80%

100%

5 years ago 4 years ago 3 years ago 2 years ago 1 year ago Current(2006)

0

10,000

20,000

30,000

40,000

Employment rate among those who began receiving CPPD in 2006

Average earnings among those who began receiving CPPD in 2006 (in 2006 $)

Source: Longitudinal Administrative Database.

The employment rate and earnings of CPPD benefi ciaries continue to decline after benefi ts are granted, and it is important to emphasize that the decline is more pronounced than in the case of denied applicants. This should be as expected. At the same time it is true that CPPD pension helps ease fi nancial constraints on the benefi ciaries allowing them to reduce their labour force participation while maintaining some degree of fi nancial security as intended under CPPD. (Figure 4.2)

Figure 4.2CPPD applicants' average earnings (2001-2006)

Em

ploy

men

t Inc

ome

($)

0

5,000

10,000

15,000

20,000

25,000

30,000

35,000

-3 -2 -1 1 2 3 Years before application (-) and after decision (+)

Denied Granted

Source : Longitudinal Administrative Database.

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32 Summative Evaluation of the Canada Pension Plan Disability Program

Second, it is also worth noting that CPPD benefi ciaries tend to have lower employment earnings than the average population. When using the Longitudinal Administrative Database to compare older (age 50-64) non-benefi ciaries with benefi ciaries who began receiving their CPPD in 2006, the average earnings among benefi ciaries declined considerably during the three years prior to CPPD; while during the same time frame, average earnings among non-benefi ciaries remained stable with a slight increase. (Figure 4.3)

Figure 4.3Average earnings among 50-64 year olds

0

10,000

20,000

30,000

40,000

50,000

60,000

3 years ago 2 years ago 1 year ago Current year

CPPD Beneficiaries No CPPD

Source : Longitudinal Administrative Database.

Third, studies have also found that many denied applicants do not resume working after their CPPD applications are denied. For example, the applicant survey reported that about 60 percent of denied applicants had not returned to any form of gainful employment in the three to four years after their denial.69 As mentioned in Section 3.1.3, this raises the concern that CPPD may not meet the needs of the working age population with disabilities. On the other hand, this decline in labour supply among denied applicants also suggests that the reason behind such a decline is likely to be disability itself rather than the possibility of receiving CPPD pension (which were never received by these people, and who had no chance of receiving CPPD pension if they continued not to work and hence lost eligibility for benefi ts because of inadequate recent employment).

69 TNS (HRSDC 2009b), p.34.

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Summative Evaluation of the Canada Pension Plan Disability Program 33

5. Issues in Program Delivery The three sections of this chapter view the delivery of the program from different perspectives with a view to obtaining multiple lines of evidence. The fi rst section focuses on the experience of signifi cant partners in program delivery – applicants, health care professionals, and staff members in regional processing centres. The second section describes the application process in greater detail. The third section provides a description and insights into the impacts of various policy changes on program delivery.

5.1 Issues Related to Signifi cant PartnersCPPD is not delivered in isolation by the Directorate in HRSDC responsible for CPPD. The proper functioning of this program is contingent on the perspective of numerous partners, inside HRSDC and outside.

5.1.1 ApplicantsThis section presents fi ndings from a CPPD applicant survey and a series of focus groups conducted with CPPD applicants and benefi ciaries. The participants of these two studies reported how they fi rst found out about the program, their experience communicating with the program, as well as their understandings about the program.70

5.1.1.1 Learning about the Program

According to the fi ndings from the survey and the focus groups, people most commonly fi nd out about CPPD from medical professionals, or a referral from another income replacement program. Among participants of the focus groups, those who were on private insurance, workers compensation or workplace safety and insurance board (WCB/WSIB), or Provincial Social Assistance indicated that they were expected to apply for CPPD. Many people also fi nd out about the program from their family, friends, and employers. Less frequently, people hear about CPPD from HRSDC or Service Canada information or representatives. Those whose applications were subsequently granted were more likely to fi nd out about the program from a doctor; while denied applicants were more likely to hear about it from family or friends, provincial disability programs, or to have had pre-existing knowledge of the program. Table 5.1 indicates the main sources of information about the program among applicants, both granted and denied.71

70 TNS (HRSDC 2009b); Whetstone Group Consulting (HRSDC 2008a).71 TNS (HRSDC 2009b), p.10.

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34 Summative Evaluation of the Canada Pension Plan Disability Program

Table 5.1How First Found Out About the CPPD Pension by Granted and Denied

Total(n=2001)

Granted(n=1027)

Denied(n=974)

Medical professional 20% 24% 17%Family/friends 13% 12% 15%Employer 13% 13% 12%Just knew about it 6% 5% 7%Private health insurance (short term disability) 6% 6% 6%Employment Insurance program 5% 5% 4%Social worker/services 4% 4% 4%Government /MP 3% 2% 3%WCB/WSIB 3% 3% 2%HRSDC 2% 2% 2%Provincial disability program 2% 1% 3%Lawyer 1% 2% 1%Other 16% 15% 17%Don’t know 7% 6% 8%Note: Totals may not equal 100% due to rounding.

5.1.1.2 Communications with the Program

Most applicants had contact with the program by mail or by telephone. These are also the most preferred methods of communication when it comes to being informed about the application outcome. The preference of which one comes fi rst depended on whether the application was granted or denied. Granted applicants prefer a telephone call fi rst followed up by a letter, and denied applicants prefer a letter followed by a telephone call.72

For some applicants, program communication in general was not seen to be particularly helpful. Less than one quarter of the focus group participants remembered receiving the fi rst client contact call. Of those that did remember, most indicated that they were not well informed about the process that would take place.73

In terms of the call to deliver the decision to grant or deny the benefi t, less than half of the focus group participants remembered receiving such a call. Reception to it was different between granted and denied applicants. Granted applicants welcomed the call but denied applicants suggested that it would be helpful to receive a letter fi rst, with an invitation to call if they had questions.74

When written communication is used to deliver the decision, mixed results were found. Participants of the survey felt that the letter was clearly written, was easy to understand, and it provided details about their acceptance or denial. The focus group participants, on the other hand, thought that the letter was impersonal, full of program jargon, and diffi cult

72 Ibid, p.12.73 Whetstone Group Consulting (HRSDC 2008a), p.20.74 Ibid, pp.21-22.

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Summative Evaluation of the Canada Pension Plan Disability Program 35

to understand. Both the survey and the focus groups found that information on return to work options and other benefi ts or assistance that was available for denied applicants was inadequate.75

5.1.1.3 Understanding of the Program

Granted and denied applicants had similar knowledge of the CPPD Pension when they applied. However, granted applicants identify more understanding of the program after applying for the benefi t. Nonetheless, a majority of granted applicants remain unaware of many aspects of the program. Areas where knowledge is strong include taxability, vocational rehabilitation, children’s benefi ts, volunteer work, and other benefi ts. Areas where knowledge could be improved include return to work rules, impact of receiving children’s benefi ts, and consequences of applying late.76

5.1.2 DoctorsPhysicians play an important role in assessing the state of health of the applicants in accordance with the CPPD requirements. A medical report from the applicant’s family physician must be submitted as a part of an application for CPPD pension. Different members of the medical community may also be involved in providing the necessary information for CPPD to assess eligibility. This may include psychiatrists, neurologists, and rehabilitation specialists. During a series of key informant interviews conducted with general practitioners and specialists, respondents were asked to identify their understanding of the CPPD eligibility requirement, their awareness of the return to work support, their interaction with other disability programs, and their experience communicating with the program.77 This section presents the results from these key informant interviews.

5.1.2.1 Awareness and Understanding of Eligibility Criteria

In the process of establishing eligibility for CPPD pension, applicants must have a “severe and prolonged” disability that prevents him or her from working at any job on a regular basis. Defi nitions and concepts of severe and prolonged disability are communicated to physicians through a “Physician’s Guide” provided by the CPPD Pension.

Respondents identifi ed various problems associated with these defi nitions. Some defi nitions are diffi cult to quantify, some are open to different interpretations, and some entail information that is unknown to physicians and therefore that is not within physicians’ expertise to assess. The defi nitions were reported to be particularly diffi cult to apply to patients with more subjective symptoms such as mental health problems and chronic pain.78

75 TNS (HRSDC 2009b), p.14; Whetstone Group Consulting (HRSDC 2008a), p.22-23.76 TNS (HRSDC 2009b), pp.16-17.77 Whetstone Group Consulting (HRSDC 2010).78 Ibid, pp.5-9.

