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Ontario Disability Support Program (ODSP) Legal Guide
(20 June 2021)

Chapter 3 - Income Support


  1. Overview
    (a) General
    (b) Example
    (c) Budgetary Requirements
    (d) Consumer Price Indexing (CPI)
    . Overview
    . 'It's Not Normal Indexing'
    . Conclusion
  2. Renters and Home Owners
    (a) Overview
    (b) Basic Needs
    (c) Shelter
    . Definition
    . Maximum Shelter Amounts
    . Shared Accomodation Shelter Expense Allocation
    . Shared Accomodation Shelter Expense Allocation in Public Housing
    (d) Maximum Basic Needs and Shelter for Two Spouses
    (e) Northern Supplement
  3. "Boarders and Lodgers"
    (a) Background
    (b) ODSP Misinterpretation
    (c) Budgetary Requirements Calculation
    (d) "Boarding and Lodging" Component
    (e) "Boarding and Lodging" Northern Supplement
  4. Special Diet Supplement
    (a) Overview
    (b) Eligibility
    (c) Transition Rules from FBA
    (d) Underinclusive Coverage and the Human Rights Code
  5. Pregnancy Supplement
  6. Sponsored Immigrants
    (a) Overview
    (b) Budgetary Requirements of Recipients NOT Living in Sponsor-Controlled Premises
    (c) Treatment of Recipients Living in Sponsor-Controlled Premises
    . Overview
    . Calculation of "Deemed Income"
    . Exceptions
    . Comment
  7. Prisoners
  8. Institutional Residents
    (a) Overview
    . Categorically-ODSP eligible
    . Otherwise-ODSP Eligible
    . ODSP-Ineligible
    (b) Categorically-ODSP Eligible
    . Psychiatric Facilities
    . Centre for Addiction and Mental Health (CAMH)
    . Homewood Health Centre (Guelph)
    . Homes for Special Care Act Facilities
    . SSPSIPDD/A Facilities
    (c) Otherwise ODSP Eligible
    . Overview
    . Long-Term Care Homes
    . Facilities for the Chronically-Ill
    . Corrections-Related Community Resource Centers
    . CFSA Facilities
    . Residential Schools for Vision or Hearing Impaired
    . Abused Women's Interval or Transition Homes (Shelters)
    . General Interval or Transition Home (Shelters)
    . Hospitalization
    . Residential Substance Addiction Treatment Programs
    . Homeless and Living Rough
    (d) ODSP-Ineligible
________________________________________


1. Overview

(a) General

This chapter discusses the primary elements of income support, which include "shelter", "basic needs" and as well some supplements (special diet, pregnancy allowance, northern allowance) which can be added to a recipient's cheque.

While the ODSP definition of "income support" formally also includes most additional "benefits" (ie. drug card, special diet, transportation aid, community start-up and maintenance allowance, etc), which may or may not be provided in money form [Act s.2], these latter are discussed in Ch.4: "Benefits" (see especially Ch.4, s.1: "Important Explanatory Note").

Essential to determining the amount of income support (the amount of the cheque or direct deposit) is the concept of "budgetary requirements" ("BRs"). The following simple formula sets out how income support is determined [Reg s.29(1)]:
Amount of Income Assistance = Budgetary Requirements minus deductions
Deductions such as chargeable income are discussed in Ch.7: "Income Rules". Overpayment deductions are discussed in Ch.11, s.3: "Director Decisions: Overpayments".

(b) Example

Assume a single recipient with a rent of $500 living alone in a bachelor apartment, with $200 chargeable (ie. deductible) income (this is NOT the same as gross employment income). Currently the calculation for this applicant is:
$596 Basic Allowance
$479 Shelter (maximum)
-------
$1075 Budgetary Requirements
($200) Deductible Income
-------
$875 Income Support Amount
(c) Budgetary Requirements

"Budgetary requirements" ("BRs") are amounts, designated by charts and formula below) established by the ODSP regulations, that are allocated for the components of an allowance: mainly, the "shelter" component and "basic needs" component. The amount of these components varies with the size and make-up of the "benefit unit" (another key concept which is explained in Ch.2: "Claimants"). Of course, the more dependents in the benefit unit, the higher the budgetary requirements.

