Mar. 17 Update: Questions I’d like answered, along with what we know and what we don’t about the new Ontario Autism Program.

Last week felt like it had more than seven days. Despite that, outside of an education announcement on Monday (which turned out to be pretty much a nothingburger), we didn’t learn much of anything, despite the fact the new “plan” goes into effect April 1.

The Legislature is back in action this week, so that means we have four days of Question Period. I’ve been in the Ottawa bubble long enough to know that, for any legislature, it’s called “Question Period” and not “Answer Period” for a reason. Still, I’m hopeful we get some answers.

In all of these updates, I have my list of 20 questions near the bottom. I’m going to deviate somewhat from them, though. Here’s what I’d like to see opposition politicians ask for from the government:

1. What is the forecasted expenditure for the new plan in fiscal years 2019–20, 2020–21 and 2021–22? What were the assumptions underlying these forecasts? Can they provide this forecasting?
2. When designing this new policy, did the government model employment effects (e.g. therapist jobs), so it could forecast net job losses (or gains). Can it provide that forecast? Furthermore, did it break down the employment effects by region, gender, etc.? If so, could it provide that information?
3. When designing this new policy, did the government estimate the average Childhood Budget size a child would get? Did they do an analysis of how the average Childhood Budget size would be impacted by gender, by region, or by urban vs. rural-remote? Can they provide this analysis?
4. When designing this new policy, did the government estimate how many more parents will leave the labour force due to income-testing of Childhood Benefits? Did the government attempt to estimate the effective tax rates on secondary earners? Furthermore, did they break this down by gender or region? If so, can they provide this analysis?
5. Did the government perform any kind of GBA+ (Gender-based Analysis Plus) on this new policy? If so, can they provide it?
6. Did the government do any analysis on how this new policy will impact the availability of services in rural-remote areas? In Francophone communities? If so, can they provide it? What assurances, if any, can the government provide that these communities will be able to access services?

I’m sure I’ll think of other questions as soon as I hit “post”, but here’s a start.

No changes to the “What we know” list and the Top 20 questions in the last week, because Ontarians aren’t allowed to have nice things. Like answers to basic questions.

New Program

Issue 1: Maximum Per Year Funding

How it works

The funding is based on a Childhood Budget model, where a child is assigned a lifetime budget based on their age when entering the program. There will be rules that govern how much families can spend of that budget each year, though those rules are currently unclear.

For the purposes of calculating the Childhood Budget, the maximum funding is $20,000/yr for kids aged 2–5 (4 years) and $5,000 for kids 6–17 (12 years). Note that this is not necessarily the amount that can be spent in a year, as “[f]amilies will have options in how they receive their budgets. This includes being able to access 20 percent of their remaining childhood budget each year.” (More detail here). We know very little about these options, or how much a family can spend in any given year.

Note that those figures represent the maximum — the actual Childhood Budgets are adjusted basically on a family’s income.

What we know

• The $20,000/$5,000 split is not nearly enough money to purchase ABA, which costs around $80,000/yr.
• Parents cannot use the money to purchase OT or speech therapy but can use the money to purchase iPads. We don’t know if the money can be used for apps, such as speech therapy apps.
• Families will be able to purchase “eligible services” from “the providers of their choice on a fee-for-service basis. This will include behavioural services including assessments and consultations, family/caregiver capacity building and training, respite services, technology aids and travel.” (Source)
• It appears that families can roll-over unused yearly budget into following years, thanks to the Childhood Budget model, but it would be nice to have this confirmed.

What we don’t know

• What services and supports families will be able to purchase (other than what is listed above). We are told this will be released sometime in April 2019, which is after the new program is live! We are not even sure if spending on ABA will be eligible.
• The government’s current explanation of what the money can be spent on: “will include behavioural services such as assessments and consultations, family/caregiver capacity building and training, respite services, technology aids, and travel.”
• How families pay for services (do they pay out of pocket, then submit receipts? A receipts model would be highly problematic, as it would require families to have significant up-front cash. Does the money go direct to providers?) Sarah Jones was able to get some information on this from Amy Fee, but we don’t know if this is official government policy.
• What happens the first year a child is diagnosed. If a child is diagnosed at age 3.5, do they have to wait until their next birthday to receive funding? Do they get the full amount for a 3-year-old? Is the funding pro-rated? (So they’d receive half the amount they would for a full year?)

Issue 2: Means-Testing

The Childhood Budget is means-tested, meaning that the amount of money a family receives in their budget depends on their income. As well, the amount of money families can spend each year from their Budget also depends on their income. Childhood Budgets are re-assessed every year, to reflect changes in a family’s income.

