Special Priority Policy Review within Domestic Violence

Special Priority Policy Review within Domestic Violence Action Plan

Report to Stakeholders

Ministry of Municipal Affairs and Housing Housing Division

July 2006

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Table of Contents

1.0 Introduction ........................................................................................................................3

Consultations on the Special Priority Policy ...............................................................................3

Where are we at now?..................................................................................................................3

What are the next steps?...............................................................................................................3

2.0 Background.........................................................................................................................4

Special Priority Access for Victims of Abuse under the Social Housing Reform Act ..................4

Brief History of the Special Priority Policy .................................................................................4

3.0 Report to Stakeholders for Feedback – Work Group Recommendations and Options for Consideration............................................................................................................................5

3.1 Time Limit for Submitting Applications ...........................................................................5

3.2 Definition of Abuse...........................................................................................................6

3.3 Indicators of Abuse...........................................................................................................7

3.4 Verification of Abuse........................................................................................................8

3.5 Statement/Record of Abuse and Verbal Follow-up ..........................................................9

3.6 Verifying “living with” Criteria.......................................................................................9

3.7 List of Professional Verifiers..........................................................................................11

3.8 Ranking within the Special Priority Household Category .............................................12

3.9 Review of Special Priority Status ...................................................................................12

3.10 Requests for Internal Transfers under the Special Priority Household Category.........13

3.11 Implementation Strategies..............................................................................................14 Special Priority Policy, Education and Training....................................................................14 Need for Supports...................................................................................................................14 Leaseholder Status and TPA ..................................................................................................14

4.0 Recommendations with Broader SHRA Implications ..................................................16

4.1 Arrears Provisions .........................................................................................................16

4.2 Internal Review Processes and Application Timelines ..................................................16

4.3 Refusal of Three Offers ..................................................................................................17

4.4 Special Priority Applicants in Multiple Service Areas...................................................17

5.0 Key Government Initiatives ............................................................................................18

5.1 MCSS Initiatives under the DVAP .................................................................................18

5.2 Strengthening the Justice System Response ...................................................................19

5.3 Affordable Housing for Victims of Domestic Violence ..................................................19

Questionnaire, pages i to vii

Appendix “A” - Work Group Report and Final Recommendations Appendix “B” and “C” – Special Priority Policy Provisions in Regulation

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1.0 Introduction Consultations on the Special Priority Policy In recent years, the government has heard stakeholders express varying concerns about the Special Priority Policy under the Social Housing Reform Act, 2000 (SHRA). The Special Priority Policy provides priority access to social housing for victims of abuse. Under the policy, households that have a member or members who are abused can request to be included in the Special Priority Household Category which provides priority placement on the social housing waiting lists.

Upon learning of stakeholders’ concerns about the policy, the Minister of Municipal Affairs and Housing made a commitment to review the provincial priority access policy within the government’s broader strategy and action plan on the issue of domestic violence. The Government of Ontario is committed to better protect and support victims of domestic violence. The government’s vision for its action plan is one where women and their children can live free from the fear of domestic violence, and know that there is appropriate intervention and support should domestic violence occur.

In November 2004, the Ministry of Municipal Affairs and Housing (MMAH) formed a work group to review the Special Priority Policy and to develop recommendations for regulatory changes that strengthen the protection provided to victims of abuse and improve implementation. Strengthening the policy is among the key initiatives under the government’s action plan to improve the community supports available to victims of domestic violence.

The work group met regularly over the course of 2005 and was comprised of key stakeholders: regional representation of municipal service managers, domestic violence organizations, housing provider organizations, legal clinic and access centers representatives, the Ontario Women’s Directorate (OWD) with the Ministry of Citizenship and Immigration, the Ministry of Community and Social Services (MCSS), and the Ministry of the Attorney General (MAG).

Where are we at now? In December 2005, the work group finalized their recommendations for a number of regulatory amendments and implementation strategies. The ministry has prepared this report which includes the recommendations from the work group and outlines suggested approaches and options for possible regulatory amendments.

What are the next steps? The report is being circulated to a wider set of stakeholders: all 47 municipal service managers, additional domestic violence organizations and key province-wide organizations.

The ministry would like to provide our stakeholders with an opportunity to review the work group recommendations and the options for consideration before proceeding with potential regulatory amendments.

You are invited to provide your comments on the work group recommendations and options outlined in Section 3 of this report. At the end of the report is a questionnaire that corresponds to Section 3 which you can submit to us in addition to other issues you may wish to comment on. Please submit your responses by August 8th, 2006 to:

Mary Fantauzzi, Sr. Policy Advisor, Housing Division, Municipal Affairs and Housing, 2nd Floor, 777 Bay Street, 2nd Floor, Toronto, ON M5G 2E5, Fax: 416-585-7003, Email: [email protected].

We look forward to hearing from you.

Doug Barnes

Assistant Deputy Minister

mailto:[email protected]

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2.0 Background Special Priority Access for Victims of Abuse under the Social Housing Reform Act The Special Priority Policy under the Social Housing Reform Act, 2000 (SHRA) provides priority access to social housing for victims of abuse. Under the policy, households that have a member or members who are abused and apply for rent geared-to-income (RGI) assistance or special needs housing, have a mandatory priority on the waiting lists. The policy is intended to provide priority access to housing for victims of abuse who have been abused by someone they are or have been living with, or by someone sponsoring them as an immigrant, and from whom they intend to separate permanently. Municipal service managers who administer the policy have flexibility to waive certain criteria in order to reduce barriers for victims of domestic violence. Key objectives of the policy:

• To protect the safety of the applicant and other household members by enabling them to leave an unsafe and abusive situation.

• To protect individuals’ privacy and confidentiality.

• To ensure timely processing of special priority applications (e.g. determination of eligibility, notice of decisions) given the risks to safety.

