Thank you for this opportunity to comment on your deliberations about the creation of a new Ontario Nutritional Supplement Program.
Given the complexity of the issues and constraints facing government on the Special Diet Allowance/Nutritional Supplement Program, our recommendation is that Ontario integrate its deliberations and a decision about this program into the upcoming Social Assistance Review.
We recognize that staff across your ministries have been working diligently over the past few months to try to create a new Nutritional Supplement Program that falls within the constraints the government is currently facing.
These constraints have been outlined to us as:
- Budget constraints arising from the current government deficit, continuing economic uncertainty, and a projection of rising costs;
- Questions around program accountability, as outlined by the Auditor General in a report of December 2009, and a desire to limit administrative costs;
- Restrictions arising from the decision of the Human Rights Tribunal’s decision of February 2010 and the April 2011 deadline on its extension of the systemic remedy requirements.
We can appreciate that the combination of these factors continues to hamper the straightforward and timely creation of a new Nutritional Supplement Program. Indeed, even evaluating the additional costs associated with therapeutic diets is complex enough to have taken considerable time and engagement in the past. For example, the creation of the Special Diet schedule in 1999, a process that engaged more than 20 dieticians with expertise in more than 15 areas, is said to have taken more than eight months. Likewise, the Special Diets Expert Review Committee, which provided detailed information and recommendations on the additional costs arising from the dietary needs associated with particular medical conditions, was engaged in 2006 but did not submit its report to government until 2008.
Given that your government is poised to announce the terms, duration of, and process for a review of social assistance programs, and given the intricacy of the issues and the constraints currently facing government, we feel that the most prudent and practical way forward is to include deliberations about and a final decision on a Nutritional Supplement Program within the upcoming Social Assistance Review. This would ensure that decisions on the Nutritional Supplement Program are not made in isolation but rather take into account the variety of associated issues surrounding Ontario’s social assistance programs.
Including this issue in the Review is also, in our view, an appropriate decision given the constraints that you have outlined to us, which we discuss below.