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Home / Resources / Law and Policy Submissions

Law and Policy Submissions

Recent documents are in both PDF and html formats but all may be available in alternate formats on request.

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IWC submission re WSIB consultation process on changes to the appeals system

July 21, 2023 by IWC Community Legal Clinic

Submission addresses the lack of true consultation with those most affected – injured workers – on the major changes proposed and erosion of the right to appeal, based on recommendations of the KPMG Value for Money Audit of the dispute resolution and appeals process. IWC presents lessons from past WSIB policy and reform consultations that […]

Download IWC submission re WSIB consultation process on changes to the appeals system Continue readingIWC submission re WSIB consultation process on changes to the appeals system

OLCWCN Commentary re KPMG Value for Money Audit (VFMA) Dispute Resolution and Appeals Process

June 5, 2023 by Ontario Legal Clinics' Workers' Compensation Network

Letter to the WSIB Chair underscores that the auditor’s findings that make a number of errors which demonstrate a lack of understanding of Ontario’s workers’ compensation system. If adopted, the recommendations will negatively impact injured workers’ access to justice – many of the most vulnerable injured workers won’t be able to appeal their decisions and […]

Download OLCWCN Commentary re KPMG Value for Money Audit (VFMA) Dispute Resolution and Appeals Process Continue readingOLCWCN Commentary re KPMG Value for Money Audit (VFMA) Dispute Resolution and Appeals Process

Complaint to the Ombudsman regarding WSIB drastically reducing time to appeal

April 25, 2023 by IWC Community Legal Clinic Thunder Bay & District Injured Workers' Support Group

Following a community consultation, Thunder Bay injured workers group and IWC call for a meeting with the Ombudsman to address WSIB response to key recommendations made by the KPMG Value for Money Audit of the appeal system, in particular the proposed drastic reductions to the time to appeal which would disentitle most injured workers.

Download Complaint to the Ombudsman regarding WSIB drastically reducing time to appeal Continue readingComplaint to the Ombudsman regarding WSIB drastically reducing time to appeal

IWC submission on WSIB’s draft policy on communicable illnesses

March 28, 2023 by IWC Community Legal Clinic

IWC supports the WSIB initiative to develop a policy for communicable illnesses but identifies a number of concerns, among which that it is highly restrictive, fails to apply the standard test for causation and the principle of individualized assessment.

Download IWC submission on WSIB’s draft policy on communicable illnesses Continue readingIWC submission on WSIB’s draft policy on communicable illnesses

OLCWCN submission re Communicable illnesses policy consultation

March 28, 2023 by Ontario Legal Clinics' Workers' Compensation Network

The Network’s submission on the proposed draft policy makes detailed recommendations  that would ensure entitlement decision-making for communicable illness claims is guided by the evidentiary principles of Ontario’s workers’ compensation law.  The OLWCN also strongly supports those submissions calling for a separate policy on COVID-19, given the severity of health consequences and the number of […]

Download OLCWCN submission re Communicable illnesses policy consultation Continue readingOLCWCN submission re Communicable illnesses policy consultation

IWC Submissionto WSIAT’s New Pre-Hearing Process Consultation

January 13, 2023 by IWC Community Legal Clinic

IWC makes recommendations on the changes proposed by the Tribunal to reduce delays, urging instead the elimination of time limits, simplification of the process and forms.

Download IWC Submissionto WSIAT’s New Pre-Hearing Process Consultation Continue readingIWC Submissionto WSIAT’s New Pre-Hearing Process Consultation

IWC submission on Temporary Employment Agency Rate Setting (clerical work exemption)

November 16, 2022 by IWC Community Legal Clinic

While IWC support the WSIB’s approach to align Temporary Employment Agency (TEA) rates with the rates of their clients’ classes, the Clinic details in its second submission why the proposed modification to create an exception for “clerical labour” is not appropriate…

Download IWC submission on Temporary Employment Agency Rate Setting (clerical work exemption) Continue readingIWC submission on Temporary Employment Agency Rate Setting (clerical work exemption)

IWC submission to Consultation on Serious Injury Program and Independent Living Policy suite

October 14, 2022 by IWC Community Legal Clinic

Submission notes that almost all of the benefits outlined in the Independent Living Policy Suite legally (under ss. 32, 33 of the Workplace Safety and Insurance Act) are and should continue to be available to all injured workers – not only those defined by the WSIB as “severely impaired.” Brief also makes recommendations on criteria […]

Download IWC submission to Consultation on Serious Injury Program and Independent Living Policy suite Continue readingIWC submission to Consultation on Serious Injury Program and Independent Living Policy suite

Thunder Bay & DIWSG Submission to the WSIB Serious Injury Program consultation

October 13, 2022 by Thunder Bay & District Injured Workers' Support Group

Response to phase I of the WSIB’s consultation on the Independent Living policy suite, following the value-for-money audit of the Serious Injuries Program. In addition to feedback on the specific consultation questions, the submission highlights the negative consequences suffered by many injured workers with serious injuries resulting in a permanent impairment, the need for a […]

Download Thunder Bay & DIWSG Submission to the WSIB Serious Injury Program consultation Continue readingThunder Bay & DIWSG Submission to the WSIB Serious Injury Program consultation

IWC submission on Temporary Employment Agency rate setting

June 29, 2022 by IWC Community Legal Clinic

The Clinic’s position has long been that the experience rating system is ineffective in improving health and safety, and encourages claims suppression. Until eliminated, submission recommends that temporary employment agencies move to their new applicable premium rate established by the WSIB.

Download IWC submission on Temporary Employment Agency rate setting Continue readingIWC submission on Temporary Employment Agency rate setting

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