• Special provisions re RGI eligibility recognizing the nature of abusive relationships. Brief History of the Special Priority Policy Prior to the devolution of social housing to the municipal sector, the Special Priority Policy had been in place in the public housing sector since 1986. By 1994, the policy was introduced to the provincial non-profit programs and became a key component of the Modified Chronological Resident Selection System (MCRSS) implemented in 1997. Upon the transfer of social housing to the municipal sector, the Special Priority Policy moved to a legislative/regulatory framework applicable to the public and non-profit housing programs prescribed under the Social Housing Reform Act, 2000 (SHRA). When in 1986 the Ontario Housing Corporation (OHC) - a provincial crown agency which owned and managed public housing - adopted the Special Priority Policy, a uniform system and guidelines for processing applications was created. Over the years, there were subsequent revisions of the policy as awareness of domestic violence grew and in consultation with key stakeholders. For example, the policy was expanded to include other applicants that could be subject to abuse (e.g., children, seniors), and later the policy was modified to become gender neutral to be inclusive of all potential female or male applicants. When the province adopted the Modified Chronological Resident Selection System, OHC and provincial non-profit and co-operative housing providers were required to participate in the one-window access system which was a combination of mandatory and optional priorities including the mandatory priority placement for persons who are abused. The special priority guidelines for non-profits were not as detailed as those of OHC’s policy. The reality was grim then as is the case today – women continue to be the primary victims of violence and leaving a violent relationship increases the risk to a woman’s safety. The policy is in keeping with the government’s ongoing commitment to respond to the housing needs of abused women and their children and to enhance programs and services for women wanting to leave an abusive partner.

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3.0 Report to Stakeholders for Feedback – Work Group Recommendations and Options for Consideration

Your opinions and views are important to us. Please provide your feedback on the following work group recommendations and options being proposed for possible regulatory amendments. We have provided a questionnaire at the end of this report that corresponds to the options/questions for consideration. See questionnaire for contact information and mailing instructions. For more details on the work group recommendations and discussions, please refer to Appendix “A”. Key regulatory provisions related to the Special Priority Policy have been provided in Appendix “B” and “C”. 3.1 Time Limit for Submitting Applications Currently in regulation, when the abused individual no longer lives with the abuser, the request for special priority should normally be made within three months after they cease to live together. The municipal service manager may allow a request to be submitted later if the service manager is satisfied that it is appropriate under the circumstances. The set of circumstances for consideration to waive the three-month rule are as follows: a) No member of the household was aware of the policy b) No member of the household was aware of the time limit c) The abused member is at risk of further abuse d) The abused member is at risk of returning to the abusing individual due to financial hardship that could be alleviated if the

member received RGI assistance e) The abused member is in need of RGI assistance to alleviate financial hardship arising from legal proceedings in relation to the

previous abuse or f) The abused member is attempting to use the provision of RGI assistance as part of an overall program recovery and

reestablishment of a safe and normal life. [Refer to Appendix “C” for O. Reg. 298/01, Subsection 24 (14)]

The Hadley Inquest recommendation was to consult on the three-month timeline in consideration of the latest data on periods of risk of violence upon separating from the abuser. Latest data from Statistics Canada (2001) show that risk of abuse upon separation can extend up to and beyond one year of separation (refer to Appendix A, “Stakeholder Work Group Final Recommendations”, page 1). Work Group Recommendations The work group reviewed the eligibility criteria and reached general agreement to maintain the three-month rule but recommended that service managers must waive the three (3) months where the verifiers of abuse (i.e., professionals listed in regulation who can verify the abuse) demonstrates that the abused individual is at risk of further abuse from the abusing individual. The verifier would be required to provide a professional opinion as to why the applicant is still at risk of further abuse. The work group also recommended removing the remaining considerations listed above as all perspectives agreed that the acceptance of applications beyond three months should be based on the key criterion of further risk of abuse from the abusing individual. The work group discussed some of the general implementation concerns: women’s groups raised concerns about maintaining the three-month timeline and OAITH (the Ontario Association of Interval and Transition Houses) preferred to see the time limit extended to four (4) to six (6) months; some service managers questioned whether the proposal without an upper limit would go beyond the intent to enable separation from the abuser.

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A question was also raised about some of the verifiers of abuse currently listed in regulation and their ability to demonstrate or provide a professional opinion on an applicant’s risk of further abuse particularly those professionals working outside of the VAW (violence against women) sector such as such as doctors, lawyers, teachers, guidance counsellors, members of the clergy, property manager, etc. As discussed among the work group members, the presence of indicators or actual abuse/threats at the time of application suggests risk of further abuse. Women’s groups pointed out that there would be other cases where the threat of further abuse exists but the actual abuse, threat or indicator would not be present at the time of application. 3.1 Time Limit for Submitting Applications – Option/Question for Consideration To ensure a request for inclusion in the Special Priority Household Category is accepted beyond the three-month time limit where the verifier of abuse is able to demonstrate to the service manager on a reasonable basis that the applicant is at risk of further abuse from the original abusing individual. What is your feedback? Given the complexity in determining risk of further abuse, please provide your feedback on the following method to assist in determining further risk of abuse: a) that one or more of the existing indicators are still present, b) that the abuse is current or ongoing, or c) that there is continued risk of further abuse. 3.2 Definition of Abuse The work group discussed the current definition of abuse in O. Reg. 298/01: “an incident of physical or sexual violence against an individual, an incident of intentional destruction/injury to an individual’s property, or words, actions or gestures that threaten an individual or his or her property.” The current regulations also include a list of records of abuse which service managers must accept as verification of abuse. These records (generally described as indicators of abuse) further define the nature of abuse (see section 3.3 for the work group’s recommendations and further discussion on indicators of abuse). Work Group Recommendation There was consensus from all perspectives for changes to the definition of abuse in order to set the context of abuse within an abusive relationship and establish a more expansive, contextual basis rather than focus on any incident of abuse. The work group agreed to adopt the Policing Standards Manual definition of domestic violence with some changes to set the context of an “abusive relationship” as follows:

“For the purpose of this regulation, abuse is any use of physical or sexual force, actual or threatened, in an intimate relationship, including emotional or psychological abuse, undue or unwarranted control over the abused member’s financial activities, harassing or stalking behaviour. Although both women and men can be victims of abuse, the overwhelming majority of this abuse involves men abusing women. Abuse in intimate relationships includes partner abuse, elder abuse, child abuse, inter-sibling abuse, abuse by a family member (e.g., parent, child, in-laws) or a live-in caregiver who is a relative. These relationships vary in duration and legal formality. These acts are often committed in a context where there is a pattern of assaultive and controlling behaviour. This abuse may include physical assault, emotional assault and psychological and sexual abuse. It can include threats to harm children, other family members, pets and property. The abuse is used to intimidate, humiliate and/or frighten victims, or make them powerless. The abuse may include a single act of abuse. It may also include a number of acts, which may appear minor or trivial when viewed in isolation, but collectively form a pattern that amounts to abuse.”

