PDD Safety Standards Consultation Phase 2
PDD Safety Standards Consultation Phase 2
Phase 2 Feedback
Deadline July 6, 2016
The PDD Safety Standards Regulation, which was problematic on so many levels, was repealed by the Minister of Human Services in response to the Phase 1 Consultation Report. The failure to consult with the developmental disabilities’ community in the development and implementation of the Standards, was one of the principal reasons for the Standards to have been so problematic. Now is the time to ensure the government moves in the right direction by providing your feedback to the Phase 2 proposals, which can be found at Phase II PDD Safety Standards Consultation. On the basis of your feedback the final recommendations will be prepared and submitted to the government in the hopes that these recommendations will be adopted to enable individuals with developmental disabilities to lead safer lives in community.
There is an overwhelming preponderance of experience and research that supports inclusion as a principal means of enabling individuals with developmental disabilities to lead safer and more meaningful lives in community. Individuals with developmental disabilities must have the support and means to an enriched and meaningful life, and in that and with that context, safety needs to be considered. It would be a serious mistake to try and create safer lives without first considering what is required to support individuals with developmental disabilities to live valued and meaningful lives.
We encourage everyone to respond, at the very least, by completing the online survey and for those able, to participate in the webinars. There will also be a few specific small focus groups for invited participants.
Inclusion Alberta would like to suggest the following considerations in responding to the Phase 2 Consultation Discussion Guide Proposed Ideas. This is not a commentary that addresses every point to be considered but is offered as a general guideline to facilitate discussions and input into the consultation process.
Proposed Idea 1
PDD Program Review
Feedback in Phase One confirmed that individuals are safest when they are connected to their community. This is best achieved through a PDD system that supports inclusion, works to align services to achieve the best possible outcomes for individuals, and has the trust and confidence of the people it serves.
- Undertake a review of the PDD program to enable safer lives in community for individuals with developmental disabilities
- Develop a broader engagement model/means of open communication between PDD and the disability community that will build trust and support positive interactions.
With the end of the Supports Intensity Scale (SIS), announced by the Minister of Human Services, separate from the Review of the PDD Safety Standards, but as welcome, a review of the PDD program becomes even more urgent. Without input from the developmental disabilities community, there is no guarantee government will replace SIS with something more respectful and helpful. And given the ongoing reorganization of the Department of Human Services with an interest in creating a more integrated response to individuals with the developmental disabilities, this too adds to the necessity for a program review. It should go without saying that any review must be conducted with the disability community (individuals, families, providers and allies) at the table as partners rather than being the subject of a review,
For decades, families have asked government to create a response to the needs of adults with developmental disabilities that was at least as expansive as that of the Family Supports for Children with Disabilities (FSCD) program. Eligibility for the PDD program was more closely aligned with FSCD before government moved to a single IQ score in determining eligibility. Requiring an IQ score and then determining eligibility on the basis of that score is demeaning and in conflict with the ethical requirements of how and why psychological testing is to be performed. A program review should look at how supports and funding should flow over the lifespan without an abrupt reconsideration and possible break in supports at age 18.
The role of government should be to provide funding for supports and services while ensuring accountability relative to the use of public funds. To this end a program review should examine how government can create enabling legislation, policies and actions to enable individuals with developmental disabilities to achieve an inclusive and meaningful life – this is the outcome government should be seeking. Governments cannot and should not be responsible for managing individualized and personalized planning that leads to an inclusive life, just as it is should not be and is not responsible for determining the life of any other Albertan. As such, a program review should deeply consider how the means of individualized and personalized planning can be provided through independent community and family based resources. It is on the basis of these plans and what would be needed to achieve a meaningful and inclusive life that funding decisions should be made. When the proposed outcomes of an individualized plan are not being achieved, then government should enable the needed reviews, analysis and actions for progress to be made. Government can neither plan for individuals nor ensure outcomes are achieved, but they can support personalized and individualized planning to be available at the community level and the development of effective services and supports.
To build trust and positive interactions will require a change in the culture of PDD at the frontline level from one where frontline workers are only empowered to say “no” to requests for funding and supports with every “yes” seemingly requiring a review at supervisory or managerial levels. Trust can also be established by ensuring there is an effective advisory body to government representative of the developmental disability community and whose advice government demonstrates it is following. As noted above separating planning and the determination of what is needed to achieve the desired outcomes from funding decisions, will contribute to a more open relationship with government. Naturally government may not agree to a particular plan and/or its costs, but this is more open and honest. However, this allows for much better assessments as to the difference between what is needed to achieve a safer thus inclusive life and what government is able to offer. This then contributes to much better systems planning as to what will be needed in the future.
