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Bureaucracy in the making

July 3, 2013

On June 13th, City Council asked Fiona Crean – already working full-time as the City’s Ombudsman – to act as Toronto Community Housing’s eviction monitor. At the same meeting, Council called for a Commissioner of Housing Equity to hear tenant complaints. And then on June 26th, Councillor Mihevc brought forward a motion to add reviews of subsidy calculations to the Landlord Tenant Board’s duties.

Will these changes help TCHC tenants stay housed? I’m not so sure.

After all, TCHC already has — or at least has had — a Managing Director of Human Rights and Equity, a Tenant Complaint Process, and the Internal Review protocol required by the Housing Services Act. Yet of the  79 evicted seniors reviewed in the Ombudsman’s report, only one took advantage of TCHC’s formal Internal Review process. It seems people who do not have the wherewithal to verify their incomes don’t have the wherewithal to lodge appeals either.

Of course I understand why City Councillors voted for these proposals. The natural impulse, when we see a system fail, is to add another layer of accountability. Surely, we think, if we put someone else in charge  – City Council itself, the Ombudsman, the Landlord Tenant Board, a Commissioner of Housing Equity, whoever – things would get better. But we also know that this is how bureaucracies are made — adding layer after layer of oversight until we end up with an even more complicated and top-heavy system than when we started.

Less bureaucracy, not more

So what if we looked for changes that created less bureaucracy, not more? Here are some ideas – some original but most not – that I think might help.

Eliminate income verification for people on fixed incomes. The Housing Services Act says seniors need only verify their incomes every second year. But why review these incomes at all? Seniors rarely get richer as they grow older. And if they manage to earn a little extra income on the side, who cares? Set the rent when they move in, with provision to adjust at the tenant’s request if incomes decline.

The same goes for tenants on social assistance. If they earn a bit of extra money, I say good on them. The time to report is when they get full-time jobs and leave social assistance altogether. TCHC tenants already consent to share information with social assistance offices when they sign their income verification forms. Social assistance could simply give TCHC the signal when tenants leave the system, and lighten the paperwork for TCHC and thousands of tenants.

Simplify income verification for everyone else.  TCHC’s How to Show Proof of Income and Assets Guide calls for a different document for every type of income. Why not reduce it to one: CRA’s Notice of Assessment? Canada Revenue has already done the heavy lifting. Let’s take advantage of it.

And why do tenants need to verify assets when the rent is based on income? Interest earned on assets would be reflected in the Notice of Assessment. As for imputing income from other assets, does every tenant really need to verify their assets to catch the one in a thousand with significant real estate or stock holdings?

Ready to go a step further? Hand the entire job over to Canada Revenue, the nation’s income verification expert — an idea I mentioned in my last entry.

Simplify rent calculations. Do we really need all the bitsy adjustments now in the system: a $2 charge for a clothes dryer, or $2 deduction for a fridge? Why not keep it simple? Your rent is 30% of your gross household income, period.

Security, not subsidy

Most of these suggestions would require changes to Provincial rules. But they would also need a change in public attitudes.

Rent-geared-to-income housing is now treated like a handout. The elaborate bureaucracy is designed chiefly to ensure no-one cheats the system. But what if we treated rent-geared-to-income housing as the foundation for economic security? In other words, what if we treated it like Old Age Security?

Old Age Security is Canada’s biggest handout program. But hardly anyone sees it that way. We believe it is right to give our seniors a dignified old age, and the system is set up accordingly.  No annual income verifications. No elaborate enforcement system. The Federal Government is content to write cheques every month, trusting it can recoup funds from those who don’t need the subsidy at income tax time.

Well, don’t we believe that families and disabled people, as well as seniors, deserve to live in dignity?

Simplifying the rent-geared-to-income system would be a step in the right direction. It would help TCHC staff. It would help TCHC tenants. And it might even save money too.

Now that’s something Toronto City Council could fight for!

3 Comments leave one →
  1. Dr. Rosemary Gray-Snelgrove permalink
    July 3, 2013 8:46 pm

    I love the thrust of this piece, particularly the concluding argument regarding trust as a basis of providing housing. I also like the ideas for simplifying at many levels.

    My only caveat is a small one and I feel petty mentioning it, but my (retired) housing manager’s cap slapped itself on my head as soon as I read the paragraph on simplifying rent calculations. I think there may be ways to do that, but I want to explain why some providers, like me, have found that charging tenants for energy-gobbling appliances seems the only way to manage budgets. Huge hydro cost upswings hit us in summer when personal air conditioners (usually second hand, non-energy efficient) were running day and night. We decided on giving tenants $100 toward buying energy efficient new ones – which would still help us stay within budget. We tried raising money to put central air into the building to no avail. Then there were the big water and hydro rises when a mum got a washer and dryer and used it daily for the several infants in the unit. Total sympathy for the need to keep cool in the heat, and for mothers not wanting to have to go down to the basement to do the laundry (we put in really good washers, and kept the cost low). Only way to handle going way beyond our hydro budget was to charge people whose machines put the costs up. Lousy way to do things, but we were being hammered on several sides by our funders. Never felt right, but we didn’t see what else to do. Failure of imagination – good luck to those still working on it….Rosemary

  2. July 4, 2013 8:41 am

    Joy, thanks for your insightful comments. Too often the reaction of layering in more bureacracy and accountability systems to protect the customer has exactly the opposite effect since added administration only take staff away from the customer as staff must ensure accoutability, compliance and reporting of yet more rules. We need to remember that “less is more” sometimes.

    We are all still awaiting simplicity of the RGI rules to do some of the things you have suggested, namely using CRA’s assessment to verify income. But the Province has yet to pass a regulation under the Housing Services Act to enable this. So housing provdiers are stuck with the complexity of the current RGI system layered on top of the Housing Services Act rules and Resdidential Tenancy Act rules.

  3. Gordon Mack Scott permalink
    July 4, 2013 10:32 am

    While almost all the arguments about simplification are valid, I am hesitant to use CRA documents as verification tools. It seems like the thin edge of the data abuse wedge. Like SINs, these are single purpose tools and should remain so. There is a limit on the number of places core CRA ID info should be stored. And the limit is one.

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