The work group was divided on the inclusion of the term “duration” when describing the nature of an abusive relationship. Women’s groups wanted the inclusion of the term to recognize that the nature of relationships

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and alternative/unconventional relationships can vary. The work group also discussed the difficulty in placing a time limit on what constitutes a relationship. There was general acknowledgement at the work group table that the more expansive definition proposed in its entirety could present challenges within a regulatory framework. While there were original suggestions to focus the policy and definition to address woman abuse, it was pointed out that as the policy evolved over the years, it was expanded to include other applicants that could be subject to abuse (e.g., children and elders), and to be inclusive of all potential female or male applicants. At the same time, it is recognized that the prevalence of violence is against women and the Special Priority Policy is in keeping with the government’s ongoing commitment to enhance programs and services for abused women and their children. 3.2 Definition of Abuse – Option for Consideration To amend the definition of abuse in keeping with the work group’s key objectives to set the context of domestic violence and abuse within an abusive relationship which includes partner abuse, elder abuse, child abuse, abuse by family members, by a live-in caregiver, abuse within same-sex relationships, and other alternative relationships. What is your feedback? 3.3 Indicators of Abuse Service managers must accept, as verification of the abuse, any of the records described in O. Reg. 298/01, subsection 25 (4) that is prepared by individuals described in subsection 25 (5) [see section 3.7 for list of individuals] whether the record is disclosed in writing or in verbal form. Upon a number of reviews of the policy over the years, the records (or indicators) of abuse were expanded to reflect the nature of abusive relationships and to provide better direction to staff responsible for processing applications. For example, there was the expansion to include psychological abuse recognized as a real form of abusive behaviour that is complex and can take many forms. Work Group Recommendations The work group reviewed the current provisions and proposed additional records (indicators) to further describe the nature of abuse. Front-line workers from municipal administrators to the VAW (violence against women) sector felt that the records of abuse (generally described as the list of indicators of abuse) continue to provide a helpful tool during the verification review processes. See next page for “Option for Consideration”.

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3.3 Indicators of Abuse – Option for Consideration To add to the current list of records (or indicators) of abuse in keeping with the work group’s proposed additions highlighted in bold below: (4) The record referred to in subsection (3) is any of the following: 1. A record of intervention by the police indicating that the member was abused by the abusing individual. 2. A record of physical injury caused to the member by the abusing individual. 3. A record of the application of force by the abusing individual against the member to force the member to engage in sexual activity against his or her will. 4. A record of attempts to kill the abused member (or another member of the household). 5. A record of the use of a weapon against the abused member. 6. A record of words, actions or gestures by the abusing individual that threaten the member or his or her property including, but not limited to, the following: i. Threats to kill the abused member or another member of the household. ii. Threats to use a weapon against the abused member or another member of the household. iii. Threatening to physically harm the member or another member of the household. iv. Destroying and/or injuring or threatening to destroy and/or injure the member’s property. v. Intentionally killing and/or injuring pets or threatening to kill and/or injure pets. vi. Threatening to harm and/or remove the member’s children from the household. vii. Threatening to prevent the member from having access to his or her children. viii. Forcing the member to perform degrading acts or acts of public humiliation. ix. Terrorizing the member. x. Enforcing social isolation upon the abused member. xi. Threatening to take action to withdraw from sponsoring the member as an immigrant. xii. Threatening to take action that might lead to the member being deported. xiii. Other words, actions, threats, or gestures which lead the member to fear for his or her safety. 7. A record of undue or unwarranted control by the abusing individual over the member’s daily personal or financial activities. 8. A record of stalking and/or harassing behaviour. [Refer to Appendix “C”, O. Reg. 298/01, Subsection 25 (4)] What is your feedback? 3.4 Verification of Abuse As mentioned above, service managers must accept, as verification of the abuse, any of the records described in subsection 25 (4) of O. Reg. 298/01 that is prepared by individuals described in subsection 25 (5) whether the record is disclosed in writing or in verbal form. [Refer to Appendix “C”, O. Reg. 298/01, Subsection 25 (3)]. Work Group Recommendation To address the difficulties municipal administrators have in processing applications when they receive verbal verification, the work group recommended that the verification of abuse be stated in writing and that the current provision allowing verbal verification be removed. 3.4 Verification of Abuse – Option for Consideration To require written verification of abuse [removing the option for verbal verification currently in subsection 25 (3) of O. Reg. 298/01]. What is your feedback?

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3.5 Statement/Record of Abuse and Verbal Follow-up In determining whether a request for special priority status is complete, the service manager must consider whether he/she has received all other information or documents (in addition to the signed request and signed consent from the applicant), including information and documents from a third party, for the purpose of verifying the statement of abuse [O. Reg. 298/01, Subsection 24 (16)]. Subsection 24(8) further establishes that the onus is on the member making the request for special priority status to provide such information and documents as the service manager may require for the purpose of verifying the statement of abuse. This means that if service managers are not satisfied that the statement has been verified, they can ask the applicant to provide further information and documents for the purpose of verification. Work Group Recommendation Municipal administrators of the program described how sometimes they receive written forms/records of abuse without sufficient detail and that is why verbal follow-up with the verifier (third party) would be helpful in these cases. To assist the verification review process, the work group agreed to allow service managers to verbally follow up with the professional/verifier of abuse in order to clarify the verification of abuse provided in writing. Upon further consideration of the work group’s proposal for allowing verbal follow-up with the verifier, it is plausible that in some cases, the verifier of abuse who is contacted by a municipal administrator may be reluctant to provide additional information verbally regarding the abused member given the confidentiality and personal nature of the information requested. With or without authority in regulation, it is possible that some verifiers/professionals would not be prepared to provide additional information verbally (such as over the phone) afraid of placing the safety of the applicant or other household members at risk. There is also the risk of the disclosure of information collected during the application process to the abuser or someone who might provide the information to the abuser. A second option is to maintain the current provisions. At the same time, the work group’s recommendation/option of requiring only written verification (i.e., removing the verbal option currently in regulation) and the assistance of a verification tool developed at the local level would also help reduce the need for verbal follow-up with a third party.

3.5(a) Statement of Abuse and Verbal Follow-up – Option 1 for Consideration To give service managers the authority to verbally contact the individual producing/verifying the record of abuse where insufficient information is provided. What is your feedback?

OR,

3.5(b) Statement of Abuse and Verbal Follow-up – Option 2 for Consideration To maintain the current provisions as is, i.e. leaving the onus on the member making the request for special priority status to provide such information and documents as the service manager may require for the purpose of verifying the statement of abuse. What is your feedback? 3.6 Verifying “living with” Criteria The work group reviewed subsection 24 (3) in O. Reg. 298/01 which requires that a request for special priority status be made only where a member of the household has been subject to abuse from someone that they are or have been living with, or from someone who has sponsored them as an immigrant (whether or not the abused member lives with the sponsor), and the household member intends to live permanently apart from the abuser. The request must include applicants’ statements declaring that these criteria are met.