The 'basic needs' component is fixed at an amount which depends on the size and make-up of the benefit unit and is meant for general living expenses like food and clothes.

The shelter component is set at a maximum amount. If a recipient's shelter expense is LESS than the maximum, they get the smaller amount. If the shelter expense (eg. rent) is MORE than the maximum, they only get the maximum [there is an exception to this for exceptional heating costs, see s.2(c) below].

Generally, the total of "basic needs" and "shelter" components equals the total "budgetary requirements". There are however additional amounts (discussed below), such as special diet and pregnancy allowance, which can also increase a recipient's "budgetary requirements".

Note however that "boarders" (and "lodgers") - as opposed to renters and owners - are subject of a different calculation for budgetary requirements. This treatment and the definition of a "boarder" is explained below in s.3.

The concept of "budgetary requirements" also plays a key role in establishing ODSP financial eligibility. If an applicant's monthly deductions are greater than the BRs, then (generally) they are not eligible for income support on the basis of their income, at least for that month (see Ch. 7: "Income Rules").
Note Re Shared Custody or Shared CCTB Eligibility for a Dependent Minor

Where an applicant/recipient shares either physical custody of a child on an approximately equal basis, or shares eligibility for the benefit under s.122.61 of the Income Tax Act [the old Canada Child Tax Benefit] on behalf of the child as a shared custody parent, most non-shelter elements of budgetary requirements above (ie. basic needs, northern allowance, special diet and pregnancy supplement) are reduced by 50% of the amount attributable to that child [Reg s.33.2]. Such 'sharing' of dependent minor children is generally discussed at Ch.2, s.5, and is specifically noted in both the "renter" and "boarder" discussions below.
(d) Consumer Price Indexing (CPI)

. Overview

Following on some harsh worldwide inflation, at 01 June 2023 the province amended the ODSP General Regulation to ostensibly inflation-index the primary components of ODSP income support ('CPI-Indexing') [Reg 29.1]. But these amendments are not yet in force under their own terms, and if and when they are effective [by an "adjustment"], they are far from most peoples' conception of cost-of-living indexing.

The specific 'budgetary requirement' items that are intended to be covered under this regime are the following [Reg 29.1(2)]:
  • Basic needs (renters and owners)

    See Ch.3 'Income Support', s.2(c): 'Renters and Home Owners - Basic Needs' [Reg 30(1)1];

  • Basic needs (renters and owners) maximum (cap') for a spousal couple for shelter and basic needs

    See Ch.3 'Income Support', s.2(d): 'Renters and Home Owners - Maximum Basic Needs and Shelter for Two Spouses' [Reg 30(2)];

  • Shelter rate (renters and home owners)

    See Ch.3 'Income Support', s.2(c) 'Renters and Home Owners - Shelter' [Reg 31(2)2 (the chart)];

  • Shelter (renters and home owners)- When Cost of Heating Exceeds Chart Maximum

    See Ch.3 'Income Support', s.2(c) 'Renters and Home Owners - Shelter (Maximum Shelter Amounts)' [Reg 31(2)5];

  • Institutional Residents

    See Ch.3 'Income Support', s.8 'Institutional Residents' [Reg 32(1)2,3];

  • Board and Lodging Rates

    See Ch.3 'Income Support', s.3 'Boarders and Lodgers' [Reg 33(1)1,2,2.1].
. It's Not 'Normal' Indexing

The primary difference between classical indexing and this limited ODSP CPI-Indexing is that classical indexing seeks to ensure that the recipient's buying-power remain the same despite inflation, commonly a simple measuring of inflation following by a subsequent identical rate increase - typically annually.

This new ODSP CPI-Indexing is odd in several respects, and has present ambiguities which hinder prediction as to it's intended form. For instance:
  • Communication of the Rate Increase

    Prior to these Reg amendments [2/23], the province periodically (and if so, annually) increased these budgetary requirements components by re-issuing messy Reg amendments which had to be 'manually' updated in charts the Ontario Laws database (also the Canlii database).

    These charts will still persist. But now if and when a CPI-Increase 'adjustment' takes place [rounded-to the nearest dollar: Reg 29.1(5)] the increase will be 'deemed' to have occured, without the charts being updated [Reg 29.2(3)]. Instead, the ODSP Director will publish newly-'adjusted' charts on the Government website "(b)efore July 1" [Reg 29.1(8)].

  • 'Triggering' an Adjustment

    The more concerning aspect of this new - and as yet uninitiated - ODSP indexing regime is: when and by how much 'adjustments' will be.

    Rather than rate increases being determined simply by looking to the last year's inflation, as it would be in what I am calling 'classical' indexing, no ODSP adjustment (ie. rate increase) "shall occur during a year if the cost of living index for the year is less than the cost of living index for the last year during which an adjustment occurred" [Reg 29.1(6)]. In other words, if annual inflation is lowering or static when assessed, no adjustment is made that year - ie. the budgetary rates stay the same. On the other hand, if annual inflation is increasing then an 'adjustment' can be made.
. Conclusion

This s.29.1(6) rule naturally gives rise to indexing irregularity, but it's predictability is even more uncertain. When an 'adjustment' is finally made, what this ODSP regime does is - rather than looking to the last year to determine it's rate increase, this system looks to the last year during which an adjustment occurred, which could be several years - even decades - before [Reg 29.1(4,7)]. This makes the inflation calculation practically impossible, and - given that these ODSP CPI indexing rules are subject to political (ie. cabinet) modification - renders the primary goal of CPI indexing, that of ending the 'politicization' of social assistance rates, meaningless. It is hard not to view this scheme as a facade.


2. Renters and Home Owners

(a) Overview

This category: "renters and owners" [Reg s.30] applies to determine budgetary requirements in most recipients' situations (including those of homeless people not living in shelters). The status of homeless applicants is generally addressed in the welfare (Ontario Works) program in Chapters 2: "Claimants" and Ch.3: "Basic Assistance".

The budgetary requirements of those who receive 'board and lodging' (room plus meals) are treated separately in section 3 below. The definition of "boarder/lodger", as opposed to 'renter', is discussed at length in that section.

The following are the items (each explained below) included in determining the BRs of a "renter/owner":
  • Basic needs [s.2(b) below]
  • Shelter [s.2(c) below](renter/owner)
  • Northern supplement [s.2(e) below]
  • Special diet [s.4 below]
  • Pregnancy Supplement [s.5 below].
Note Re Shared Custody or Shared CCTB Eligibility for a Dependent Minor

Where an applicant/recipient shares either physical custody of a child on an approximately equal basis, or shares eligibility for the benefit under S.122.61 of the Income Tax Act [the old Canada Child Tax Benefit] on behalf of the child as a shared custody parent, most non-shelter elements of budgetary requirements above (ie. basic needs, northern allowance, special diet and pregnancy supplement) are reduced by 50% of the amount attributable to that child [Reg s.33.2]. Such 'sharing' of dependent minor children is generally discussed at Ch.2, s.5.
(b) Basic Needs

'Basic needs' are the amounts fixed by law as below [Reg s.30(1)1].

Column 1: Number of dependent adults included in the benefit unitColumn 2: Recipient if there is no spouse included in the benefit unitColumn 3: Recipient with spouse included in the benefit unit, if Column 4 is not applicableColumn 4:
Recipient with a spouse included in the benefit unit if each of the recipient and the spouse is a person with a disability or a person referred to in subparagraph 1 i of subsection 4 (1) or paragraph 3, 5.1, 5.2, 6, 7 or 8 of subsection 4 (1)
0$706$1,018$1,409
1$1,094$1,216$1,607
2 or more$1,293$1,437$1,828

Column 1: If more than two dependent adults are included in the benefit, an additional amount of $222 for each subsequent dependent adult included in the benefit unit.

Column 2: An amount of $143, in the case of a benefit unit in which no spouse is included and all dependants included in the benefit unit are less than 18 years old.

Column 4: See sub-section (d) "Maximum Basic Needs and Shelter for Two Spouses", below. Practically this covers most situations of dual-ODSP eligibility. While it does not apply where ODSP eligibility is based on facility or institutional residence as discussed in Ch.2 "Substitutes for PWD Status", such a recipient would not normally be co-habiting with spouses at such times. Similarly, most other grand-parenting categories are now either spent due the age of the recipient (over 60 or 65 years of age categories), or were 'hived-off' to the Ontario Works (welfare) system (single parents) in June of 1998.

