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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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ONIWG-RAC letter to Minister of Labour re Bill 149

January 8, 2024 by Ontario Network of Injured Workers Groups - Research Action Committee

Followup to letter of Nov. 23, 2023. ONIWG encourages the Minister to amend the Workplace Safety and Insurance Act provisions in Bill 149, Working for Workers Act Four, by increasing the percentage of of the Loss of Retirement so it is equal to the pre-accident Canada Pension Plan contributions.

Download ONIWG-RAC letter to Minister of Labour re Bill 149 Continue readingONIWG-RAC letter to Minister of Labour re Bill 149

OLCWCN letter to the Minister of Labour re Bill 149

November 27, 2023 by Ontario Legal Clinics' Workers' Compensation Network

The Network proposes amendments to schedule 4 of the Working for Workers Four Act that would decrease the poverty of injured workers: restore the Loss of Earnings benefit rate to 90% of net pre-injury earnings; restore the WSIB’s contribution to the Loss of Retirement Income benefit to at least 10% of the wage loss benefits; […]

Download OLCWCN letter to the Minister of Labour re Bill 149 Continue readingOLCWCN letter to the Minister of Labour re Bill 149

ONIWG letter to Minister re Cost of Living Adjustments

September 13, 2023 by Ontario Network of Injured Workers Groups

A recent Toronto Star article described how a WSIB coding error in calculating the cost-of-living adjustment (COLA), went unnoticed for 20 years,  shortchanging more than 100,000 injured workers of $42 million. ONIWG’s letter to Minister Monte McNaughton details another situation where the Board is making a significant error in calculating the annual cost of living […]

Download ONIWG letter to Minister re Cost of Living Adjustments Continue readingONIWG letter to Minister re Cost of Living Adjustments

IWC submission on changes to WSIB Appeals Practices & Procedures document

August 26, 2023 by IWC Community Legal Clinic

IWC makes recommendations to the Consultation on Changes to the ASD (Appeals Services Division) Practice and Procedures document, a consultation contemporaneous with the ongoing appeals consultation on the KPMG value for money report and the WSIAT consultation on its appeals process…. The IWC submission focuses on the proposed change of the WSIB’s default hearing method, […]

Download IWC submission on changes to WSIB Appeals Practices & Procedures document Continue readingIWC submission on changes to WSIB Appeals Practices & Procedures document

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

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