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The intent of the policy to provide priority access to permanent housing for applicants who wish to separate permanently from their abuser. However, it is acknowledged that in some situations, attempts may be made to resolve issues and/or reconcile. (For further discussion on the landlord/tenant relationship, see section 3.11, Leaseholder Status and the TPA) Work Group Recommendations The work group agreed to accept the applicant’s self-declaration to verify the intent to separate from the abuser (as per the current provisions). The work group also agreed to maintain the current provisions requiring verification of the statement of abuse but with one proposed amendment to require the statement of abuse be in written form and removing the current option for verbal verification (refer to section 3.4 - Verification of Abuse). The work group reviewed the criteria under clause 24(3)(b) which requires that the individual be abused by someone that they are or have been living with, or by someone who has sponsored them as an immigrant. The provisions recognize that leaving a violent relationship increases the risk to household member(s) safety; the provisions also recognize the dependent nature of immigration sponsorship arrangements and potential for control issues and the sponsor’s access to the abused within or outside a common living arrangement. The work group agreed to include the “living with or having lived with” criteria as subject to verification, i.e., making explicit the authority of service managers to request verification of the “living with” criteria (i.e. proof of cohabitation) with the proviso of reasonableness and flexibility when requesting the verification. The work group discussed the nature of abusive relationships and how taking steps to obtain the information can sometimes place the applicant’s safety at risk and other situations where the information is not obtainable (e.g., abused woman’s name is not on the lease and the difficulty to establish having lived with the abuser). In the current regulatory framework, service managers can waive certain criteria and use the policy in a more flexible way such as waiving information where they are satisfied that it is not obtainable. There are also provisions which prohibit requests for certain information and under certain circumstances, e.g., where there are safety concerns. The work group reviewed the number of safeguards in regulation with respect to requests for documentation:

• The service manager cannot require information or documents from more than one of the professionals listed to verify the abuse. [O. Reg. 298/01, Subsection 24 (12)]

• If the service manager is satisfied that the member making the request or a third party is unable to provide information or a document, the service manager shall not require the member or the third party to provide that information or document. [O. Reg. 298/01, Subsection 24 (9)]

• If the household member believes that he or she will be at risk if he or she attempts to obtain the required information or document/s, the service manager must not require the household member to provide the information or documents. [O. Reg. 298/01, Subsection 24 (10)]

• The service manager must not require information about whether legal proceedings against the abuser have been commenced and must not require information or documents pertaining to such proceedings. [O. Reg. 298/01, Subsection 24 (11)]

The work group did not reach agreement on allowing service managers the discretion to waive the “living with” criteria. There were concerns from service managers that removing the “living with” criteria altogether from the qualification requirements would go beyond the intent to enable separation from the abuser, and faced with very long waiting lists and service managers want a means to establish those most in need are being helped. 3.6 Verifying “living with” Criteria – Option for Consideration To include the “living with or having lived with the abuser” criteria as subject to verification with the proviso of “reasonableness” of documents requested. Service managers required to waive the verification (proof of cohabitation) where a) applicants feel they will be at risk in obtaining the documents or b) where the service manager is satisfied the information is not obtainable. Abuse by an immigration sponsor would continue to qualify within or outside a common living arrangement with the abused. What is your feedback?

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3.7 List of Professional Verifiers In O. Reg. 298/01, service managers cannot require information or documents from more than one of the professionals listed in regulation to verify the abuse. [O. Reg. 298/01, s. 24 (12)] This provision and others alike throughout the regulatory framework reflect the need to achieve a balance between obtaining adequate information about abuse and not being overly intrusive in requiring information that is of a very personal, confidential nature and which may place the safety of the applicant or other household members at risk. The list of verifiers currently listed in regulation:

1. A doctor 2. A lawyer 3. A law enforcement officer 4. A member of the clergy 5. A teacher 6. A guidance counsellor 7. An individual in a managerial or administrative position

with a housing provider

8. A community health care worker (defined in s. 25(6) 9. A social worker (defined in s. 25(6) 10. A social services worker (defined in s. 25(6) 11. A victim services worker (defined in s. 25(6) 12. A settlement services worker (defined in s. 25(6) 13. A shelter worker (defined in s. 25(6)

Work Group Recommendations The work group reviewed the current verifiers/professionals able to verify the abuse and agreed to add the title and definition of a community legal worker; to adopt a more inclusive definition for a member of the clergy; the work group also agreed on a description for a community services worker to capture a category of workers who may not be members of a college or registered with a specific certifying body but in their role are qualified to verify abuse. The work group also agreed to ensure a professional relationship exists between the abused and the verifier of abuse. 3.7 List of Professional Verifiers – Option for Consideration In line with the work group’s proposals, to allow the following: 1. the verifier to provide the statement of abuse in their professional capacity; 2. adding community legal workers among the current list of professionals who can verify abuse; 3. add a definition for a member of the clergy that is inclusive of all faiths; and 4. to capture workers described as community services workers who, while not registered with a specific registered body, are able and qualified to verify abuse. Community Legal Worker: “Community legal worker means an individual employed by a community legal clinic who provides legal aid services in the area of clinic law, within the meaning of section 2 of the Legal Aid Act, 1998.” Member of the Clergy: “Minister of Religion licensed to perform a marriage in the Province of Ontario.” Community Services Worker defined as:

For the purposes of this regulation, community services worker means an individual who is employed by a community service or government agency, for the purpose of providing social support services in the community. Examples of titles that fall under this category include but are not limited to:

- Housing and Outreach Worker - Homeless Shelter Staff - Housing Help Center Worker - Mental Health Clinician - Housing Support Worker - Transitional and Housing Support Worker - Immigration Worker - Community Support Worker - Child Protection Worker - Homeless Support Worker - OW/ODSP Case Worker

What is your feedback?

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3.8 Ranking within the Special Priority Household Category Under the Special Priority Policy, a special priority household has the highest ranking above all other applicants on the waiting list. Within the Special Priority Household Category, an applicant at greater risk of abuse has priority over all other special priority applicants. Where applicants are deemed to be at the same level of risk, those currently living with the abuser have priority. In all other cases where there is the same level of risk and common living arrangement (i.e., living with the abuser or not), ranking special priority applicants is based on the date of their application for special priority status. (Refer to O. Reg. 298/01, Section 42.) In terms of ranking levels of risk among special priority applicants, service managers spoke to their inability to assess levels of risk and raised serious concerns about the associated liability, the lack of resources and the necessary expertise required in any form of risk assessment. It was further pointed out that ranking levels of risk among special priority applicants is an unworkable task (e.g., ranking a new applicant against 10 or more applicants already on the waiting list). Work Group Recommendation The work group made it clear that without the proper expertise and resources, there should be no ranking. It was felt by the work group that until an effective approach is established, ranking be done by chronological date of application. VAW representatives agreed with the recommendation while pointing out that ranking by date does not recognize the reality of women in high risk situations who should be housed first. MMAH will continue to review the issue of ranking to help arrive at some solutions. 3.8 Ranking within the Special Priority Household Category – Option for Consideration Until a more effective system is established, to allow ranking among special priority households based on the chronological date of application. What is your feedback? 3.9 Review of Special Priority Status Once it has been determined that a household is eligible for the Special Priority Household Category on the waiting list, this decision is not subject to ongoing review and the status must not be changed, regardless of how long the household is on the waiting list. [Refer to O. Reg. 298/01, Subsection 25(7).] Work Group Recommendations The work group discussed various criteria for removing special priority status while applicants are on the waiting list. Service managers pointed out that where special priority applicants may wait several months for housing, that during that time circumstances may change (e.g., abuser is added to the application, abuser dies or is incarcerated, victim partners with or marries someone else, etc). Women’s groups explained that while death of the abuser removes the risk to the applicant, relocation and incarceration of the abuser does not. Women’s groups also raised concerns about the ongoing review and scrutiny of special priority applicants bringing further intrusion in the lives of women. Service managers concerned about maintaining the integrity of the program and their administrative processes do not want to see an ongoing systematic review but felt they should have the ability to review a file where they receive credible information/documentation.

The work group agreed that the focus to address any cases of misrepresentation should be on the verification review process. The work group reviewed the general structure of the SHRA which deals with ineligibility as illustrated in s. 12 of O. Reg. 298/01 which spells out grounds where a household originally found eligible for rent geared-to-income assistance then ceases to be eligible. The work group also discussed the list of grounds

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in O. Reg. 339/01, sub-sections 18(1) and (2) on the basis of which a housing provider can refuse to offer a unit to a household. The Special Priority Policy provides priority access to housing for member(s) of a household who are abused and who wish to separate permanently from their abusers. If while on the waiting list or at the time of being offered a unit, the applicant adds the abuser to the application, the work group recommended that special priority status be removed as this action effectively nullifies the applicant’s statement of intent to separate. The work group also agreed to remove special priority status where the applicant (the abused individual) reports that the abuser is deceased (which removes the risk of abuse). 3.9 Review of Special Priority Status – Option for Consideration To remove special priority status while applicants are on the waiting list where the applicant reports: adding the abuser to the application (or at time of offer of a unit), or that the abuser is deceased. It would be important under this option that any changes in information be provided by the original member who is abused. Women’s groups pointed to concerns about reliance on third party information that could be misused by others and possibly used as a means of sabotage by the abuser or other parties. What is your feedback?

3.10 Requests for Internal Transfers under the Special Priority Household

Category In O. Reg. 339/01, housing providers are required to maintain a list of current tenants in their housing project(s) who require a transfer to another unit for a number of reasons. For example, existing tenants can apply for an internal transfer and request to be included in the Special Priority Household Category. Housing providers are required to review households’ eligibility under the special priority category and to rank all special priority applicants higher than other households on their internal transfer list. [Refer to O. Reg. 339/01, section 11, Internal Transfers.] Work Group Recommendation The work group discussed the challenges of non-profit housing providers working within the current legislative/regulatory framework including providers’ responsibility to process internal requests under the Special Priority Policy. The work group agreed to transfer this responsibility to service managers/access centers who process special priority applications on a more regular basis. 3.10 Requests for Internal Transfers – Option for Consideration To transfer responsibility for determining special priority eligibility of internal transfers to service managers/access centers who would do so on behalf of housing providers. What is your feedback?

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3.11 Implementation Strategies While the work group focussed on the application/eligibility review process, there were a number of recurring themes throughout the discussions: from the need for better education and training on the policy and the sharing of best practices, to the accompanying supports needed once special priority applicants (victims of domestic violence) are housed and become tenants/members in a housing project. Special Priority Policy, Education and Training During the discussions on the regulatory provisions, the work group repeatedly agreed on the importance of training and the need for consistent application of the regulations while ensuring “reasonableness” and flexibility on the part of the administrators who process special priority applications. The regulatory framework, particularly around the Special Priority Policy, reflects the need to achieve a balance between obtaining adequate information about the abuse and not being overly intrusive by requiring information that is of a very personal, confidential nature and which may place the safety of the applicant or other household members at risk. As part of a multi-pronged approach, the ministry will continue to work with its municipal partners to improve the implementation of the policy. Training on the Special Priority Policy for municipal service managers will be delivered as part of the rent geared-to-income and waiting list management training models. The ministry will be reviewing its training curriculum regarding the Special Priority Policy and its communication tools in consideration of the recommendations and suggestions from the work group. (See also section 5.1 below on training social housing providers on the issue of domestic violence.) Need for Supports The work group recognized the need to support women once they are housed and discussed the current initiatives funded by MCSS to support women in securing and maintaining their housing. The work group agreed that housing is an important part of the solution but felt more resources to supplement the existing support programs are needed for successful outcomes. Housing provider groups and service managers raised some of the complex issues from the increased percentage of special priority households in projects and the need for the accompanying supports. For example, housing providers report that there is a much higher rate of successful tenancies for women who are victims of violence where there is funding for a community development worker within buildings/communities. Everyone also recognized the importance of working together across sectors to help find solutions. While access to housing under the Special Priority Policy is not the only solution to domestic violence, it is a vital support system that provides victims of abuse a viable option to secure permanent housing and leave an abusive relationship. The cross-sectoral initiatives funded by the Ministry of Community and Social Services (MCSS) are important steps to supporting victims of violence - from housing provider training to improving linkages to the community support services. As detailed below in section 5.1, MCSS has allocated funds to the Transitional and Housing Support Program in the amount of $3.5 per year beginning in 2004/05, with an additional $1M/year beginning in 2006/07 (see section 5.1 for more details). The roll-out of these and other programs will assist in determining the responsiveness of the continuum of services across sectors. Leaseholder Status and TPA When discussing the prevalence of violence against women and the nature of abusive relationships, a key concern shared by work group members was for the woman’s safety and the protection of her tenancy. There was agreement among all perspectives that to help protect the woman’s safety the abuser should be prevented from signing the lease so that the woman maintains the right to the unit. Strategies discussed included the importance of community agencies’ support to abused women in their decisions, and counselling and advising women on mechanisms to protect their tenancies.