OCB Note:
Since July 2008 basic needs amounts for children were reduced in conjunction with the introduction of the Ontario Child Benefit (OCB) and the elimination of the National Child Benefit Supplement (NCBS) clawback. Under this change recipients are, for the most part, presumed to be in receipt of OCB and the NCBS - thus making up for the basic needs reduction. The Ontario Child Benefit scheme is explained in detail at Ch.7, s.6.

(c) Shelter

. Definition

'Shelter' refers to expenses related to maintaining a dwelling place which is a principal residence. It does not include expenses related to premises or buildings in which the benefit unit does not reside.

Note that where a recipient is RECEIVING rent as a landlord or as a chief tenant subletting), then such rental income is assessed SEPARATELY from the shelter expense calculations set out here (see Ch.7, s.4: "Income Rules: Rent Paid to a Claimant").

The "shelter" component of the budgetary requirement of a renter/owner is determined by totalling the amount of the following monthly expenses, subject to maximums set out in the chart below [Reg s.31].

Eligible shelter expenses include:
  • rent for dwelling place, other than amounts for parking and cable;

  • principal and interest on a mortgage, loan or an Director-approved repair loan respecting the property;

  • occupancy costs paid under an agreement to purchase the dwelling place;

  • property taxes;

  • premiums for an insurance policy with respect to the dwelling place or its contents;

  • reasonable and necessary expenses, approved by the administrator, for the preservation, maintenance and use of the dwelling place;

  • if the shelter is a condominium or co-op housing then the common expenses required, except that portion of the common expenses allocated to the cost of energy for heat;

  • cost of an energy source used for household purposes other than for heat (eg. hydro);

  • water and sewage;

  • rent of a furnace and a hot water heater;

  • rent under a land lease;

  • the cost of energy for heat.
In most situations the largest of these expenses will be rent or mortgage payments. Typically this alone is enough to push the shelter expense to the maximum allowed (see chart below).

. Maximum Shelter Amounts

The total of the above shelter expense covered cannot exceed the maximums set out here (EXCEPT in the rare situation where the cost for heat exceeds the maximum shelter amount, then the shelter cost shall be the actual cost for heat [Reg s.31(2)2]).

Benefit Unit SizeMaximum Monthly Shelter Allowance
1522
2821
3889
4964
51,041
6 or more1,078
Note 1:
Where the benefit unit consists of only the recipient and a spouse, see sub-section (d) "Maximum Basic Needs and Shelter for Two Spouses", below.

Note 2:
Where a co-resident applicant and a spouse are both eligible in their own right for ODSP under the conditions set out in 'Basic Needs' Note 1 above, then the shelter allowance will be increased by $76 per month [Reg 31(2)5].
. Shared Accomodation Shelter Expense Allocation

Prior to 01 August 2010 the General Regulation included rules for how to allocate the shelter component of budgetary requirements when benefit unit members shared accomodation with others not in their benefit unit (ie. those not on social assistance, and those in another benefit unit). On that the date those rules were repealed.

The starting principle (the formula was a bit complex) of calculating the shelter component under those rules was a simple equal division of shelter costs for the residence (typically rent and utilities) amongst the sharing adult co-residents (children were not 'counted').

One beneficial feature of the calculation under the old rules was that no shelter 'share' was allocated to anyone who provided daily physical assistance on an ongoing basis to the recipient or spouse where the recipient or spouse requires assistance in order to function in a community setting (ie. a "care-giver"). The net effect of that rule was to increase the shelter expense of the care recipient for ODSP budgetary requirement purposes (which was beneficial if the maximum shelter amount had not yet been reached), without influencing the 'contractual' sharing arrangements made between the 'sharers'. Those rules happily tolerated situations where the shelter component allocated to the benefit unit was actually more than what they in fact paid.

With the repeal of these rules the determination of the shelter component of a single ODSP recipient or benefit unit that shares accomodation must default to the actual financial terms of the sharing. So if a two-adult and one child benefit unit shares a $1000 apartment (while paying $400), with a single adult not on social assistance (paying $600), then the benefit unit's shelter component will be $400 - in accordance with the co-resident's actual 'contractual' sharing arrangement.

This 'new' rule (or non-rule) thus creates an incentive for sharing residents (whether on social assistance or not), to set the agreed rent and utilities share of the benefit unit at - or close to - the maximum shelter component available (in that example, and at the date of writing that amount would be $816).

Extreme examples of such arrangments (eg. where the benefit unit is allocated all of the common shelter expenses, while the others pay nothing) could be limited by the 'improvident disposition of assets' provisions [see Ch.8, s.7], or even - quite conceivably - as a form of conspiracy to defraud the government. It remains to be seen how vigorously ODSP (and welfare administrators, where a similar repeal was made) will push the issue.

Lastly, keep in mind that situations where recipients themselves act as landlords or chief tenants (ie. subletting) are not sharing situations. Those are treated as conventional landlord/tenant situations with the sublettor (chief tenant) being in the position of the landlord, and the sublessee being the 'tenant'. As well, in situations where a recipient is the sublettor, income chargeability against them from such arrangements is treated in accordance with the normal income rules for landlords (see Ch.7 "Income Rules: Rent Paid to a Claimant").

. Shared Accomodation Shelter Expense Allocation in Public Housing

There is a specific provision in the General Regulation addressing the allocation of shelter expense when a recipient resides in public subsidized housing with others who are not in the benefit unit [Reg 31(2)6]. It provides that "shelter does not include that portion of the rent for which the applicant or recipient is liable with respect to a person living in that rental accommodation who is not a member of the benefit unit."

This provision anticipates joint liability for the full rent shared between such people, but leaves the determination of the benefit unit's shelter expense ambiguous as the determination of the recipient's "share" is a matter of policy established by the housing provider. In such cases inquiries can be made of the housing provider - however as a matter of practice ODSP simply applies the shelter 'splitting formula' set out above in "Shared Accomodation Shelter Expense Allocation".

Note that situations of sub-letting within such subsidized units are typically barred by public housing rules.

(d) Maximum Basic Needs and Shelter for Two Spouses

The maximum payable ("cap") for a spousal couple for shelter and basic needs is $2,070 [Reg 30(2)].

Of course, couples are still entitled to have their budgetary requirements increased above this "cap" by special diet, pregnancy and northern supplements - and to the "benefits" set out in Ch.4: "Benefits".

(e) Northern Supplement

If the benefit unit resides north of the 50th parallel and does not have year round road access then add the following amounts to "budgetary requirements" [Reg s.30(1)2]:

# of Non-Spousal DependentsRecipientRecipient & Spouse
0272431
1430530
2526628
For each additional dependent: $102

3. "Boarders and Lodgers"

(a) Background

ODSP has a separate way of calculating budgetary requirements where the recipient "receives board and lodging from the same source" [Reg s.33(1)] (as opposed to "renters and owners", discussed above).

The terms "boarders' and 'lodgers' are old common law terms that refer to what are technically known as 'licensees' - a term largely superceded by statutory changes rolling them into residential tenancy law as full "tenants".

The common law has its own test as to when it will categorize an occupation of premises as a "license" (ie. boarder or lodger) rather than as a "tenancy". This test is flexible and looks at a variety of characteristics (all of which are judged cumulatively), such as (there can be more):
  • absence of exclusive possession (the primary criterion: whether the occupant DOES NOT have the contractual right to sole possession of the premises);

  • only one private room;

  • sharing a bathroom and/or kitchen (ie. the unit is NOT self-contained);

  • whether the unit is part of a building referred to as a 'boarding house' for municipal regulation purposes.
A "boarder" was a licensee who got a room AND meals (although technically it could mean just meals) and a "lodger" just got a room. These old distinctions still persist in ODSP and welfare law - although they are often misinterpreted by ODSP authorities. Because of this recipients should not complacently accept the categorization placed on them by ODSP, and may want to consider advocating for or appealing for a change to "renter" in order to increase assistance.

(b) ODSP Misinterpretation

For purposes of determining budgetary requirements, ODSP law doesn't distinguish between "boarders" (ie. with meals) and "lodgers" (ie. without meals) as discussed above [though it does for purposes of boarder/lodger rental income: see Ch.7: Income Rules"]. The budgetary requirements of both are determined under the same rules [sub-section (c) below].

However ODSP - and welfare - tend to treat ANY situation where food is provided by the landlord under these rules - EVEN THOUGH the underlying legal relationship is one of tenancy - not license. Thus a recipient living in a full tenancy (ie. a conventional apartment with exclusive possession), and also getting meals included in the arrangement - is typically wrongly assessed under the "boarder/lodger" rules. These situations arise sometimes when older parents allow their adult son or daughter to reside in a separate self-contained apartment - attached or close to the main family home (eg. a basement apartment) - with parents providing meals for their disabled offspring.

All that being said, which categorization of living arrangement is most advantageous to the recipient is not always clear-cut. Calculations should be run under both "renter" (above) and 'boarder and lodger' (below) formulas to determine which generates the greater "budgetary requirements" to benefit the recipient. Recipients can then advocate - or even legally restructure - their situations accordingly.

***********

(c) Budgetary Requirements Calculation

The budgetary requirements of a 'boarder and lodger' are calculated as follows:
  • Boarding and Lodging Component [s.3(d) below]
  • Northern supplement [s.3(e) below]
  • Special diet [s.4 below]
  • Pregnancy Supplement [s.5 below]
  • and $71 'special boarder allowance'.
Note Re Shared Custody or Shared CCTB Eligibility for a Dependent Minor

Where an applicant/recipient shares either physical custody of a child on an approximately equal basis, or shares eligibility for the benefit under S.122.61 of the Income Tax Act [the old Canada Child Tax Benefit] on behalf of the child as a shared custody parent, most non-shelter elements of budgetary requirements above (ie. basic needs, northern allowance, special diet and pregnancy supplement) are reduced by 50% of the amount attributable to that child [Reg s.33.2]. Such 'sharing' of dependent minor children is generally discussed at Ch.2, s.5.
(d) "Boarding and Lodging" Component [Reg s.33(1)]

Members of Benefit UnitSingle RecipientRecipient and Spouse
Recipient and/or Spouse867One ODSP: 1292
Both ODSP: 1727 * Note 1
Add for Each 18 yrs Plus DependentFirst 486
Add'l 239
239
Add for Each 13-17 yrs Dependent First 293
Add'l 145
145
Add for Each 0-12 yrs DependentFirst 255
Add'l 107
107
Note 1:
In the last column: "Recipient and Spouse (Both ODSP)" applies to situations where both applicant and spouse are ODSP-eligible BUT ONLY where their eligibility is based on either:

- being found to be a "person with a disability";
- being CPP-disabled eligible;
- grand-parenting of FBA eligibility on basis of being blind, disabled or PUE (permanently unemployable) status
- being in receipt of a disability pension under paragraph (b) of section 105 of An Act Respecting the Quebec Pension Plan
- persons determined to be eligible for services and supports and funding under the Services and Supports to Promote the Social Inclusion of Persons with Developmental Disabilities Act, 2008.
- residents, and former residents if they are resident after 01 January 2018, of facilities established, licensed or approved by the province under the Homes for Special Care Act (typically, former residents of long-term provincial psychiatric facilities) [Reg 4(1)5, 5.1];
- residents and former residents of homes that are part of the program of the Ministry of Health and Long-Term Care known as Community Homes for Opportunity [Reg 4(1)5.2];
- being persons in receipt of an award under the English and Wabigoon River Systems Mercury Contamination Settlement Agreement Act, 1986.

Practically this covers most situations of dual-ODSP eligibility. While it does NOT apply where ODSP eligibility is based on facility or institutional residence as discussed in Ch.2 "Substitutes for PWD Status", such a recipient would not normally be co-habiting with spouses at such times. Similarly, most other grand-parenting categories are now either spent due the age of the recipient (over 60 or 65 years of age categories), or were 'hived-off' to the Ontario Works (welfare) system (single parents) in June of 1998.
(e) "Boarding and Lodging" Northern Supplement

If the benefit unit resides north of the 50th parallel and does not have year round road access then additional amounts are added as follows [Reg 33(1)3]:


# of Non-Spousal DependentsRecipientRecipient & Spouse
0272417
1420506
2511599
For each additional dependent: $99

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Last modified: 04-02-24
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