The government has released their sliding scale for income test, for the purposes of calculating the Childhood Budget. More detail on what we know here. Families earning over $55,000/yr will have their Childhood Budget reduced by the income test. Families earning over $250,000/yr will be ineligible for funding altogether.

What we know

• That a dual-earner couple with a combined income of $56,000 from two full-time minimum wage jobs, living in downtown Toronto with 3 kids is considered too rich to receive full-funding.
• The funding formula is the same for single-earner for and dual-earner families, so the program has a rather large built-in “marriage penalty”. (Or put differently, will this program pay families to get divorced).
• The Childhood Budget is reassessed every year to reflect a family’s current income. This has all kinds of unintended consequences, including putting families in a situation where their “available budget” is negative! (More details at: Why the OAP income testing formula stinks.)
• We know the government is defining income, for means-testing purposes, as Line 236 on your tax return (which is standard for these types of programs), which is income after Line 207 through 235 deductions (including child care expenses and RSP contributions) have been applied. So this is “pre-tax” income, but net of some deductions.
• “Once the income testing process is fully automated, Adjusted Family Net Income will be used. Adjusted Family Net Income is your family net income minus any universal child care benefit (UCCB) and registered disability savings plan (RDSP) income you’ve received plus any UCCB and RDSP amounts repaid.” Note that they are referencing the old Harper-era UCCB, not the current CCB which was brought in by the Trudeau government. So any CCB payments are not considered income.This may still affect some families, as I believe it is still possible to receive retroactive UCCB payments. (Note: I was an (unpaid) outside economic advisor to Justin Trudeau prior to the 2015 election and did some of the design work on the CCB. So this is giving me serious flashbacks.)
• The funding and means-testing works for families is unaffected by the number of children you have, whether they are on the spectrum or not. If you have one 11-year-old with a “Childhood Budget” of $15,000, each child would receive a budget of $15,000 if you instead had 11-year-old twins on the spectrum.
• The income test does not take into account a child’s individual needs, nor does it take into account differences in cost-of-living across the province.

What we don’t know

• If families have a substantial change in their financial situation (say a job-lost) in the middle of the year, can they be re-assessed to have their funding reflect their new income level? Or do they have to wait the full year? What is the process for doing so?
• If families have a negative balance in their Childhood Budget, will they be required to pay back the money?

Issue 3: Going from Diagnosis to Funding

How it works

We know next to nothing about how children will transition from being diagnosed to receiving funding when the new program is fully implemented.

What we don’t know

• How long will it take for families to receive funding after a child is diagnosed? Will it be immediate? Will they have to wait a certain amount of time (say 6 weeks)? Or wait until a certain date (say April 1?)
• How does funding “renew”. Let’s suppose a 5-year old child starts to receive funding on October 13, 2021. She turns 6 on November 27, 2021. Does her initial pot of funding extend to her birthday (November 27, 2021)? end of the year (December 31, 2021)?, end of fiscal year (March 31, 2022)?, a full year (October 12, 2022?)? How does the fact she is going from a 5-year old (younger child) to a 6-year old (older child) during that year affect funding?

Issue 4: Data Needed to Forecast Costs

How it works

Outside analysts (like yours truly) would like to be able to estimate how much the government will be spending on this new program. (Note: this is different than knowing how much the government will be budgeting for the program, since a program can run over- or under-budget. In the past, there have been years where the OAP has run overbudget and years where it has run underbudget.)

In order to estimate how much the government is likely to spend, we need to know how the spending rules work for the Childhood Budget. There’s also a number of other important pieces of information we need to know.

What we don’t know

• Forecasted utilization rates for spending.
• How many kids are projected to use the program, along with their ages.

Issue 5: Government’s Forecasts of Costs

How it works

Based on the little information we have, it looks like the government is cutting yearly funding in the range of $50–100M, but honestly, who knows? We would like the government to tell taxpayers and parents what this new program costs, and whether it is less than what the old program would have cost.

What we know

• Between fiscal years 2011–12 and 2015–16, the government spent $180–190M each year. (Data here).
• In fiscal year 2016–17 they spent $254,633,529
• In fiscal year 2017–18 they spent $317,801,400
• The number $321 million, which the government has repeated both in Question Period and on Twitter. What we don’t know is what fiscal year this represents. Note that this would be a slight nominal increase from 2017–18, it would be a real (after inflation) decrease in expenditure, no matter which fiscal year it is for. I explore the issue in: Making sense of the millions.

What we don’t know

• What the government will spend in fiscal year 2018–19 (Which ends Mar. 31, 2019)
• What the government would have budgeted in fiscal years 2019–20, 2020–21 and 2021–22 had there been no changes to the program.
• What the government will budget for fiscal years 2019–20, 2020–21 and 2021–22 under this new program.

Transition from Old Program to New One

How it works

Despite there being less than a month until the new program starts, we know very little on how this works.

What we know

• The transition starts on April 1, 2019
• The transition is expected to last 18 months (that is, until Sept. 30, 2020)
• In advance of this new plan, in 2018 the government stopped providing therapy to children on the waiting list, without telling parents, denying the kids on the top of the waiting list with the therapy they need. Their motives for doing so are in dispute.

What we don’t know

• What changes were made to the OAP in fiscal year 2018–19, by this government (or the previous one), to prepare for this transition. There were rumours going around the community for some time that the Ontario government was not allowing service providers to start treating kids on the waiting list. Those rumours turned out to be true. What else has the government done to the program?
• For children currently receiving funding, how much funding will they receive upon renewal? Will it be the existing amount? The amount from the new funding formula? Something else? Nothing?
• For children currently on the waiting list, how long will it take them to receive funding? What does the process look like? Will they all have to wait until October 1, 2020?
• For children diagnosed during this period, will they receive their funding before October 1, 2020? On Oct. 1? Or will they have to wait a full 18 months? (So a child diagnosed on February 20, 2020 would need to wait until August 20, 2021)
• Will the government continue to spend the same amount of money on services during this period? Or will they be saving money by reducing funding to kids currently receiving treatment while not extending new funding to kids on the waiting list? (as asked earlier)

Mike’s Top Twenty Questions

1. What was the chain of events that led to the program freeze? When did it happen? Why did at least one service provider believe the freeze would only be temporary?
2. Why were parents left in the dark about the program freeze? Why were service providers instructed to keep us ignorant? What purpose did this serve?
3. If the original OAP budget for 2018–19 was $256 million, and an additional $102 million was requested, why is the current budget only $321 million instead of $358 million? Where did the missing $37 million go?
4. Why was the 2018–19 OAP budget only $256 million, when $317.8 million was spent in 2017–18?
5. The “23,000” waiting list number was obtained by amalgamating all the waiting lists into one. Given that some children could be on multiple waiting lists, how many unique children are on waiting lists? How many of those children have never received service before?
6. What is the forecasted expenditure for the new plan in fiscal years 2019–20, 2020–21 and 2021–22? What were the assumptions underlying these forecasts?
7. Why does the new plan take into account family income and a child’s age, but not a child’s needs? How is it a good use of taxpayer money to give some children more money than they need, while providing children with more significant needs only enough money for a few weeks of therapy?
8. For children currently receiving services, will the cost of those services retroactively count against their Childhood Budget, when those budgets go into effect?
9. What goods and services can families purchase under the new plan? Are OT and speech therapy included? If not, why not?
10. What will the transition look like for kids currently receiving treatment?
11. What new supports, if any, will be given to schools as kids who are losing full-time ABA under the new model are put into the classroom?
12. For children currently receiving therapy (either through DSO or DFO), how long will it take them to access new funding when their current funding runs out? Will there be a time gap?
13. On the Ontario Autism Resource page, it states “Families will have options in how they receive their budgets. This includes being able to access 20 percent of their remaining childhood budget each year.” How will this work? Can you provide more details or examples?
14. For the purpose of the income test, how is family income calculated in cases where two individuals have joint custody of a child?
15. The income test has ‘brackets’. Will these brackets be adjusted for inflation each year? If they are not, parents will see their Childhood Budgets reduced as they are pushed into higher income brackets simply for having their wages rise with inflation.
16. Similarly, will Childhood Budgets be indexed for inflation, to reflect the increasing cost of services?
17. How do Childhood Budgets account for ‘partial years’, as it is unlikely a child would enter the program on their birthday? Or will children only become eligible on their birthday?
18. Since Childhood Budgets are adjusted for income each year, it is possible for a family’s past spending to exceed their Childhood Budget, as that budget is revised downward. Will parents be required to pay back any difference?
19. With the elimination of the Direct Service Option, what will the government do to ensure services are available across the province?
20. During the transition, which service providers can parents access, given that the approved list of service providers will not be released for several years?

I likely will be expanding this list in the future.

List of Resources

From the Ontario Government

• Program details from the Ministry of Children, Community and Social Services
• Feb. 6 Press Release: Helping Families by Improving Access to Autism Services
• Feb. 6 Press Release: Ontario Takes Decisive Action to Help More Families with Autism
• Feb. 6 Press Release: Electronic Press Kit Now Available: Ontario Takes Decisive Action to Help More Families with Autism
• Feb. 7 Press Release: New Ontario Autism Program Draws Support From Across the Province. (No press releases since then)