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The work group raised a number of questions on how to deal with a situation where a suspected abuser moves in after the special priority applicant has been housed. Can any possible mechanism be built in the Tenant Protection Act (TPA) to prevent abusers from signing the lease? Should service managers have the regulatory authority to disclose the name of the abuser to the housing provider in order to refuse housing based on being identified as the abuser during the application process? The issue was also raised on how the confidentiality of the woman’s situation would be maintained by doing so and women’s groups were concerned about setting up a system of over-policing women’s lives once they are housed. Service managers also want a better understanding of the duty to report children in need of protection under the Child and Family Services Act if the abuser is added to the household. Once housed, special priority applicants and RGI applicants alike become tenants where the relationship between the tenant/member and the landlord/housing provider is governed by the Tenant Protection Act (TPA), Co-operative Corporations Act, their lease or occupancy agreement. The ministry has reviewed lease requirements and leaseholder status within the context of the TPA (specifically any possible mechanism that could be built in to prevent an identified abuser from signing the lease). Firstly, a tenancy agreement need not be in writing and can be implied based on the actions of the landlord and tenant toward each other. For example, a female tenant allows a friend to move into the unit she is renting and the landlord accepts rent from the friend; the actions of the landlord toward the friend may imply that the friend now has a tenancy agreement with the landlord and with the accompanying rights and obligations. Furthermore, once applicants are housed, the TPA governs the relationship between tenants and landlords, not between household members of a tenancy, and thus eviction notices apply to entire households and not to specific members of a household. Removing a member of a household against their will or the will of other household members falls outside the scope of the TPA. It would be incumbent on a tenant/member or landlord (and not the province) to limit access of an undesired visitor. There are options available to both. As was discussed with the work group, the household’s tenancy is also protected by the safety and security provisions of the TPA, police protection and enforcement (e.g., restraining orders, no trespassing orders). Tenants can be evicted for interference with the right of other tenants to the safety and enjoyment of the premises. If an abuser is not an invitee and is not entitled as an invitee to be on the premises, the landlord or tenant can speak to police about trespass remedies. During the work group discussions, we also learned from the co-operative sector representative that typical co-op bylaws allow for the fast-tracking of evictions in the case of domestic violence which they point out could be lengthy and expensive where the abuser resists the eviction. Co-ops can also ask their members to house a partner as a guest so that the partner has no rights to the unit. There are also tools provided in the SHRA regulations to enable housing providers to control who occupies the unit (e.g., provider can restrict occupants on the lease to members they approve, there are also RGI eligibility rules and allowable grounds for refusal to offer a unit). However, human rights issues may arise by service managers or providers targeting a particular type of client (i.e., refusing to add the abuser to the lease) and should be explored with service managers’/providers’ own legal counsel. When an applicant discloses the name of the abuser (while not required to do so) providers may not be able to use the information for another purpose (i.e., to refuse to add abuser to household). Here again, human rights and privacy issues may arise and should be explored with housing providers’ own legal counsel.

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4.0 Recommendations with Broader SHRA Implications In addition to the specific provisions dealing with special priority applicants, the work group also discussed a number of regulatory provisions which impact all households applying for rent geared-to-income (RGI) assistance. These recommendations which impact the broader SHRA regulatory framework fall outside the scope of the work group’s mandate and are outlined below for information purposes only. 4.1 Arrears Provisions Section 7 of O. Reg. 298/01 sets out the basic eligibility rules for RGI assistance. Among the basic rules is that no arrears should be owing for rent or damages to a housing provider under any housing program. Under the current regulation, when specifically determining eligibility and placing households on the waiting lists, service managers have the flexibility and could choose to ignore former rent arrears “in extenuating circumstances” or if an agreement has been established to repay the housing provider. Extenuating circumstances would include situations where no repayment agreement has been established. There is a special provision for a special priority household to repay only 50 per cent of the arrears if the household had a joint tenancy with the abuser. [Refer to O. Reg. 298/01, 7(1) (f).] In November 2005, MMAH implemented changes to the arrears provisions to clarify that a household that owes arrears, damages or a reimbursement (adding reimbursement) to a social housing provider under any housing program (removing the clause around who administers) will not be eligible unless the amount is repaid or there is a repayment plan in place. The new provisions also clarify that the arrears refer to a previous tenancy so that arrears in an existing RGI unit are not automatically grounds for ineligibility. Women’s groups raised concerns about the interpretation of the criterion of “extenuating circumstances”. While service managers reaffirmed that extenuating circumstances covered situations where there were no repayment agreements in place, women’s groups pointed to a few cases where despite reasonable efforts made by the applicant to enter into a repayment agreement, housing providers/service managers were never satisfied with any repayment arrangement. The work group reviewed the arrears provisions and proposed some wording changes to allow former arrears to be ignored where “the member entered into an agreement and is paying as agreed OR (where there is no repayment agreement), the member is making or is attempting to make all reasonable efforts to repay the arrears”. 4.2 Internal Review Processes and Application Timelines Key objectives of the policy provisions include protecting the safety of special priority applicants and other household members and ensuring timely processing of their applications. The work group reviewed the time lines for determining RGI eligibility for special priority applicants. Women’s groups supported service managers’ recommendation to allow a total of 14 days for assessing a completed application and RGI eligibility and that the two decision points be synchronized for practical purposes. Under the current regulation, service managers are required to make a final decision within 14 days from the date the special priority application is determined to be complete. The work group also reviewed the timeframe to conduct internal reviews of decisions with respect to the Special Priority Household Category. The work group agreed on extending the time frame to conduct internal reviews from the current 5 days to 10 days in order to coincide with the time frame to assess other RGI decisions [O. Reg. 298/01, S. 58 (4)]. Following the work group sessions, the regulatory amendments implemented in November 2005 maintained the original time frames for determining RGI eligibility and for reviewing SPP decisions while allowing service managers to establish the timelines for notifying households of their decisions based on their administrative structures.

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While the recommendation for synchronizing decision points in the application process has broader implications, the work group’s proposal for changes to notification and internal review timelines may no longer be applicable given the latest changes implemented in November 2005. There was no consensus reached on the issue of appeal/internal review processes. The VAW sector and legal clinic representatives want changes to ensure an applicant’s right to request a face-to-face hearing for special priority appeals while service managers want to maintain their right to determine the form and processes for conducting internal reviews of decisions. A similar question of a more arm’s length appeals process was raised during earlier consultations and falls under the context of the broader SHRA regulatory framework.

