Given the far-reaching scope of the review of the Board’s Independent Living policies and their potential impact, IWC submits that they require further in-person/online consultations with stakeholders, especially injured and ill workers, who will be the ones directly impacted by these policy changes. The submission details major concerns on the modified/draft policies with recommendations.
Injured Workers Community Legal Clinic
411-815 Danforth Ave
Toronto, ON M4J 1L2
June 19, 2024
WSIB Consultation Secretariat
200 Front Street West
Toronto, Ontario
M5V 3J1
Sent by email to: consultation_secretariat@wsib.on.ca
Dear Consultation Staff,
Re: The WSIB’s Consultation on Independent Living Policies
Injured Workers Community Legal Clinic is a legal aid clinic with a province-wide mandate. We have specialized in the area of workers’ compensation since 1969. As a legal aid clinic, our services are provided to people with little or no income for no charge. In addition to legal advice and representation, our mandate includes community development, public legal education and participation in law and policy reform.
Thank you for the opportunity to make a submission for Phase 2 of this consultation. We are, however, concerned with the scope of this review and strongly believe that further, more in depth consultation is required.
Section 1: Summary of Positions on Major Issues in the Modified/Draft Policies
The summary positions outlined in this section will be explained in further detail in section 2.
1. Further public consultation is required for each policy
2. There must be proactive adjudication and the establishment of benchmarks for doing so
3. A hybrid approach (threshold percentage + individual assessment) for entitlement to benefits and services in the Independent Living policies.
4. Clarify unclear, restrictive, & exclusionary definitions, such as “serious injury” & “serious illness”
5. Remove categorical exclusions and restrictions
6. Clarify annual rates for benefits and services
7. Eliminate the unnecessary stratification of benefits
8. Remove the unnecessary reviews of entitlements, which creates a culture of fear, uncertainty and anxiety
9. Add in lock-in protections
10. Make changes to the language in various policies
….. [download full submission in PDF or Word]
Download IWC submission to WSIB consultation on independent living policies phase 2