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36 Summative Evaluation of the Canada Pension Plan Disability Program

Respondents were also asked to indicate their awareness of the non-medical criteria associated with the CPPD Pension. The majority were either not sure or not aware of these criteria. It was suggested that applicants should be able to verify their non-medical eligibility prior to having a physician complete a medical exam.79

5.1.2.2 Awareness of Return to Work Supports

Most physicians interviewed were either unaware or not sure if they had heard about the return to work supports. Respondents identifi ed a number of misconceptions about the return to work supports including that CPPD would cover medical expenses during the work trial period and that participation in any of the return to work supports would result in some reduction in CPPD pension.

Some respondents pointed out that the return to work supports seemed to be in confl ict with the eligibility criteria. Specifi cally, having the capacity to be re-trained makes a patient ineligible for CPPD pension. Thus, the return to work component of the program was seen by some as based on the person’s ability to actually pursue gainful employment, in direct confl ict with the criteria for qualifying for CPPD.80

5.1.2.3 Interactions with other Disability Programs

All of the physicians interviewed indicated that they had interaction with other disability income programs such as long-term disability carriers, workers compensation or workplace safety and insurance board, and provincial disability income programs. A vast majority of them thought that CPPD and other disability income programs could interface better. The most common issue was the duplication in information collected in the assessment processes for the different programs, which caused stress for applicants and unnecessary paperwork for physicians. This was perceived to be particularly true for CPPD and long-term disability carriers.81

5.1.2.4 Communications with the Program

The Physician’s Guide is a publication which is made available to physicians in hard copy and online. It provides an overview of the CPPD Pension, and clarifi es the role and responsibilities of the physician.

Most physicians interviewed do not recall receiving the Physician’s Guide in print or receiving a notifi cation of the online version. Their primary reference material is the information in the application package provided to the applicant.

79 Ibid, pp.9-10.80 Ibid, pp.11-12.81 Ibid, pp.12-13.

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Summative Evaluation of the Canada Pension Plan Disability Program 37

The most preferred means of communication by the respondents was through some sort of electronic means. Multiple forms of communication were also identifi ed as a good way to get the message through. The majority of respondents felt that information should be provided in a timely fashion, and only when new information is available. When asked which audiences would be most appropriate for CPPD to target, most respondents suggested targeting general and family practitioner attendees at conferences.

In order to help CPPD shape their communications plan with physicians, most respondents expressed their interest in providing input to CPPD. It was also pointed out that it is important for physician to be given notice of the decision on the application, as they are the ones who will be providing support to their patients after the CPPD application outcome is provided.82

5.1.3 Staff Members in Regional Processing CentresA series of key informant interviews were conducted with staff members in the nine regional offi ces where CPPD applications are processed.83 Interview respondents were asked to comment on the service delivery process of the CPPD Pension. This section presents fi ndings on service delivery from these key informant interviews.

5.1.3.1 Effectiveness of Communications with Applicants and Benefi ciaries

Respondents were asked to rate the level of the standard communications with applicants and benefi ciaries. The majority rated standard communication with applicants and benefi ciaries as effective. However, some issues were also identifi ed regarding both verbal and written communications.

Call Centre Inquiries – The call centres are designed to provide the applicants with appropriate information and links with other HRSDC and Government of Canada programs and services, and to help speed up the process. Communications with the call centres were not perceived as effective by applicants. Interview respondents identifi ed a number of challenges from a service provider’s view point. First of all, central managing of the call centres is associated with diffi culties for call centre staff to provide locally based advice and referrals. Other problems identifi ed also included communication problems due to language profi ciency, ineffi cient work tools and computer systems, high staff turnover, inconsistent data and information, as well as diffi culty keeping call centre personnel current on changing policies and procedures.84

82 Ibid, pp.14-16.83 Whetstone Group Consulting (HRSDC 2008c).84 Ibid, p.15-16.

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38 Summative Evaluation of the Canada Pension Plan Disability Program

Early Client Contact – Early Client Contact is an operational policy for CPPD staff to call a client when an application is received, when additional information is needed, and when a decision is made. Most respondents believed that the Early Client Contact is a good practice but could be improved.

Some staff questioned the value of calling clients to acknowledge the receipt of their application, as it is labour and time intensive. However, many others thought that if the calls were used properly, it could result in additional information, and at the very least that it would reassure the client.

The delivery of a denial decision was identifi ed as problematic. Most respondents found it very diffi cult to deliver such a call. Many reported that clients do not seem to want to receive this news by phone. It was suggested that a letter should be sent fi rst with the offer to call.85

Written Communication – The majority of respondents rated standard communications with applicants and benefi ciaries as effective. In particular, the benefi ciary newsletter, “Stay in Touch”, was seen as an effective communication tool. However, it was identifi ed that written communication with applicants needs to be improved, especially the application form and letters that go out to clients. The majority of respondents thought that the National Automated Template System (NATS) letters are too long and complicated. As noted the system supporting the National Automated Template System is not user-friendly.86

Other Outreach Activities – Aside from a few respondents who said that they conducted information sessions through organizations like the United Way and used all opportunities to be part of any network, there is a general consensus among respondents that there is not enough outreach to the general public.87 However, communication has improved over the last few years, and as a result, applicants are becoming more informed. Respondents noted that program delivery has become much more client-focused and transparent. The application and adjudication process used to be a paper exercise, but now staff call the clients. They ask them for additional information that is needed, inform them of where they are in the adjudication process and when they can expect a decision, and call them when a decision has been reached. Staff also inform clients of other programs and community resources that might be of help.88

5.1.3.2 Issues with Changing Policies and Procedures

Changing policies and guidelines pose an ongoing challenge to delivery staff. Many respondents reported that the process initiated around New Facts and Additional Information was very diffi cult to administer because the operational guidelines were unclear and the training was inadequate. It has resulted in increasingly complex processes to address legal

85 Ibid, p.20.86 Ibid, pp.24-25. 87 Ibid, pp.26-27.88 Ibid, pp.31-32.

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Summative Evaluation of the Canada Pension Plan Disability Program 39

technicalities and have had a signifi cant impact on the adjudication process. On the other hand, some respondents commented that the Medical Adjudication Framework and the Hierarchy of Issues and Summary Sheet were helpful. Furthermore, many respondents reported the current split between operations and policy as another ongoing issue. A disconnect between the National Head Quarter and the regions was also recognized. Specifi cally, it was noted that there was insuffi cient support from the National Head Quarter in addressing regional issues, and as a result, there was a lack of regional input in the policy development processes.89

5.1.3.3 Working Relationships with Other Earnings-Replacement or Income Support Programs

Respondents were asked about the quality of the working relationship between CPPD and other programs with which they might have contact. The majority are positive about the working relationships with the long-term disability insurers. However, the amount of contact and the degree of formalized working relationships with other programs varies across regions. In most regions that are processing applications from more than one province, they have developed closer working relationships with the province in which they are located. All regions either have or are developing agreements with provincial assistance programs. Though varying in their specifi cs, these agreements generally involve providing information or training on contributory requirements so that the province refers only those who would meet these requirements. Most regions have either a formal Memorandum of Understanding or an informal agreement, and good working relationships, with Worker’s Compensation Boards.90

5.1.3.4 Quality of Service Delivery

Although the majority of respondents rated timeliness as excellent or good, they pointed out that getting medical information in a timely manner is a big challenge. Some also mentioned that the speed-of-service measures should be more realistic and should focus more on meeting applicants’ needs.

Service consistency overall is described by the majority of respondents as good. However, some pointed it out that consistency across fi les at a single point in time is good, but over time consistency is poor due to ongoing changes in the interpretation of the eligibility criteria, contributory rules, and the volume of the backlog. In terms of transparency, it was rated as good or excellent by the majority of respondents.91

89 Ibid, pp.18-19., p.21. (See also Rideau Strategy Consultants Ltd (HRSDC 2008b), p.6.)90 Ibid, pp.34-36.91 Ibid, pp.29-30.