4.3 Refusal of Three Offers Under the SHRA, a household ceases to be eligible for RGI assistance if it refuses three offers of a unit, and must be removed from the waiting list. The units offered to the household must be units for which they are eligible, and must be of the size and type for which the household indicated a preference and in a housing project the household selected. A household can refuse a unit and not be removed from the waiting list if the household is a couple and they are offered a bachelor unit, or the household is in temporary housing that is to be provided while one or more members of the household are receiving treatment or counselling or that is provided because the household is in need of emergency shelter [refer to O. Reg. 298/01, Section 39]. The work group discussions focussed on the “Refusal of Three Offers” rule as it applies to households living in temporary housing. Under the current regulations, a household can refuse a unit and not be removed from the waiting list if the household is in temporary housing that is to be provided while one or more members of the household are receiving treatment or counselling or that is provided because the household is in need of emergency shelter. The current provisions ensure that applicants are not penalized for making efforts to seek help from shelters or support services and for completing their stay before moving into permanent housing. The work group agreed to maintain the current provisions allowing exemption to the “Three Refusal of Offers” rule where households are staying in a shelter but proposed adding the criterion of being able to refuse and not be removed from the waiting list if staying in a shelter for the purpose of “additional security or safety supports”. 4.4 Special Priority Applicants in Multiple Service Areas The current regulatory provisions do not address the status of households placed on several different waiting lists once they are housed in a specific service area. The work group agreed that once special priority households are housed in a specific service area, they can remain on other centralized waiting lists in chronological order based on their original application date; and because they have been housed and effectively removed from the abusive situation, their special priority status also be removed. A similar issue was raised during earlier consultations on the status of households once they are housed while they have RGI applications on several other different waiting lists.

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5.0 Key Government Initiatives The government recognizes that the response to domestic violence must be a multi-faceted one from police protection and enforcement, the justice system, public education and prevention, to a network of supports from the community. The government has initiated work to improve services across a continuum of supports. The government’s four-year Domestic Violence Action Plan includes:

• $58M to provide better community-based supports for victims, including enhanced counseling and shelter services and second stage housing supports;

• $5.9M to train front-line workers, professionals, neighbours, friends and families across Ontario to

recognize the signs of abuse, and help women and children get the supports they need;

• $4.9M for a public education campaign targeting children and youth and the adults who influence them, to change attitudes and mobilize communities to stop violence before it happens; and,

• Improvements to Ontario’s criminal and family justice system to better protect and support women

and their children, and to hold abusers accountable for violent behaviour. The plan also targets programs and services to meet the needs of women from diverse and at-risk communities. For more details on the Domestic Violence Action Plan, you can visit the Ontario Women’s Directorate website at www.ontariowomensdirectorate.gov.on.ca. Following is an overview of some of the key government initiatives under the Domestic Violence Action Plan which may be of particular interest to the social housing sector. 5.1 MCSS Initiatives under the DVAP Key initiatives under the government’s Domestic Violence Action Plan to assist applicants under the Special Priority Policy range from increased community supports to training housing providers on the issues faced by abused women in maintaining their housing. $3.5M/year investment in the new Transitional and Housing Support Program (THSP), beginning in 2004/05, plus an additional $1M/year beginning in 2006/07

• The investment builds on existing programs, helping connect women to the network of community supports so they can build stable lives.

• Under the program, there is greater focus on helping abused women, wherever they are living, to find and maintain housing.

Cross-Sectoral Referral Agreements

• The agreements are intended to outline how the two sectors will work together locally to achieve the goal of helping abused women find and maintain housing and connect with community supports.

• Signing of the agreements and implementation by Fall 2006.

Funding in the amount of $500,000 for training social housing providers on the issue of domestic violence

• Training will provide social housing providers with information on the issues and challenges faced by abused women, and the practical tools to better support women facing issues of abuse to secure and maintain their housing including local linkages to community-based services.

• Training will also strengthen the linkages between social housing providers and violence against women agencies and community-based resources, including connections with transitional and housing support workers, local domestic violence coordinating committees and other networks where providers can access information.

http://www.ontariowomensdirectorate.gov.on.ca/

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• Audience of the training to include: social housing property managers, co-operative housing managers, social housing coordinated access centres’ staff, Aboriginal housing managers, as well as private landlords with rent supplement units.

• Training curriculum to be developed by Summer/Fall 2006 and training anticipated to take place in 2006/07.

5.2 Strengthening the Justice System Response Under the Domestic Violence Action Plan, the provincial government continues to make improvements to Ontario’s criminal and family justice system to better protect women and children from domestic violence and to ensure the seamless delivery of services from the justice system. Among these improvements is the amendment to the Children’s Law Reform Act proclaimed in February, 2006 which requires courts to consider domestic violence when making orders relating to the custody of or access to a child. There are initiatives to improve access to justice including working with the federal government to improve funding for family and civil legal aid; increasing awareness of family law, domestic violence and civil rights through community legal education publications; and encouraging the federal government to amend the Criminal Code to require reverse onus in bail situations and to retain the concepts of custody and access in any amendments to the Divorce Act.

Other key initiatives include:

• Training for Ontario judges in court cases involving violence against women and for part-time Crown

Attorneys to help them prosecute cases effectively. • Improvements in restraining orders and enforcement of breaches. Standardized provisions for

restraining orders are being developed to ensure consistency of practice across the province. • Strengthening policies and police training to mitigate impact of victims of dual charging.

5.3 Affordable Housing for Victims of Domestic Violence Increasing the housing options available for victims of domestic violence is also vital to support women as they re-establish themselves in the community. The provincial government is increasing the number of units under the Affordable Housing Program (AHP) for victims of domestic violence; 500 capital units have been designated for victims of domestic violence with accompanying support from MCSS in the amount of $1M under the Transitional and Housing Support Program to provide additional counselling and support services to the women housed in these units. There are also 500 housing allowances dedicated to victims of domestic violence representing 10% of the total provincial allocation of 5,000 housing allowances.

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Questionnaire Please complete the following questionnaire. For full discussion and background information on each of the options/questions for consideration outlined below, refer to Section 3, Report to Stakeholder for Feedback, Work Group Recommendations and Options for Consideration. For more details on the work group recommendations and discussions, please refer to Appendix “A”. Key regulatory provisions related to the Special Priority Policy have been provided in Appendix “B” and “C”. Please provide your contact information: Name of Organization: __________________________________________________________________________ Contact Name and Position: _____________________________________________________________________ Address: _____________________________________________________________________________________ Phone Number: _______________________________________________________________________________ Email: ________________________________________________________________________________________ Mail, email, or fax this completed questionnaire in addition to any written comments no later than August 8th, 2006 to: Mary Fantauzzi, Sr. Policy Advisor Housing Division, Municipal Affairs and Housing 2nd Floor, 777 Bay Street Toronto ON M5G 2E5 Fax: 416-585-7003 Tel: 416-585-6838 Email: [email protected]

mailto:[email protected]

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Questionnaire

3.1 Time Limit for Submitting Applications – Option for Consideration To ensure a request for inclusion in the Special Priority Household Category is accepted beyond the three- month time limit where the verifier of abuse is able to demonstrate to the service manager on a reasonable basis that the applicant is at risk of further abuse from the original abusing individual. What is your feedback?

Strongly Agree Neutral Disagree Strongly Agree Disagree Comments: Given the complexity in determining risk of further abuse, please provide your feedback on the following method to assist in determining further risk of abuse: a) that one or more of the existing indicators are still present, b) that the abuse is current or ongoing, or c) that there is continued risk of further abuse. Please give us your views.

3.2 Definition of Abuse – Option for Consideration To amend the definition of abuse in keeping with the work group’s key objectives to set the context of domestic violence and abuse within an abusive relationship which includes partner abuse, elder abuse, child abuse, abuse by family members, by a live-in caregiver, abuse within same-sex relationships, and other alternative relationships. What is your feedback?

Strongly Agree Neutral Disagree Strongly Agree Disagree Comments:

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3.3 Indicators of Abuse – Option for Consideration To add to the current list of records (or indicators) of abuse in keeping with the work group’s proposed additions highlighted in bold below: (4) The record referred to in subsection (3) is any of the following: 1. A record of intervention by the police indicating that the member was abused by the abusing individual. 2. A record of physical injury caused to the member by the abusing individual. 3. A record of the application of force by the abusing individual against the member to force the member to engage in sexual activity against his or her will. 4. A record of attempts to kill the abused member (or another member of the household). 5. A record of the use of a weapon against the abused member. 6. A record of words, actions or gestures by the abusing individual that threaten the member or his or her property including, but not limited to, the following: i. Threats to kill the abused member or another member of the household. ii. Threats to use a weapon against the abused member or another member of the household. iii. Threatening to physically harm the member or another member of the household. iv. Destroying and/or injuring or threatening to destroy and/or injure the member’s property. v. Intentionally killing and/or injuring pets or threatening to kill and/or injure pets. vi. Threatening to harm and/or remove the member’s children from the household. vii. Threatening to prevent the member from having access to his or her children. viii. Forcing the member to perform degrading acts or acts of public humiliation. ix. Terrorizing the member. x. Enforcing social isolation upon the abused member. xi. Threatening to take action to withdraw from sponsoring the member as an immigrant. xii. Threatening to take action that might lead to the member being deported. xiii. Other words, actions, threats, or gestures which lead the member to fear for his or her safety. 7. A record of undue or unwarranted control by the abusing individual over the member’s daily personal or financial activities. 8. A record of stalking and/or harassing behaviour. [Refer to Appendix “B”, O. Reg. 298/01, Subsection 25 (4)]



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3.4 Verification of Abuse – Option for Consideration To require written verification of abuse [removing the option for verbal verification currently in subsection 25 (3) of O. Reg. 298/01].



3.5(a) Statement of Abuse and Verbal Follow-up – Option 1 for Consideration To give service managers the authority to verbally contact the individual producing/verifying the record of abuse where insufficient information is provided. What is your feedback?

Strongly Agree Neutral Disagree Strongly Agree Disagree Comments: OR, 3.5(b) Statement of Abuse and Verbal Follow-up – Option 2 for Consideration To maintain the current provisions as is, i.e. leaving the onus on the member making the request for special priority status to provide such information and documents as the service manager may require for the purpose of verifying the statement of abuse. What is your feedback?


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3.6 Verifying “living with” Criteria – Option for Consideration To include the “living with or having lived with the abuser” criteria as subject to verification with the proviso of “reasonableness” of documents requested. Service managers required to waive the verification (proof of cohabitation) where a) applicants feel they will be at risk in obtaining the documents or b) where the service manager is satisfied the information is not obtainable. Abuse by an immigration sponsor would continue to qualify within or outside a common living arrangement with the abused.


Strongly Agree Neutral Disagree Strongly Agree Disagree

Comments:

3.7 List of Professional Verifiers – Option for Consideration In line with the work group’s proposals, to allow the following: 1. the verifier to provide the statement of abuse in their professional capacity; 2. adding community legal workers among the current list of professionals who can verify abuse; 3. add a definition for a member of the clergy that is inclusive of all faiths; and 4. to capture workers described as community services workers who, while not registered with a specific registered body, are able and qualified to verify abuse. Community Legal Worker: “Community legal worker means an individual employed by a community legal clinic who provides legal aid services in the area of clinic law, within the meaning of section 2 of the Legal Aid Act, 1998.” Member of the Clergy: “Minister of Religion licensed to perform a marriage in the Province of Ontario.” Community Services Worker defined as:

For the purposes of this regulation, community services worker means an individual who is employed by a community service or government agency, for the purpose of providing social support services in the community. Examples of titles that fall under this category include but are not limited to:

- Housing and Outreach Worker - Homeless Shelter Staff - Housing Help Center Worker - Mental Health Clinician - Housing Support Worker - Transitional and Housing Support Worker - Immigration Worker - Community Support Worker - Child Protection Worker - Homeless Support Worker - OW/ODSP Case Worker



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3.8 Ranking within the Special Priority Household Category – Option for Consideration Until a more effective system is established, to allow ranking among special priority households based on the chronological date of application.



3.9 Review of Special Priority Status – Option for Consideration To remove special priority status while applicants are on the waiting list where the applicant reports: adding the abuser to the application (or at time of offer of a unit), or that the abuser is deceased. It would be important under this option that any changes in information be provided by the original member who is abused. Women’s groups pointed to concerns about reliance on third party information that could be misused by others and possibly used as a means of sabotage by the abuser or other parties. What is your feedback?


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3.10 Requests for Internal Transfers – Option for Consideration To transfer responsibility for determining special priority eligibility of internal transfers to service managers/access centers who would do so on behalf of housing providers.



Any additional comments? (Separate written submissions are welcome.)

Documents

Special Priority Policy Review within Domestic Violence