When government plans for individuals this is always compromised by the simple reality that funding questions are more paramount than whether it is a right and good plan. As such, there are too often occasions when the PDD’s plan is to simply insert an individual in an open and already funded “space” rather than truly consider what an individual requires to pursue an inclusive and meaningful life. This further contributes to there being little information as to the difference between what is needed to support personalized and individualized supports and what is available.
Idea 1 should become a recommendation.
Proposed Idea 2
Training and Education
Quality support services are an important contributor to the health and safety of individuals. Front-line staff provide a variety of supports to individuals with developmental disabilities. Currently, there is no provincial minimum educational or certification requirements for staff working with persons with developmental disabilities.
- Require staff working with persons with developmental disabilities to possess post-secondary education that includes specific training in providing supports to people with disabilities.
- Require staff working with persons with developmental disabilities to be professionally certified.
- Staff salaries should be commensurate with position and required qualifications and experience.
- Safety experts continue to provide information and materials to individuals with developmental disabilities, their families and service providers on how to take steps to live safely in their homes and communities.
In the 1970’s Alberta developed and implemented one and two year post-secondary education programs for people who wanted to work and be hired in the field of developmental disabilities. A one year certificate or a two year diploma were often required for someone to work in the field. Eventually a bachelor and graduate program applicable to the developmental disabilities field were also developed at the University of Calgary. In addition, those hired to work in supporting people with developmental disabilities would be paid according to the positions they were hired into, and the education and experience needed for those positions. Government always maintained this approach for those it employed but this was gradually lost within the community sector. Government did not maintain the same commitment to those working in the community sector although those working in community are almost always much more hands on with individuals with developmental disabilities than government employees; and thus far more likely to affect life outcomes, either negatively or positively than a government employee.
As a consequence of the lack of support for the development disability sector, which can be starkly contrasted with the government’s commitment to the child care sector, we have moved from a province where there were once about 10 post-secondary programs specific to training people to work with people with developmental disabilities, to one or two programs remaining. And now, as the Phase 2 Discussion Guide notes, in too many instances no training is required and there is little provision for enabling people to be paid according to their training and position. This field has become one, not where people pursue a career out of a commitment to individuals with developmental disabilities but a field where people work on their way to a career in some other field. They literally move in waves through the lives of individuals with developmental disabilities on their way to a life, leaving the person with a developmental disability to be supported by the next untrained and underpaid staff person.
Some years ago now, this was a direction the child care field was moving in, but as it would seem children without disabilities are more valued than individuals with disabilities, government , with the child care communit,y created post-secondary training programs for people to work in child care, established criteria for required training levels for particular positions, ensured salaries were commensurate with training and positions and provided time and incentives for those currently in the child care field to obtain the necessary training. The very same approach can be applied to the field of developmental disabilities. While this approach will take years to be fully achieved, this is far better direction to be moving in, then the current one that has been moving in the opposite direction for years to the very serious detriment of individuals with developmental disabilities.
Enabling individuals with developmental disabilities to have fulfilling, safe and inclusive community lives, requires skilled and knowledgeable staff. The degree of skill and knowledge required cannot be achieved without post-secondary programs and continuing requirements for and access to continuing skill development. The combination of required trained and commensurate wages will improve staff retention. Staff need to know both the individuals and their family as well as understand and have sustained relationships with the community into which individuals are to be included.
There is no need to reinvent the proverbial wheel. There is no need to start from scratch as curriculums for post-secondary training programs to work in the developmental disabilities which were created in Alberta, still exist even though many programs no longer exist, and are offered in other parts of Canada. As such, curriculums only need to be updated not necessarily completely recreated. Government has a history of successfully moving in this direction in partnership with the child care community and as the developmental disability community stands ready to partner, past plans can be utilized and built upon.
Idea 2 should become a recommendation.
Proposed Idea 3
Contracted service providers are required to obtain and maintain accreditation standards at least every three years through Alberta Council of Disability Services Creating Excellence Together (CET). The CET standards measure quality of service, organization, governance, and operational effectiveness and how these factors impact clients’ reporting on quality of life
- Strengthen accreditation standards in the areas of health and safety to reflect the critical individualized safety requirements in the homes of people with developmental disabilities. This could also include increasing the frequency of monitoring for compliance with those standards.