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40 Summative Evaluation of the Canada Pension Plan Disability Program

5.2 The Application Process

5.2.1 Application According to the applicant survey, the application process was perceived as too long by over half (54 percent) of the applicants. The application process for granted applicants took longer than for denied applicants (on average 7.4 versus 5.3 months) as their cases require more information and documentation.92

Participants in the Focus Groups raised a number of issues about the application process. The majority of participants indicated that their ability to cope with their illness, disease or accident was severely impacted by being continuously asked to ‘prove’ that they were as disabled as they claimed. Many participants (granted and denied) felt they suffered an erosion of self-esteem and dignity as a result of the application process. They felt they were not trusted and their claims that they were disabled were disregarded despite support from their personal network of health care professionals. Many focus group participants stated that they had to rely on the support and goodwill of family and friends. The survey of applicants found similar results. Fifty-three percent of the applicants required fi nancial support from friends and family and 59 percent relied on friends and family for emotional support during the application process.93

The application form is perceived to be lengthy and complex by applicants as well as delivery staff. Many applicants expressed frustration with fi lling out the application form and saw a need for some form of assistance. Delivery staff felt that the form does not always explain clearly why certain information is requested, and as a result such information is not always fi lled out.94 Many applicants with a mental health disability felt that the application form was geared to those with physical disabilities. Some applicants with physical disabilities also commented having diffi culty with the application form since it is more geared toward those with more acute disabilities.95

Both the medical professionals and the delivery staff who participated in key informant interviews suggested some kind of simplifi cation in the process of completing CPPD application forms. The medical professionals suggested a common application form for CPPD and other disability programs.96 The staff members suggested combining the current application, consent form, and the questionnaire into one form.97

92 TNS (HRSDC 2009b), p.53.93 Whetstone Group Consulting (HRSDC 2008a), p.17; TNS (HRSDC 2009b), p.53.94 Whetstone Group Consulting (HRSDC 2008c), p.17.95 Whetstone Group Consulting (HRSDC 2008a), p.20.96 Whetstone Group Consulting (HRSDC 2010), p.13.97 Whetstone Group Consulting (HRSDC 2008c), p.24.

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Summative Evaluation of the Canada Pension Plan Disability Program 41

5.2.2 AdjudicationThe majority of the focus group participants did not have an adequate understanding of the adjudication process and were unaware of any contact between CPPD and their doctors. The participants reported a wide range of times for adjudication, based on their personal experiences, varying from two or three weeks to over a year. The participants at both ends of this range of processing times questioned the adjudication process. Those who reported lengthy adjudication questioned why it took so long, and those whose adjudication took only weeks sometimes questioned why there was so little investigation.98

The majority of the processing centre respondents reiterated the diffi culty of getting medical information in a timely manner. In some areas, applicants may not have a regular doctor which adds to the delays. Most also thought that the fee scale was outdated and that physicians should be paid more.99 Doctors who participated in key informant interviews expressed the same concern over the existing fee scale.100 They noted that there have been no increases in fees in a long time but the CPPD Pension has increased the amount and type of information required.101

Other challenges reported by respondents include ineffi cient electronic tools, constantly changing policies, as well as diffi culties in recruiting and retaining medical adjudicators.

5.2.3 Reconsideration and AppealsWhen applicants are denied, they can ask for reconsideration. The request must be made in writing and made within 90 days of receiving the initial decision letter. Reconsideration means that a second adjudicator will consider the application, as if for the fi rst time, and will reach a decision either to uphold the denial, or to grant the benefi t.

There is a general lack of understanding about this process among the focus group participants. Denied participants indicated that they were unaware that reconsideration was an internal departmental process. It was noted that the language used in communication documents was somewhat discouraging. As a result, individuals may give up the opportunity to request for reconsideration.102

If applicants are not satisfi ed with the decision on their reconsideration, they can appeal to the Offi ce of the Commissioner of Review Tribunals, or at the next level, to the Pension Appeals Board. About 40 percent of those ultimately denied and 27 percent of those ultimately granted have appealed a decision made by the CPPD Pension.103 It should be noted that new information can be introduced at any stage, which may affect the decision to

98 Whetstone Group Consulting (HRSDC 2008a), p.21-22.99 Whetstone Group Consulting (HRSDC 2008c), p.21, p.25.100 Whetstone Group Consulting (HRSDC 2010), pp16-17.101 The fee scale for physicians was increased by 30% in 2009.102 Ibid, p.22.103 TNS (HRSDC 2009b), p.74.

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42 Summative Evaluation of the Canada Pension Plan Disability Program

grant or deny benefi ts. Some denied applicants decided not to appeal, reportedly according to those interviewed because they perceived the appeal process to be diffi cult, lengthy, and stressful.104

5.2.4 Automatic ReinstatementAutomatic reinstatement was instituted in 2005. It allows CPPD benefi ciaries who leave benefi ts for work to have their benefi ts reinstated, if the same or a related disability reoccurs within two years of returning to work and prevents them from staying at work. In the following year after it was instituted, there were 1,810 CPPD benefi ciaries who self-reported a return to work and were eligible to apply for automatic reinstatement. In September 2006, a telephone survey was conducted with 155 persons who had used the automatic reinstatement provisions. The survey found that the automatic reinstatement users were well informed of its provisions, received help from multiple sources, and about half the respondents thought that this option might have helped them stay at work longer.105

Most processing centre respondents considered automatic reinstatement a very positive provision, because it encourages benefi ciaries who might not otherwise have attempted to go back to work to do so. It also gets benefi ciaries back “in pay” faster with little paperwork, especially for those with recurring conditions. On the other hand, some argued that Automatic Reinstatement does not necessarily provide a safety net for all. Some may fi nd themselves worse off after attempting a return to work. For example, some benefi ciaries who manage to stay in the workforce for some time and then cannot continue to work may fi nd that they cannot meet the program’s contributory requirements any more. Those benefi ciaries who become disabled again because of a different condition would lose eligibility for a benefi t or would have to reapply to re-establish their eligibility.106

5.2.5 Benefi t PaymentAll processing centre respondents characterized the payment system as effi cient and accurate. The vast majority reported that the payments are issued in a timely manner, especially on the urgent fi les. Nevertheless, there are some procedural issues identifi ed by the respondents. There is a need to standardize the process nationally. Staff working in this area reported challenges related to duplication, a lack of integration between systems, unclear procedures, ongoing need for training, and lengthy wait times for a number of complex processes including cases involving issues of child custody, statutory declaration and reimbursements to insurance companies. Most importantly, respondents reinforced that this part of the service takes a great deal of time, but there are currently no Key Performance Indicators for this work, which impacts the level of resources available.107

104 Ibid, pp.77-78.105 Rideau Strategy Consultants Ltd. (HRSDC 2007a), p.23.106 Whetstone Group Consulting (HRSDC 2008c), pp.22-23.107 Ibid, p.23.

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5.3 Impact of Changes to Service Delivery on Client Service

As mentioned earlier, delivery of the CPPD Pension was decentralized and transferred to Service Canada. This decentralized structure was established to facilitate client-centred service delivery. Staff members at the nine regional processing centres who participated in the key informant interviews were asked how decentralization had affected program and service delivery. This section presents their responses on this issue.

Respondents thought that service delivery had improved signifi cantly following decentralization. It was noted that the workload is better managed in the regions, resulting in more fl exibility and shorter backlogs. Many noted that because staff know the doctors, clients, local insurers and local labour market conditions, the time frame for processing and adjudication has been substantially reduced. It was also mentioned that decentralization has led to better relationships among the CPPD call centres, clients, and provincial programs with which CPPD interfaces.

5.4 Performance Measurement Framework and Quality of Administrative Data

All regions report on Key Performance Indicators.108 They capture the length of time between when a complete fi le is received (application, questionnaire and medical report) to when a decision is made. There is value in reviewing existing CPPD performance indicators against the proposed amalgamated logic model to ensure that there is an appropriate balance between productivity indicators (e.g., speed of service) and quality indicators (e.g., fairness, accuracy, sustainability). Although most processing centre respondents agreed that having service standards as a benchmark was useful to help them organize and manage workloads, the Key Performance Indicators are also recognized as focusing mainly on speed of service and workload measures.109 The concern is that client service and program delivery may be jeopardized to meet speed standards if quality of decision making is not obtaining the same management focus. For example, most managers and two-thirds of medical adjudicators who participated in the key informant interviews indicated that the Key Performance Indicators may affect the triage process by encouraging less complex fi les to be processed fi rst and this is perceived that it was done solely as a means to meet performance targets.110 Respondents also reported that a more comprehensive system of performance indicators is needed as the existing Key Performance Indicators only measure part of the process and at the time of the interviews it was felt that they were not being consistently applied across all regions.111

108 Key Performance Indicator (KPI) is the offi cial public indicators which came into effect for the fi scal year 2004-05. The target KPI for initial applications is 75% of all CPPD initial application decisions being made within 120 calendar days of receipt of a completed application. For reconsiderations, the target KPI is 70% of all CPPD reconsideration decisions being made within 120 calendar days of receipt.

109 Theodore Poister Associates (HRSDC 2009), p10-11.110 Whetstone Group Consulting (HRSDC 2008c), p.28; See also Rideau Strategy Consultants Ltd. (HRSDC 2008b), p.26. 111 Whetstone Group Consulting (HRSDC 2008c), p.28.

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44 Summative Evaluation of the Canada Pension Plan Disability Program

A fi le review was conducted to examine a sample of applicant fi les. The fi le review examined how applicant cases are typically developed and came up with conclusions about the quality of available administrative data. The fi le review found that there is a great deal of scope for improving the data quality by better coordination and consolidation of all applicant and benefi ciary data.112

5.5 Cost Effectiveness of Program Administration and Delivery

There is interest in knowing what the administrative and delivery costs are for the CPPD Pension and how cost-effective the program is. Attempts were made to compute the program delivery costs of CPPD with a view to assessing the cost-effectiveness of the program and how this might have changed over time. In addition to administrative databases, the analysis drew on many other sources including interviews with program offi cials, other offi cials of the federal government, and with other stakeholders such as provincial offi cials and also case studies of programs in other jurisdictions, including similar Canadian provincial programs, and some other countries that have similar disability programs.113

Throughout the study period there were signifi cant shifts in how the CPPD Pension was delivered within the changing organization structure of HRSDC and its predecessor departments. Delivery of the CPPD Pension was regionalized (decentralized) after the last evaluation study of the program in 1996. It was then transferred to Service Canada in 2005, with policy, strategy and advisory functions remaining with HRSDC. About nine regional processing centers are responsible for program delivery. This decentralized structure was established to facilitate client-centered service delivery. The aim was to facilitate easier communications with applicants and benefi ciaries, better linkages with other programs in each local vicinity, and generally faster and more responsive program delivery.

The resulting changes in the mode of program delivery rendered meaningful comparisons of cost data over time very diffi cult. A sub-committee was formed to attempt to validate the data early on in the evaluation, and it was agreed that some aspects of the historical time series could not be understood when analysed carefully. It was concluded, therefore, that is was impossible to make a quantitative assessment of the impact of decentralization on overall costs.

Some qualitative observations can, however, be made on the basis of the available program data and other sources. First, Service Canada managers were asked which factors they thought contributed most to the delivery costs of the CPPD. Most noted that administrative and adjudication costs were the highest cost areas, but, notably, many suggested that appeals and communications were both signifi cant cost areas also. Second, most federal respondents thought that the cost-effectiveness of delivery might have diminished with the decentralization of delivery and the establishment of Service Canada. These changes have required a signifi cant increase in

112 Rideau Strategy Consultants Ltd. (HRSDC 2007b), pp.6-7.113 Rideau Strategy Consultants Ltd. (HRSDC 2008c).

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Summative Evaluation of the Canada Pension Plan Disability Program 45

resources. Third, although it is not possible to make meaningful quantitative comparisons of the CPPD delivery cost over time, it would be of some signifi cance to compare the program delivery costs of CPPD with those of the national disability programs that are delivered in some comparable countries. The attempts at estimating the delivery costs of CPPD produced a range of possible estimates. A technical report made a comparative analysis of the delivery costs of CPPD with those of national disability programs in four other countries, namely, the United States, the Netherlands, the United Kingdom, and Australia. These delivery cost fi gures may not be strictly comparable with the CPPD cost fi gures, but strong qualitative evidence appears to emerge suggesting that the program delivery cost fi gure of CPPD is relatively low and the program is cost-effective. For instance, in the US, the administrative cost of the disability program was 2.5 percent of the total benefi ts paid in 2006. By comparison, the cost of administering the CPPD in 2007-08 was $44.3 million or 1.28 percent of the total program expenditures ($3.5 billion). The administrative expenses of the entire CPP in 2006/07 were 2.2 percent of total benefi ts paid. The administrative cost of the disability program in Australia was 4 percent of program costs in 2005, again confi rming that the administrative cost of the CPPD Pension is lower at 1.28 percent than in Australia.114

114 For comparisons using other indicators, see Rideau Strategy Consultants Ltd. (HRSDC 2008c).

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46 Summative Evaluation of the Canada Pension Plan Disability Program

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6. Conclusions and RecommendationsNumerous evaluation questions have been answered throughout the text, which are detailed in Annex 1. With these questions, it is possible to draw some overall conclusions from the trends identifi ed. This chapter also suggests further work that could be done following from the results obtained or inspired by work done in other countries. As this evaluation was detailed in nature, a rich set of recommendations is also possible.

6.1 Conclusions and Areas for Further WorkThroughout this report and the supporting technical reports, answers to 23 broad evaluation questions are provided. This information suggests the following conclusions that might be offered with respect to broader and more strategic issues.

It is concluded that the program is founded on a strong rationale, and the overarching structure of how the program is delivered seems to work well. In addition, the program covers virtually all sectors of the labour market, and about two thirds of all those covered had suffi cient labour experience to be eligible for CPPD pension at any point in time. Further analysis on this issue is encouraged to better understand how well CPPD meets the needs of today’s working age population.

In terms of clients’ knowledge of the program, it is found that overall the CPPD is well known, but not all aspects are well understood. For instance, knowledge of return to work rules, impact of receiving children’s benefi ts, and consequences of applying late could be improved.

The application process has emerged as being overly complex. A substantial amount of evidence from many sources indicates that the process of obtaining benefi ts is highly stressful from the clients’ perspective. From a program delivery point of view, setting up a program that provides a reliable assessment of disability levels across jurisdictions and through time is a major challenge. Evaluation evidence, such as the high number of denied applicants who never work after denial, and the substantial efforts that go into the reconsideration and appeals process, suggests that the determination of CPPD eligibility is an area that warrants further analysis.

Although this report represents an important advance in the understanding of this major program, there are many questions left unanswered. It is suggested that the following areas may be considered for future study.

Assessment of eligibility in relation to different types of disabilities – US government sources indicate that very different portraits emerge when the analysis is done by disability type. While many forms of disabilities are quite clear in their impact on a client’s ability to function in the labour market, other types such as chronic pain disorders are very real but diffi cult to assess. This creates very different problems from the perspective of establishing and maintaining appropriate eligibility requirements. A signifi cant volume of applicants

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48 Summative Evaluation of the Canada Pension Plan Disability Program

reported they had not returned to work three years after denial. Further research should be undertaken to better understand the situation of these individuals that were denied benefi ts and what, if any, changes could be proposed.

Appeals process – The multi-level appeals process as described in the current report is concerning as it has a signifi cant impact on clients. At the same time, it is also an area that is not well understood. Further study of the nature of each stage of the appeal process, including characteristics of the clients and the role played by new information, may yield many useful insights.

Program delivery cost – This report failed to yield defi nitive quantitative understanding of the costs of various aspects of program delivery and the implications of the move to decentralize program delivery. Instead, some qualitative observations have been made to shed light on the cost-effectiveness of the CPPD Pension. Further analysis is needed to sort out the changes in costs due to modifi cation of the coding system associated with departmental reorganizations.

Benefi t coverage – The program covers virtually all of the labour market, and about two thirds of all those covered had suffi cient labour experience to be eligible for CPPD benefi ts at any point in time. Further work may be required in this area.

6.2 Recommendations

6.2.1 Defi ne, Develop, and Implement a Quality Assurance Framework

Discussions with program staff and a workshop to review the performance measures revealed a performance measurement system that was focused on speed of the processing rather than also considering the quality of the process. It is recommended that consideration be given to this issue. In addition, some aspects of the evaluation were hindered by challenges with the administrative data, whereas in other areas fairly rigorous analysis was possible. Although the accuracy of administrative data is not found to be a major concern, data requirements should be examined to ensure that the right people have the right information at all stages of policy and program development and service delivery.

6.2.2 The Application Process Could be Reviewed and Simplifi ed

Consider a two-step application process – At the focus groups the point was made by many applicants that it appeared to be wasteful to go through assessments by health care professionals only to learn that they did not meet the CPPD contributory eligibility criteria. It is recommended that the application process be broken up into two stages, so that contributory eligibility can be determined before health care personnel assess medical eligibility.

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Summative Evaluation of the Canada Pension Plan Disability Program 49

Consider testing approaches for making the application more user-friendly – Qualitative data strongly indicated that the application process was diffi cult and intimidating for many individuals. It is suggested that various techniques be tested to make the process more user friendly from the applicant perspective. This could include providing more assistance to applicants.

Consider how best to collaborate or coordinate with other programs – It was noted that there were similarities in the procedures for the assessment of disabilities for tax purposes, provincial benefi ts, private insurance and CPPD. It is suggested that improvements in information sharing be explored.

Enhance partnership with physicians – The discussions with physicians strongly suggested that they had valuable input and opinions. While partnerships in this area have been improved, it is recommended that a more formal process for capturing and soliciting their advice be instituted. This may be extended to other health care professionals or other groups if deemed worthwhile by the program.

6.2.3 Examine Return to Work SupportsCurrently CPPD return to work supports are provided to those who have been deemed unable to work and are eligible for benefi ts. It is recommended that more consideration be given to return to work supports that include a focus on applicants who have been denied benefi ts for not meeting eligibility criteria. This may involve informing them of a broader array of supports provided by federal, provincial or territorial governments that focus on skills and employment services.

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50 Summative Evaluation of the Canada Pension Plan Disability Program

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Summative Evaluation of the Canada Pension Plan Disability Program 51

Annex I - Evaluation Questions

Evaluation Questions Matrix for the CPPD Evaluation

Section in this report or in Technical Report (TR)

Source Documents

Continued Relevance Source Documents1. How many working age Canadians have a

disability that affects their ability to work? (by type of disability, age, sex, income, marital and family status and province)

3.1 2006 PALS & SLIDWhetstone – Analysis of Working Age Canadians with Disabilities

a. How many Canadians have a severe and prolonged disability? (by type of disability, age, sex, income, marital and family status and province)

3.1 2006 PALS2005 CCHSAdmin data

b. At what age was the onset of disability experienced? (by type of disability, age, sex, income, marital and family status and province)

N/A Whetstone – Analysis of Working Age Canadians with DisabilitiesAdmin dataData Probe - LAD

c. How has this population changed since program inception?

TR 2001 and 2006 PALS & SLIDAdmin data

2. What were the stated and theoretical rationale, mandate and objectives of CPP-D when it was created (as stated in the White Paper) and how have these evolved?

2.4 Rideau Strategy Consultants (RSC ) - Stakeholders KIIs

a. CPP-D social and economic rationale 2.4.2 RSC – Doc & Lit Reviewb. Rationale for CPP-D as fi rst payer 2.4.3 RSC - Stakeholders KIIsc. CPP-D mandate (legislation) 2.4.1. Constitution Act, 1964, 12-13 Eliz. II, c.

73 (U.K.) in section (94A)d. CPP-D objectives 2.5 RSC – Doc & Lit Review

August 1964 CPP White Papere. Rationale for including CPP-D in the CPP TR RSC - Stakeholders KIIsf. Eligibility criteria 2.1 RSC – Doc & Lit Review

RSC –Stakeholders KIIsWhetstone – SC KIIs

g. Defi nition of disability used 3.1.1 RSC –Stakeholders KIIsWhetstone – SC KIIsWhetstone – CMA KIIs

3. Are the current CPP-D statutory eligibility rules and adjudication policies consistent with the program’s current legislation, rationale, mandate and objectives?

TR RSC – Doc & Lit Review RSC –Stakeholders KIIs

4. What is the size and composition of the CPP-D-eligible population (contributory), by contribution history, age, sex, income, marital and family status, immigration status by country of origin, class of worker and province?

Whetstone – Trends Report

a. How has the eligible population changed with the amendment of the minimum contributory requirements in 1998?

3.1 Whetstone – Trends Report

b. Are there gaps in coverage, for example by type of disability or by vulnerable group?

N/A Whetstone – Trends Report

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52 Summative Evaluation of the Canada Pension Plan Disability Program

Objectives achievement Source Documents5. How many applicants are granted CPP-D

benefi ts each year?Whetstone – Trends ReportTNS- CRA-CPPD Linked StudiesGray & McDonald – Time Series

a. Who are the CPP-D benefi ciaries by type of disability, contribution history, age, sex, income, marital status, family status, family size and province?

TR Whetstone – Trends ReportTNS- CRA-CPPD Linked StudiesGray & McDonald – Time SeriesKapsalis- Unlinked LAD

b. What are the trends over the past ten years in contribution history, age, gender, income, marital and family status, immigration status by country of origin, class of worker and province?

2.6.1.1 Whetstone – Trends ReportTNS- CRA-CPPD Linked StudiesGray & McDonald – Time Series

c. At what age do CPP-D benefi ciaries enter the program (by sex, income, education, province, marital and family status and type of disability), how long do they receive benefi ts and how do they exit? (Averages)

TR Whetstone – Trends ReportTNS- CRA-CPPD Linked StudiesGray & McDonald – Time Series

d. What is the profi le of benefi ciaries who are granted benefi ts, leave the benefi t and return (by contribution history, age, sex, income, marital and family status, immigration status by country of origin, class of worker and province)?

TR Whetstone – Trends ReportTNS- CRA-CPPD Linked StudiesGray & McDonald – Time Series

e. What is the level of CPP-D disbursements to benefi ciaries, in total and per benefi ciary, by program component and by characteristics of the benefi ciaries? (In nominal and constant dollars). How and why has this changed over time?

TR Whetstone – Trends ReportGray & McDonald – Time Series

f. Are payment amounts in line with intended objectives?

TR Whetstone – Trends ReportRSC – Stakeholders KIIs

6. Do certain factors infl uence the numbers and characteristics of CPP-D applicants, over time and across regions? Such factors could include:a. Demographic changes (size of age cohorts,

change in household composition, infl uence of immigration)

TR Gray & McDonald – Time Series

b. Workforce composition and behaviour (length of attachment, age norms for retirement)

N/A

c. Economic changes (business cycle) 2.6.1.3 RSC – Doc & Lit Review Gray & McDonald – Time Series

d. Changing health profi le of Canadians (including the rising incidence of certain diseases, changing life experiences such as war service)

TR RSC – Doc & Lit Review Gray & McDonald – Time Series

e. Policy changes (CPP-D), including jurisprudence

TR RSC – Doc & Lit Review Gray & McDonald – Time Series

f. Program design changes (CPP-D) TR RSC – Doc & Lit Review

Gray & McDonald – Time Series g. Policy changes (Other programs, including

provincial uploading)TR RSC – Focus Groups

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Summative Evaluation of the Canada Pension Plan Disability Program 53

Objectives achievement Source Documents7. To what extent do provincial and private

disability-related income-support programs offset CPP-D benefi ts?a. What are the variations in offsetting policies

and what are the impacts on low-income CPP-D benefi ciaries compared to middle- or higher-income benefi ciaries?

TR RSC – Themetic Brief 3 RSC – Stakeholders KIIsWhetstone – Comparison of PT Programs

b. How are children’s benefi ts treated compared to the adult benefi t?

TR RSC – Stakeholders KIIsWhetstone – Comparison of PT Programs

8. How well have CPP-D administrators worked in partnership with other F/P/T and private disability income programs in Canada?

TR RSC – Focus groupsRSC – Stakeholders KIIsWhetstone – SC KIIsRSC- Thematic Brief 5RSC – Thematic Brief 7Whetstone – Comparison of PT Programs

9. How well does the CPP-D benefi t interface with other disability income-support programs in Canada, including:a. Canadian Forces LTD disability benefi ts,

Veteran’s benefi tsN/A

b. Employment insurance 2.4.4 RSC – Focus groups

RSC – Stakeholders KIIs

RSC – Thematic Brief 7c. Workers’ compensation organizations TR RSC – Stakeholders KIIsd. Provincial and territorial social assistance TR RSC – Stakeholders KIIs

RSC – Doc & Lit Review

Whetstone – Comparison of PT Programs

RSC- CPPD Delivery Costse. Private insurance companies TR RSC – Stakeholders KIIsf. Disability Tax Credit TR RSC – Stakeholders KIIsg. National Child Benefi t N/A

10. Is there a fair and consistent process in place to assess the eligibility/validity of applications?

a. How many applicants are approved and denied annually, and what are their characteristics, by age, sex, income, education, marital and family status, province, type of application and type of disability?

2.6.1 Gray & McDonald – Time SeriesWhetstone – Trends ReportTNS- CRA-CPPD Linked Studies

b. How many applicants are denied for failing to meet non-medical eligibility requirements, specifi cally workforce attachment requirements, over age 65 at application, in pay for CPP retirement benefi ts for more than six months, or incomplete documentation?

TR Gray & McDonald – Time SeriesWhetstone – Trends ReportTNS- CRA-CPPD Linked Studies

c. How many applicants are denied for failing to meet the “severe and prolonged” criterion?

TR Gray & McDonald – Time SeriesWhetstone – Trends ReportTNS- CRA-CPPD Linked Studies

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54 Summative Evaluation of the Canada Pension Plan Disability Program

Objectives achievement Source Documentsd. How many applicants who are denied on

initial adjudication request a reconsideration, and how many are granted?

TR Gray & McDonald – Time SeriesWhetstone – Trends ReportTNS- CRA-CPPD Linked Studies

e. How many applicants who are denied on reconsideration appeal to the Review Tribunal and how many are granted?

TR Gray & McDonald – Time SeriesWhetstone – Trends Report

f. How many applicants who are denied at the Review Tribunal ask for Leave to Appeal to the Pension Appeals Board? Of those requests granted Leave to Appeal, how many applicants are granted?

TR Gray & McDonald – Time SeriesWhetstone – Trends Report

g. How many applicants who were previously denied CPP-D benefi ts apply a second, third or fourth time (by age, sex, education, income, marital and family status, class of worker, province)? What is the time gap between these subsequent applications and what have the applicants been doing since their most recent denial?

TR Gray & McDonald – Time SeriesWhetstone – Trends Report

Impacts and Effects Source Documents11. How signifi cant is the CPP-D benefi t to

the family income of benefi ciaries (by age, sex, income, education, number of children in receipt of CPP children’s benefi ts, marital and family status, province and type of disability)?

a. What proportion of benefi ciaries’ income is from CPP-D, what part is from (1) work, (2) investments, (3) other public income support programs and (4) other sources including private insurance? (by age, sex, income, education, marital and family status, province and type of disability)

3.2.2 TNS – Linked CRA and CPPDData Probe - LAD

b. What is the ratio of CPP-D benefi ts to earnings prior to disability, by group? What is the income pattern of individuals (10-20 years) prior to being granted CPP Disability benefi ts compared to their peers?

TR TNS – Linked CRA and CPPDData Probe – LADGray – Analysis of CPPD Admin data

c. How much does the CPP-D increase the incomes of its clients, net of offsets?

TR Whetstone – Focus Group Report

d. What proportion of CPP-D benefi ciaries (individuals and families) are experiencing fi nancial hardship, including those who have income below the “poverty line”, with and without CPP-D benefi ts? (Statistics Canada, low-income cut-off or LICO)?

4.1 TNS – Linked CRA and CPPDData Probe – LAD

e. How important is benefi ciaries’ CPP-D incremental income to their health, their ability to live independently and support dependents, their ability to obtain the goods and services made necessary by their disability, and their capacity to live as well and actively as possible with their disability?

4.2 TNS – CPPD Applicants’ Survey

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Summative Evaluation of the Canada Pension Plan Disability Program 55

Impacts and Effects Source Documentsf. What impact does transition to CPP

retirement benefi ts at age 65 have on CPP-D benefi ciaries’ incomes?

TR TNS – Linked CRA and CPPD

12. What has been the experience of denied applicants after denial, (by age, sex, income, education, marital and family status, province and type of disability), in terms of:

a. income from other sources, including family income,

TR TNS – Linked CRA and CPPDTNS – CPPD Applicants’ Survey

b. earnings from employment 3.1.3 TNS – Linked CRA and CPPDTNS – CPPD Applicants’ SurveyWhetstone – Focus Group Report

c. health TR TNS – CPPD Applicants’ Surveyd. ability to live independently? TR TNS – CPPD Applicants’ Survey

13. What effect has CPP-D had on participation in the workforce and on benefi ciaries’ work-related activities (by age, sex, income, education, marital and family status, province, other income sources, voluntary activity and type of disability)?

a. Is it possible to estimate whether the CPP-D clients work less as a result of the CPP-D payments?

4.3 TNS – Linked CRA and CPPDData Probe – LADRSC – Doc & Lit ReviewGray – Analysis of CPPD Admin data

b. Does the money earned by clients improve their budgetary situation?

4.3 TNS – CPPD Applicants’ Survey Data Probe – LAD

c. Does the periodic/irregular work aid the transition back into the labour force in the event of a recovery from the disability?

TR Whetstone – Focus Group ReportTNS – CPPD Applicants’ Survey Whetstone – CMA KIIs

d. Are budgetary pressures and the opportunity to work part-time encouraging clients to work more than is medically optimal?

TR TNS – CPPD Applicants’ Survey

e. Are the two thresholds defi ning the extent to which CPPD clients can work appropriate?

. i. Do these thresholds interact with earned income limits such as those imposed by provincial programs of income support?

3.1.1. RSC - Stakeholders KIIsWhetstone – Comparison of PT programsWhetstone – Focus Group Report

f. What is the impact of Allowable Earnings on work?

N/A

14. Has the CPP-D had any unintended outcomes?

4.1 – 4.3 TNS – CPPD Applicants’ Survey RSC – Doc & Lit ReviewData Probe – LADGray – Analysis of CPPD Admin dataWhetstone – CMA KIIs

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56 Summative Evaluation of the Canada Pension Plan Disability Program

Cost Effectiveness Source Documents15. What are the CPP-D administrative/

delivery costs, in total and per benefi ciary, by functional area of the program, and how have these changed over time?

a. What are the main factors that have infl uenced delivery costs?

TR RSC-CPPD Delivery CostsRSC – Doc & Lit ReviewRSC - Stakeholders KIIsWhetstone – SC KIIs

b. How cost-effective has CPP-D delivery been, before and after decentralization and, now, with Service Canada?

5.5 CPP &OAS – Stat Book 2009CPPD Directorate - cost dataRSC-CPPD Delivery CostsRSC – Doc & Lit ReviewRSC - Stakeholders KIIsWhetstone – SC KIIs

c. What is the distribution of costs among granted and denied applicants at initial, reconsideration and Review Tribunal appeal levels?

N/A

Program Delivery Source Documents16. How effi cient and effective are CPP-D

initial adjudication, reconsideration and Automatic Reinstatement processes?

a. Are CPPD initial applications and requests for reconsideration processed in a timely manner?

5.2.1 – 5.2.3 TNS – CPPD Applicants’ Survey Whetstone – SC KIIsRSC - Stakeholders KIIs

b. Are CPPD benefi t payments issued in a timely manner?

5.2.5 Whetstone – SC KIIs

c. Are those who request Automatic Reinstatement put back onto benefi ts in a timely manner?

5.2.4 Whetstone – SC KIIsWhetstone – Trends Report

17. What is the impact of application/ appeal processing delays on applicants (granted and denied) in terms of:

5.2.1

a. income from other sources, including family income

5.2.1 RSC - Stakeholders KIIsTNS – CPPD Applicants’ Survey

b. family issues 5.2.1 TNS – CPPD Applicants’ Surveyc. health 5.2.1 TNS – CPPD Applicants’ Survey

Whetstone – Focus Group Reportd. ability to live independently 5.2.1 TNS – CPPD Applicants’ Survey

18. Is there an appropriate performance measurement framework and reporting strategy?

5.4

a. Do the management information systems include service standards and benchmarks?

5.4 Poister – CPPD Performance Measurement FrameworkWhetstone – SC KIIs

b. If so, how well has the program performed against them?

5.4 Whetstone – SC KIIsRSC - Stakeholders KIIsWhetstone – Trends Report

19. What high quality administrative data is available?

5.4 RSC –File Review RSC - Stakeholders KIIsTSN CPPD-CRAPoister – CPPD Performance Measurement FrameworkRSC – Doc & Lit Review

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Summative Evaluation of the Canada Pension Plan Disability Program 57

Program Delivery Source Documents20. How effective has early client contact

been as a means to ensuring clients understand the reasons for denial and what they have to do to provide evidence that could change the decision?

5.1.1.2 & 5.1.3.1

Whetstone – Focus GroupsWhetstone – SC KIIsRSC – Stakeholders KIIs

21. How effective have CPP-D communications with clients and client-related stakeholders been, by various methods?

a. How effective have communications with the general public been?

TR TNS – Applicant surveyRSC – Focus groups

b. How effective have communications with potential clients/populations at risk been?

TR TNS – Applicant surveyRSC – Focus groups

c. How effective have communications with current benefi ciaries been? How well do they understand various aspects of the program (e.g. allowable earnings, automatic reinstatement, vocational rehabilitation, trial work period, substantially gainful occupation, volunteer work, taxation rules on benefi ts, children’s benefi ts, late applicant provision)

5.1.1

5.2

TNS – Applicant surveyRSC – Focus groupsWhetstone – SC KIIs

d. How effective have communications with health professionals been?

5.1.2 Whetstone – Physicians KIIs

e. How effective have communications with other disability income programs been?

f. How effective have communications with disability advocacy organizations (NGOs) been?

TR RSC – Stakeholders KIIs

g. How effective has reporting to Parliament been?

TR RSC – Stakeholders KIIsRSC – Doc & Lit Review

22. How does the CPP-D compare with the QPP-D? (Statutory provisions, role, policies, relationships with other payers, reach, benefi ts and administrative costs)

TR Whetstone – QPPD Case StudyRSC – CPPD Delivery Costs

a. In what respects are the two programs in parallel and to what extent do they differ?

TR Whetstone – QPPD Case StudyRSC – CPPD Delivery Costs

23. How does CPP-D compare with selected other national and international programs of income support for persons with long-term severe disabilities? (Role, reach, benefi ts and delivery costs).

TR RSC – International Case StudiesRSC – CPPD Delivery CostsWhetstone – Comparison of PT Programs

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58 Summative Evaluation of the Canada Pension Plan Disability Program

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Summative Evaluation of the Canada Pension Plan Disability Program 59

Annex II - LegislativeChanges/ Major Events

Date Major Event or Legislative Changes1964 British North America Act (now the Constitution Act) amended, authorizing the federal

government to make laws relating to supplementary benefi ts (including survivor and disability benefi ts) irrespective of age.

1965 Canada Pension Plan enacted, effective January 1, 1966.1970 First disability pensions payable in February, 19701973 Bill C-224, CPP amended, effective January 1974.

Year’s Maximum Pensionable Earnings (YMPE) increased from $5,600 for 1973 to $6,600 for 1974 and $7,400 for 1975.

CPP benefi ts to be escalated each year effective January, 1974, to fully refl ect annual increases in the Consumer Price Index (i.e., two percent cap eliminated).

1974 Bill C-22, CPP amended, effective January 1975:

Eliminated retirement and earnings test for individuals from age 65 to 70.

Introduced equality for men and women. 1977 Bill C-49, CPP amended, effective January 1978.

Provided for credit-splitting.

Eliminated reduction in CPP children’s benefi ts which previously applied where more than four children of a deceased or disabled contributor had been eligible for such benefi ts.

Provided for child rearing provision whereby years of low or zero earnings, when a contributor leaves the labour force to raise children up to age seven, can be dropped from the contributory period. This provision ensures that reduced earnings during child rearing years will not result in lower CPP benefi ts. (Note: This amendment was only proclaimed in force in 1983 once Ontario gave its required approval.)

1980 Special House of Commons Committee on the Disabled and the Handicapped is formed. Committee proposed several improvements to the CPP disability benefi t.

1982 Federal/Provincial Ministers of Social Services establish a joint federal- provincial study to determine of establishing a national disability benefi t program.

1983 First report from Task Force completed and submitted.1985 Task Force completes second phase of study which included detailed cost estimates for various

options of a national disability program.

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60 Summative Evaluation of the Canada Pension Plan Disability Program

1986 Bill C-116, CPP amended, effective January 1987.

Major and wide-ranging CPP amendments included:

Flexible retirement

Flat-rate portion of CPP disability benefi t increased from $91.06 to $242.95 per month.

Minimum contributory requirements for entitlement to disability pension eased, to having contributions in two of the last three years or fi ve of the last ten years.

Two children’s benefi ts payable in cases where both parents are deceased and/or disabled.

Continuation of survivor’s benefi ts on remarriage.

New rules of credit-splitting on marriage breakdown and introducing sharing of retirement pension.

Additional amendments under Bill C-116 included:

Revisions to CPP appeals system, effective no later than December 31, 1991;

Review Tribunals to be established as second CPP appeals level, replacing ad hoc Review Committees;

Decisions by the Pension Appeals Board, the third and previously fi nal level of appeals, may be appealed to the Federal Court of Appeal.

1988/1989

Income Security Program (ISP) Policy Guidelines Determination of Disability, [Bulletin No: 04/89 - CPP- 01] effective March 8, 1989. This policy with respect to the determination of “any” substantially gainful occupation addresses the consideration of “having reasonable access to suitable employment given the individual’s limitations”.

1991 Bill C-39, CPP amended, effective January 1992.

A new 25-year schedule of employer-employee contribution rates is established.

A $35 increase in CPP benefi ts for the dependent children of deceased or disabled CPP contributors.

Provisions to ensure that benefi t eligibility is protected for individuals who are incapacitated.

Provisions to pay children’s benefi ts to a child adopted in fact or coming under the custody and control of a contributor after a disability benefi t is in pay.

The automatic conversion from CPP Disabled Contributor’s Child Benefi t over 18 to Orphan’s Benefi t, the assignment of CPP Disability benefi ts to Insurance Companies, and a reduction in the time limit for appeals.

1991 Bill C-260, CPP amended, effective March 1991.

Enables the Minister to take remedial action to place a person, who was denied a division of pension credits as a result of the terms of a spousal agreement (court order) made before June 4, 1986, in the position that the person would be under the Act if the spousal agreement (court order) had not been made.

1992 Bill C-57, CPP amended, effective June 1992.

To make provision for individuals who were denied Disability Benefi ts because of late application.

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Summative Evaluation of the Canada Pension Plan Disability Program 61

1995 Bill C-54, CPP amended, effective July 1995.

Administrative changes to both the CPP and Old Age Security Act (OAS) including;

Establishment of OAS/CPP Review Tribunals.

Provided for one-year retroactivity for retirement pension after age 65.

Expanding the disclosure of information provisions under both Acts. 1995 The program revised its medical determination guideline (Income Security Programs [ISP] Policy

Guideline Medical Determination of Disability under the Canada Pension Plan [CPP]” [Bulletin No: 04/95 - CPP-03]) to ensure consistency in the determination of disability.

1997 Bill C-2, CPP amended, January 1998.

Establishment of the Canada Pension Plan Investment Board; the funding provisions are amended to move from “pay-as-you-go” funding to fuller funding; the contribution rates are amended to reach 9.9%; the YBE is frozen at $3,500; changes to the combining rules.

Made a number of changes to the way benefi ts are administered and calculated in order to moderate the escalating costs of the CPP. This included several moderate changes to disability benefi ts.

Under the new legislation, the “attachment to the labour force” increases to four out of the last six years as the minimum required period of work and contributions. During that period, the person must have contributed at least 10 percent of each Year’s Maximum Pensionable Earnings (YMPE).

Amendments to the information-sharing provisions and introduction of penalty provisions. (Penalty provisions were amended later under Bill C-36 and came into force in 2010).

2000 Bill C-23, CPP amended, effective July 2000.

The Modernization of Benefi ts and Obligations Act amended 68 federal statutes, including the Canada Pension Plan and the Old Age Security Act, to extend benefi ts and obligations to common-law same-sex partners on the same basis as opposite-sex partners.

2004 Bill C-30, CPP amended, effective January 2005

Budget Implementation Act, 2004: amended the CPP to clarify the rules governing contributions to the CPP and refunds of amounts remitted in relation to employers’ contributions.

To also allow for reinstatement of a disability pension that has ceased to be payable because a person has returned to work, if the person again becomes incapable of working within a two-year period after the date when payment of the pension ceased. It also provides for reinstatement of a disabled contributor’s child benefi t to the child of a person whose disability pension is reinstated.

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62 Summative Evaluation of the Canada Pension Plan Disability Program

2007 Bill C-36, CPP amended, effective March 2008*.

CPP contributors who make 25 years or more of contributions meet the CPPD eligibility criteria for earnings and contributions with valid contributions in 3 of the last 6 years instead of the current requirement of 4 of the last 6 years. Others amendments related to CPP include: Fully integrate the CPP’s full funding provision into actuarial reporting and contribution rate setting, set out reporting requirements and clarify rate-setting in the presence of such costs, and provide for regulations to give specifi c direction to the Chief Actuary for calculating costs related to new or enhanced benefi ts.

Amendments to update and bring into force the penalty provisions under both the CPP and OAS Act.

Provisions providing the authority to set terms and conditions for the charging of interest in cases of misrepresentations for both the CPP and OAS Act.

Provisions providing the authority to set terms and conditions for electronic services.

*Note: Most amendments came into force on Royal Assent (May 2007). The full funding and long term contributor provisions came into force by Order in Council (OIC) on March 3, 2008. Amendments to the penalty provisions came into force by OIC on April 1, 2010.

2010 Bill C-51, CPP amended, effective September 1, 2010 and January 1, 2012.

The Economic Recovery Act (stimulus) amended the CPP:

To remove the work cessation test in 2012.

To increase the general drop-out from 15% to 16% in 2012 and to 17% in 2014.

To require a person under the age of 65 who receives a retirement pension and continues working to contribute to the CPP and thereby creating eligibility for a post-retirement benefi t.

To permit a person aged 65 to 70 who receive a retirement pension to elect not to contribute to the CPP.

To have the adjustment factors that apply to early or late take-up of retirement pensions fi xed by regulation after December 31, 2010 and have the Minister of Finance and the ministers of included provinces review the adjustment factors and make recommendations as to whether the factors should be changes.

There were two technical amendments concerning CPPD late applicants in relation to the proration provision and the end of the contributory period.

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Summative Evaluation of the Canada Pension Plan Disability Program 63

Annex III - Proposed Logic ModeCanada Pension Plan Disability (CPPD) Program

Clie

nt R

ecou

rse

Sys

tem

•R

evie

w T

ribun

als

•Pe

nsio

n Ap

peal

s Bo

ard

•Fe

dera

l Cou

rt

Out

puts

Prog

ram

C

ompo

nent

s&

Act

iviti

esIm

med

iate

O

utco

mes

Inte

rmed

iate

O

utco

mes

Long

er

Term

O

utco

mes

Out

reac

h

Elig

ibili

ty

Det

erm

inat

ion

Cas

e M

anag

emen

t

Wor

kfor

ce

Rei

nteg

ratio

n

•M

ailin

gs•

Publ

ic S

ervi

ce

Anno

unce

men

ts•

Info

rmat

ion

Post

ed o

n W

eb

Page

•M

obile

Out

reac

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nit

Pres

enta

tions

•C

onta

cts

with

Ref

erra

l Ag

enci

es

Tim

ely,

Acc

urat

e, C

onsi

sten

t an

d Su

stai

nabl

e D

ecis

ions

:•

Initi

al A

djud

icat

ions

•R

econ

side

ratio

ns

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st-G

rant

Info

rmat

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Pack

ages

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nnua

l New

slet

ters

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lient

/Cas

e M

anag

er

Inte

ract

ions

•Be

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s C

alcu

late

d•

Mon

thly

Pay

men

ts M

ade

•R

eass

essm

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Serv

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Rec

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d

•Th

e Pu

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and

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stak

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ders

are

aw

are

of th

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PPD

pro

gram

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ns w

ill b

e fa

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ith th

e pr

ogra

m a

nd h

ow to

ap

ply

for b

enef

its

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igib

le c

ontri

buto

rs w

ith s

ever

e an

d pr

olon

ged

disa

bilit

ies

are

enro

lled

in th

e C

PPD

P•

Inel

igib

le a

pplic

ants

are

dire

cted

to

oth

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here

ap

prop

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•C

lient

s ar

e up

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d re

CPP

DP

•C

lient

s qu

estio

ns a

nd is

sues

are

re

solv

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lient

s re

ceiv

e pa

ymen

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cor

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am

ount

s•

Oth

er d

isab

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inco

me

prog

ram

s re

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imbu

rsem

ents

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lient

s re

tain

or c

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g be

nefit

s as

app

ropr

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•C

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s st

reng

then

cap

abili

ties

for v

olun

teer

wor

k or

com

petit

ive

empl

oym

ent

•El

igib

le p

erso

ns w

ill a

pply

fo

r CPP

D b

enef

its

•C

lient

s ar

e se

rved

in a

tim

ely,

sen

sitiv

e an

d re

spec

tful m

anne

r at a

ll po

ints

of c

onta

ct w

ith C

PP

D

prog

ram

•Lo

st e

mpl

oym

ent i

ncom

e du

e to

sev

ere

and

prol

onge

d di

sabi

litie

s w

ill b

e pa

rtial

ly re

plac

ed

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PPD

clie

nts

retu

rn to

wor

k

•En

hanc

ed

soci

al a

nd

econ

omic

in

clus

ion

of p

erso

ns

with

di

sabi

litie

s in

Can

adia

n so

ciet

y

Appe

als

rece

ived

and

ad

dres

sed:

•W

ithdr

awal

offe

rs m

ade

•Se

ttlem

ent o

ffers

mad

e•

Litig

atio

n ca

ses

defe

nded

•R

etur

n to

wor

k as

sess

men

ts

com

plet

ed•

Clie

nts

trans

ition

off

bene

fits

•W

ithdr

awal

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rs a

ccep

ted

•Se

ttlem

ent o

ffers

acc

epte

d•

Litig

atio

n ca

ses

defe

nded

su

cces

sful

ly

Polic

y Le

ader

ship

and

Pr

ogra

m

Man

agem

ent

Polic

y Le

gisl

atio

n &

Reg

ulat

ions

•Po

licie

s dr

afte

d•

Reg

ulat

ions

up

date

d

Med

ical

Exp

ertis

e•

Hea

rings

at

tend

ed•

Opi

nion

s pr

ovid

ed

Ris

k As

sess

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t/Li

tigat

ion

Stra

tegy

•Li

tigat

ion

case

s re

view

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Litig

atio

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ses

defe

nded

Res

earc

h,

Anal

ysis

&

Eval

uatio

n•

Res

earc

h pa

pers

•Ev

alua

tion/

re

view

s

Partn

ersh

ips

•Pa

rtner

ship

s &

netw

orks

fo

rmed

Polic

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m

Dire

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anad

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ram

D

irect

ion

docu

men

ts

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64 Summative Evaluation of the Canada Pension Plan Disability Program

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Summative Evaluation of the Canada Pension Plan Disability Program 65

Annex IV - Bibliography Aarts, Leo and Philip de Jong, Economic Aspects of Disability Behaviour, Amsterdam,

North-Holland, 1992.

Aarts, Leo. Richard Burkhauser and Philip de Jong, Convergence: A comparison of European and United Stated disability policy, in Terry Thomason, John Burton and Douglas Hyatt “New approaches to disability in the work place”, Industrial Research Association Series, Madison, 1998.

Autor, D. and M. Duggan, Distinguishing income from substitution effect in disability insurance, American Economic Association Papers and Proceedings, 2007.

Burkhauser, R. et al., Income Security for Workers: A Stressed Support System in Need of Innovation, Journal of Disability Policy Studies, Vol. 19, pg. 204-220, 2009.

Campolieti, Michele and John N Lavis, Disability Expenditures in Canada 1970-1996: Trends, Reform Efforts and a Path for the Future, Canadian Public Policy, Vol. 26(2), pg. 241-264, 2000.

Campolieti, Michele, The Canada/Quebec Pension Plan Disability Program and the Labour Force Participation of Older Men, Economic Letters, Vol. 70(3), pg. 421-426, 2001a.

Campolieti, Michele, Disability Insurance and the Labour Force Participation of Older Men and Women in Canada, Canadian Public Policy, Vol. 27(2), pg. 179-194, 2001b.

Campolieti, Michele, Moral Hazard and Disability Insurance: On the Incidence of Hard-to-Diagnose Medical Conditions in the Canada/Quebec Pension Plan Disability Program, Canadian Public Policy, Vol. 28(3), pg. 419-41, 2002.

Campolieti, Michele and Harry Krashinsky, Substitution Between Disability Support Programs in Canada, Canadian Public Policy, Vol. 29, No. 4, pg. 417-30, 2003.

Campolieti, Michele and James Goldenberg, Disability Insurance Denial Rates and the Labour Force Participation of Older Men and Women in Canada, Atlantic Economic Journal, Vol. 35 (1), pg 59-75, 2007.

Council of Canadians with Disabilities, Disability Income, Supports and Services Project: Consultation Report, Winnipeg, 1998, Available online at http://ccdonline.ca/issues/income-and-benefi ts/consultation-reprt.html

Data Probe, Analysis of the Canada Pension Plan Disability Program Using the Longitudinal Administrative Database, HRSDC, 2010.

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66 Summative Evaluation of the Canada Pension Plan Disability Program

Department of Health and Welfare, The Canada Pension Plan, August 1964.

Doe, Tanis, and Sally Kimpson, Enabling Income: CPP Disability Benefi ts and Women with Disabilities, Ottawa: Status of Women Canada, 1999.

Government of Canada, Defi ning Disability - A Complex Issue, 2003.

Gower, D., “Income Transition Upon Retirement,” Perspectives on Labour and Income, Winter 1998, pg. 18-23.

Gray, David and Ted McDonald, Analysis of CPP Disability Administrative Data for the CPPD Summative Evaluation, HRSDC, 2010.

Gruber, Jonathan, Disability Insurance Benefi ts and Labour Supply, Journal of Political Economy, Vol. 108(6), pg. 1162-1183, 2000.

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House of Commons, Sub-Committee on the Status of People with Disabilities, Listening to Canadians, Ottawa, 2003.

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