This idea needs to be carefully considered as it runs the risk of the re-imposition through accreditation of repressive and oppressive standards in the private homes and housing of individuals with developmental disabilities. Preserving the essence of home must be a priority so as to minimize any institutionalization of the homes of individuals in the name of safety. The Safety Standards were an example of home being sacrificed in the name of safety. Compromising the integrity of home actually increases risks and vulnerabilities, it does not reduce them.
Additional accreditation requirements could be tied to staff training, knowledge and practices, the lack of which all played critical roles in most previous instances where health and safety were seriously compromised. Accreditation requirements that supported and enabled more inclusive lives in community, would also contribute to safer lives in community.
Proposed Idea 3 should be a carefully considered recommendation applied primarily to staff requirements and health and safety in the context of preserving the essence of home.
Proposed Idea 4
Safety Code Interpretation
Withdraw the August 2015 Municipal Affairs Standata.
Apply the following principles relating to the interpretation and application of safety codes:
- Residences occupied by individuals with developmental disabilities which lease or own are not “PDD residences” or facilities.
- The starting point in relation to the homes of people receiving support from PDD should be that they are residential dwellings, in the same manner as any other home.
- The source of financial or service support being received by a person living in a home should not be relevant to how the building codes are interpreted and applied to that home. That is, homes of people receiving support through PDD should be treated no differently from the homes of people not receiving public support, or receiving it from another source. Any change of use or alternative classification under the building code should be assessed as it would be for any Albertan living in similar circumstances.
- Measures required under safety codes for all Albertans should be affordable, enforceable, and meaningful so that compliance can be achieved within the circumstances where people live.
Review the Safety Codes, as is normally done, and consider measures that would be of value to improving safety in the broad range of circumstances in which Albertans live consistent with the above principles. Any such measures should be implemented only after carefully consultation with all potentially impacted groups, for example seniors, people with disabilities, others with limited mobility or receiving in-home staff support.
That Municipal Affairs staff and municipal inspectors be offered education from Inclusion Alberta, Alberta Council of Disability Services (ACDS), and individuals with developmental disabilities in understanding the homes and residences of individuals with developmental disabilities.
In more simple terms:
- The places in which people with developmental disabilities live are homes first and should not be labelled by Government as facilities (this is not intended to apply to residences approved and licensed under Supportive Living Accommodation Licensing Act).
- Consider that people may have different safety needs based on their circumstances.
The misapplication of the building and safety codes may have been one of most serious concerns arising out of the PDD Safety Standards Regulation. Principally this appears to have occurred when the PDD program advised health and building inspectors, that the homes of individuals with developmental disabilities were PDD facilities. In our view that this was taken at face value exemplifies the vulnerability of individuals with developmental disabilities when the notion of a true home can be wiped out without much thought or consideration. As such, it is essential that the integrity of the homes of individuals with developmental disabilities be secured and not subject to any oppressive regime that acts without such consideration.
The fundamental point of this recommendation is to acknowledge that the homes of individuals with developmental disabilities are not different than the homes of anyone else. Needing to support to live in one’s own place should never be construed as a means for governments to turn the homes of individuals into facilities. A far better approach would be for those responsible for building and safety codes in general to take into account that individuals with developmental disabilities live in the very same residential dwellings as anyone else. In keeping this reality in mind improvements to the building and safety codes could be made to the advantage of all while retaining the essence of home. In this way individuals with developmental disabilities contribute to the well-being of everyone.
Proposed Idea 4 should become a recommendation.
- Encourage municipalities to develop a tool similar to the voluntary Vulnerable Person Self-Registry in Calgary.
- Consider the creation of an independent Disability Advocates Office (or Ombudsmen) or the provision of additional supports to independent self-advocacy and family advocacy efforts.
The idea of self-registry is not new however its utility of adding to safety is not known, at least to our knowledge. Inclusion Alberta does not hold a strong opinion on this idea as long as it is voluntary. Lists of individuals with developmental disabilities, as with the PDD Safety Standards, have as much or more a history of being a problem than a solution.
On the merits of the second “Other Ideas”, self-interests aside, we are far more in favour of strengthening the voice and capacity of the self-advocacy and family advocacy than in more government positions. Reinforcing and sustaining the capacity of community advocacy is a far better investment of government funds in advancing safer and inclusive lives than a Disability Advocate who would most likely be8 appointed by and answerable to government rather than the developmental disability community.
Inclusion Alberta favours “the provision of additional supports to self-advocacy and family advocacy efforts”.
Click here to participate in Phase II of the PDD Safety Standards Consultation. **Deadline is July 6, 2-16.**
For more information: