Evaluation of the Canada Disability Savings Program: Phase 2

Gender-based Analysis +

The summative evaluation examined participants' results using a gender-based analysis plus lens, including, for example, intersections between gender, disability, and age.^{Footnote 8}   Examination of other intersections such as Indigenous groups, ethnicity, new Canadian and region was not possible due to data limitations.  Key gender-based analysis plus findings are:

• For the Registered Disability Savings Plans opened between 2008 and 2017, about 40% of beneficiaries are female while about 60% are male.^{Footnote 9}
• Most (69.4%) of the funds in Registered Disability Savings Plan holdings are from the Canada Disability Savings Grant or Canada Disability Savings Bond. Women, and individuals in the lower 3 income brackets, were more likely to say that the larger portion of their Registered Disability Savings Plan came from government money as compared to men and people in the higher income bracket.^{Footnote 10}

Findings on program relevance and efficiency

Relevance: The Canada Disability Savings Program is one of a suite of programs, tax incentives and financial support measures established by the federal government aimed at persons with disabilities.^{Footnote 11}The Government of Canada reiterated this commitment most recently in Budget 2016, as it promised to “eliminate systemic barriers and deliver equality of opportunity to all Canadians living with disabilities”.^{Footnote 12}

Efficiency: Following an initial start-up period when costs were incurred to implement necessary processes and systems, unit costs to administer the Canada Disability Savings Program have dropped rapidly as the number of registered plans rises while administration costs have also been declining.

Challenges

• Raising awareness among the most difficult to reach segments of the population, such as those in the lowest income bracket in order to communicate the benefit of opening an Registered Disability Savings Plan.
• Addressing the knowledge gaps that continue to exist amongst financial institution / issuer partners and Canadians seeking information regarding the Registered Disability Savings Plan, Canada Disability Savings Grant and Canada Disability Savings Bond.
• Enhancing the service experience of all those who attempt to open or maintain a Registered Disability Savings Plan, invest or withdraw funds, particularly the experience of those with multiple vulnerabilities (for example, Indigenous, new arrivals, or LGBT persons with severe and prolonged disabilities.)

Recommendations

Management action plan

• Collaborate with Canada Revenue Agency to facilitate the 2018 mail-out which will target potential Registered Disability Savings Plan beneficiaries aged 19 to 49.
  • Completion date: October/November 2018
• Work with Employment and Social Development Canada's Innovation Lab to consider possible new approaches to better target the hard-to-reach population with disabilities.
  • Completion date: September 2019
• Work with Employment and Social Development Canada Public Affairs and Stakeholder Relations Branch and collaborate with Canada Revenue Agency to improve and streamline program web content.
  • Completion date: July 2019
• As part of the work to improve the program's web content, ensure that new tools and enhanced communication products are available in alternate formats.
  • Completion date: September 2019

Recommendation 2: Continue working with all partners involved in delivering the Registered Disability Savings Plan, the Canada Disability Savings Grant and the Canada Disability Savings Bond to identify and address knowledge gaps that persist within partner organizations and among Registered Disability Savings Plan holders and beneficiaries.

Response
Management acknowledges the need to continue working with partners for the purpose of identifying and addressing knowledge gaps. Over the past years, work has been done to identify key knowledge gaps that persist among partner organizations and Registered Disability Savings Plan holders and beneficiaries.

To help issuers administer Registered Disability Savings Plans and explain the program to applicants, Employment and Social Development Canada will continue to provide a comprehensive suite (in various formats) of reference/training resources and regular updated bulletins to issuers. These resources will be regularly enhanced and refreshed based on client experiences and feedback from stakeholders.

2019 will mark 10 years since the initial payments of grant and bond were made into Registered Disability Savings Plans. The Program will put specific emphasis on communications products explaining the rules regarding withdrawals and repayments to avoid confusion among plan holders, beneficiaries and financial institution and to ensure that they are not negatively affected.

To help better address the key knowledge gaps faced by the employees of issuers who deal with Registered Disability Savings Plans, including any additional support as part of the program's ten-year anniversary, Employment and Social Development Canada will request more targeted feedback from issuers (through teleconferences and meetings) to both identify the gaps and develop potential solutions to address these gaps. This can be achieved by further strengthening the relationship with issuers through the Registered Disability Savings Plan Advisory Committee, created in 2012 to provide a forum for program delivery partners to discuss key issues. While these meetings have traditionally been held on an as needed basis, the last one being in June of 2017, increased consultation with issuers is being pursued. Employment and Social Development Canada and the Canada Revenue Agency co-chair the committee that brings together representatives from all issuers. The next Registered Disability Savings Plan Advisory Committee meeting is scheduled for October 2018. Engagement through the Registered Disability Savings Plan Advisory Committee will continue and participation in discussions by delivery partners will be encouraged.

Some identified program research gaps pose a challenge to being more strategic and targeted with outreach efforts. In particular, research and analysis are needed to determine the key demographic characteristics of the 'non-client' group, that is Disability Tax Credit-eligible individuals in the 0 to 49 age group who have not yet opened a Registered Disability Savings Plan. To this end, Employment and Social Development Canada will collaborate with Statistics Canada to carry out an ad-hoc survey on non-clients aimed at investigating the reason why they have not yet opened a Registered Disability Savings Plan and how this relates to demographic and socio-economic characteristics. In 2018, the program transferred its administrative data to Statistics Canada pursuant to a memorandum of understanding between Statistics Canada and Employment and Social Development Canada. In this regard, Employment and Social Development Canada has begun developing project parameters to have Statistics Canada link the Canada Disability Savings Program administrative data with tax file or survey data.

Management action plan

• Through reinvigorating the relationship with issuers by means of Registered Disability Savings Plan Advisory Committee meetings and teleconferences, solicit feedback from issuers regarding any potential issues evolving from knowledge gaps, for instance additional information on withdrawals may be needed to help issuers provide more clarity to holders in the event of the 10-year anniversary issue.
  • Completion date: March 2019
• Work with Statistics Canada is beginning in fall 2018 to facilitate a survey of a sample from the non-clients group in order to better understand their reasons for not opening a Registered Disability Savings Plan. It is tentatively planned that the survey could go out in Spring 2019 and then results would be rolled up during Summer 2019. The subsequent analysis will help inform the Canada Disability Savings Program's future outreach and policy work.
  • Completion date: September 2019

Recommendation 3:
Continue working with all partners to identify and address the barriers that hinder people with severe and prolonged disabilities who are aware of the Registered Disability Savings Plan from opening or maintaining one and to improve the service experience of those who attempt to do so.

Response
Management agrees with this recommendation. The Canada Disability Savings Program will continue to collaborate with partners to find ways to better address barriers that prevent people with disabilities from opening or maintaining a Registered Disability Savings Plan.

After 10 years of program delivery experience, feedback (anecdotal and quantitative) has been gathered to be able to identify some of the barriers that challenge potential beneficiaries with accessing the program. One of the key challenges is understanding how the Disability Tax Credit works and completing the application process. Recommendations are expected in 2019 from Canada Revenue Agency's Disability Advisory Committee, which was reinstated in 2017 to provide advice to the Minister of National Revenue and the Canada Revenue Agency Commissioner with respect to administrative issues evolving from disability tax measures (including the Disability Tax Credit). Employment and Social Development Canada will work with the Canada Revenue Agency and the Department of Finance to take into consideration the advice of the Disability Advisory Committee in developing the outreach strategy and to improve client service in the Program.

As part of the work to address knowledge gaps and barriers, Employment and Social Development Canada will continue to collaborate with stakeholders such as disability support organizations and financial planners and the program's delivery arm (that is the financial institutions) to focus on areas where further potential improvements to the service experience of both clients and non-clients is possible. Program officials will engage the issuers to identify areas where improvements to the service experience could be made at this Octobers Registered Disability Savings Plan Advisory Committee meeting and through teleconferences in the coming year.

In some jurisdictions it is the perception of some potential beneficiaries who are low-income that Registered Disability Savings Plan assets or income could negatively impact eligibility for provincial disability supports; and this perception prevents them from opening a Registered Disability Savings Plan. Program officials will continue to work with the provinces/territories and welcome further collaboration with the Ontario Disability Support Program. An engagement strategy is being developed to strengthen the program's collaboration with provincial/territorial counterparts and increase program promotion in particular in jurisdictions with lower take-up rates.

In addition to partnering with Statistics Canada to conduct a survey of the non-client group (as mentioned in Recommendation 2), program officials will consider other ways to solicit this type of information from the non-client group, for example through informal surveys of people who visit the Canada Disability Savings Program kiosk during conferences and events.

Management action plan

• Expand our current work with provincial and territorial representatives, especially in jurisdictions with lower take-up (for example Atlantic provinces, Quebec) — to help increase awareness and enhance understanding among provincial/territorial staff that work in the areas of social services programs/ benefits with a view to increasing take up rates across the country.
  • Completion date: July 2019
• Through Registered Disability Savings Plan Advisory Committee meetings and teleconference discussions, solicit ideas from issuers regarding any potential areas where the service experience can be improved.
  • Completion date: December 2019

2.1 Program objective

The objective of the Canada Disability Savings Program is to encourage long-term savings to help ensure the financial security of people with severe and prolonged disabilities. The program was designed based on the final report of an expert panel that had been convened by the Government of Canada and given the mandate "to make recommendations on how families can provide for the future financial security of their family member with a disability".^{Footnote 16}

2.2 Background

In 2006, the Government of Canada announced the appointment of an Expert Panel on Financial Security for Children with Severe Disabilities to examine ways to help parents save for the long-term financial security of their children. The concern was how best to ensure the financial security of a disabled child when parents are no longer able to provide support, as well as to help alleviate the poverty so disproportionately experienced by Canadians with disabilities.^{Footnote 17} In developing its recommendations, the panel was concerned with balancing 2 competing objectives: (1) to encourage long-terms savings and (2) to ensure that the beneficiary would benefit from those savings within his or her lifetime.

In Budget 2007, the Government of Canada, acting on the recommendations from the Panel’s final report^{Footnote 18}, announced the introduction of the tax deferred^{Footnote 19} Registered Disability Savings Plan. The Registered Disability Savings Plan was then introduced in 2008. As recommended by the Panel, the Registered Disability Savings Plan was modeled on the Registered Education Savings Plan emulating its higher matching rates for those in the low and modest income categories, thus producing more equitable distribution of public contributions.^{Footnote 20}

2.3 Program description

The Canada Disability Savings Program consists of 3 components:

• The Registered Disability Savings Plan
• The Canada Disability Savings Grant
• The Canada Disability Savings Bond

Rates and income threshold as of January 2017

Dash (-) indicates that the program does not provide a matching grant for this particular contribution amount.

Rates as of January 2017

Like the Canada Disability Savings Grant, the Canada Disability Savings Bond is subject to a ten-year holdback during which time any Canada Disability Savings Bond money paid into an Registered Disability Savings Plan cannot be accessed and must be paid back to the Government of Canada if the Registered Disability Savings Plan is closed.

2.4 Expected results

As articulated in the Performance Measurement Strategy for the Canada Disability Savings Program (2015),^{Footnote 25} the direct outcomes for the Canada Disability Savings Program are:

• People with disabilities are aware of the Canada Disability Savings Grant and Canada Disability Savings Bond as incentives to save in a Registered Disability Savings Plan.
• Eligible beneficiaries apply for and receive the Canada Disability Savings Grant and Canada Disability Savings Bond.
• Eligible beneficiaries take withdrawals.

2.5 Delivery model

The Canada Disability Savings Program is jointly managed by Employment and Social Development Canada, the Canada Revenue Agency and the Department of Finance. Employment and Social Development Canada is responsible for program design and delivery, policy development, outreach, communications products, Federal/Provincial/Territorial relationships, business and system needs, evaluations and performance reporting.

In closing this section, it is worth noting that, since initial implementation in 2008, operational experience has led to numerous program changes (see Appendix D). However, the program has been relatively stable during the years covered by this evaluation report.

3.1 Phase 1

The Phase 1 Evaluation examined early results of the program from 2008 to 2012. The objective of Phase 1 was to examine the design and delivery of the program, its relevance, and early directional impacts. It confirmed that the Canada Disability Savings Grant and the Canada Disability Savings Bond had introduced important new instruments, namely asset-development, to provide financial security for persons with severe and prolonged disabilities. As expected, the evaluation found a number of areas for improvement in the program itself and its administration, such as enhancing performance measurement; improving communications and outreach; streamlining the application process; and supporting awareness and knowledge amongst delivery partners.

3.2 Phase 2

4.1 Need for future savings for persons with disabilities

The need for people with disabilities to save for the future was strongly supported by all lines of inquiry. An overwhelming number of respondents to the Survey of Households of Canadians with Disabilities survey^{Footnote 31}  (98.5%) felt that they needed to save for the future; key informants concurred,^{Footnote 32}  case studies supported this need^{Footnote 33}  as did the technical studies of program data.^{Footnote 34}  In addition, respondents to the Survey of Households of Canadians with Disabilities revealed a lack of confidence in their future regarding self-sufficiency with almost half (45.9%) indicating they will not have enough money in the future for either their wants or their needs.^{Footnote 35}  There were no significant differences by gender or income level.

Interviewees for nearly all case studies anticipated that the beneficiary of the Registered Disability Savings Plan would need additional savings in the future to either pay for additional care required by their disability, or to supplement income – irrespective of whether that income was from employment or provincial income assistance and disability programs.^{Footnote 36}  There were some case study participants who expected that beneficiaries would be eligible for, and live in, group homes or similar living arrangements, where costs of living would be provided by the province.^{Footnote 37}  However, these case study participants noted that these programs cover only the “bare basics” such as shelter, food and care while other expenses such as clothing, entertainment or outings are not covered by these programs.^{Footnote 38}

The Canada Disability Savings Grants and Canada Disability Savings Bonds available through the Registered Disability Savings Plan were seen as an incentive for saving,^{Footnote 39} particularly for those with low and modest incomes. The desire to save for anticipated future needs is further highlighted by the finding that some beneficiaries and account holders continue to contribute to a Registered Disability Savings Plan even after they reach the maximum grant (See section 5.4 for more details).

4.2 Barriers to accumulating desired savings

According to the Canadian Survey on Disability, people with disabilities and families of children with disabilities face significant economic barriers making it more difficult to contribute to a Registered Disability Savings Plan or otherwise save for the future. An analysis of the Canadian Survey on Disability (2012) found that people aged 15 to 59 with more severe disabilities differed from those with less severe disabilities in a number of important ways, including living in lower income households, and being less likely to have employment.^{Footnote 40}

The Canadian Survey on Disability found that 22.7% of all people with disabilities were prevented from working due to their disabilities. Further examination shows that 34.6% of people with more severe disabilities are prevented from working while 11.3% of people with less severe disabilities are prevented from working due to their disabilities. Results from the Survey of Households of Canadians with Disabilities revealed that many Registered Disability Savings Plan beneficiaries were not currently employed (65.5%). Of those that were employed, a larger proportion was employed on a part-time basis (24.2%) than a full-time basis (10.3%).^{Footnote 41}

As for families of children with disabilities, analysis of the Participation and Activity Limitation Survey (2006) found that many face job-related difficulties, including not taking a job (26.4%), working fewer hours (38.4%) and leaving (21.6%) or losing (6.2%) a job to care for the child with disabilities.^{Footnote 42}   As with other issues, the prevalence was greater among families who had children with more severe disabilities than those who had children with less severe disabilities.

For these reasons, families of children with more severe disabilities have lower average household incomes ($65,310) than families with children with less severe disabilities ($71,530) or those without disabilities ($73,680).^{Footnote 43}

Both the Canadian Survey on Disability (2012) and the Participation and Activity Limitation Survey (2006) provided evidence that people with more severe disabilities and families of children with more severe disabilities incur higher living costs than people with less severe disabilities and people without disabilities. For example, 34.3% of families of children with less severe disabilities indicated that they had out-of-pocket expenses for prescription or non-prescription drugs in the last 12 months compared to 41.4% of families of children with more severe disabilities.^{Footnote 44} In addition, people with disabilities can expect these costs to continue and likely increase as they age. Out-of-pocket expenses include health-related items, assistive aids and devices, caregiving services, transportation and others.^{Footnote 45}

The Survey on Household Spending examined the period from 2010 to 2013 and concluded that households of persons with disabilities or of children with disabilities dedicate a greater percentage of expenses for food (11.7% versus 10.4%), shelter (21.5% versus 20.8%), household operation (6.8% versus 6.2%), furniture (2.8% versus 2.6%) and transportation (15.8% versus 14.9%) than comparable households without disability. They also spent more on health care and general consumption compared to households without people with disabilities or families of children with disabilities.^{Footnote 46} Higher living costs generally mean less capacity to save.

4.3 Alignment with federal government priorities

The Canada Disability Savings Program's objective is to encourage long-term savings to help ensure the financial security of people with severe and prolonged disabilities. This is consistent with the Departmental Results Framework / Program Inventory (2018 to 2019) and contributes to Employment and Social Development Canada's Strategic Outcome 4: Income security, access to opportunities and well-being for individuals, families and communities.^{Footnote 47}

The Canada Disability Savings Program is one of a suite of programs, tax incentives and financial support measures established by the federal government aimed at persons with disabilities.^{Footnote 48} The Government of Canada reiterated this commitment most recently in Budget 2016, as it promised to “eliminate systemic barriers and deliver equality of opportunity to all Canadians living with disabilities”.^{Footnote 49}

As part of the government's accessibility agenda, federal accessibility legislation was introduced to remove barriers to accessibility across sectors of federal jurisdiction. The Accessible Canada Program supports the meaningful participation of people with disabilities in the ongoing implementation and administration of federal accessibility legislation.

5.1 Program delivery

The Canada Disability Savings Program provides support to financial institutions (referred to as "issuers") that offer the Registered Disability Savings Plan in order to ensure that the program requirements are clear and that the needs of the target population are met. As Canada Disability Savings Program stakeholders, financial institutions have a front line delivery role.

A file and document review indicates that the Program provides various support tools to financial institutions. Existing training materials are reviewed and modified on an ongoing basis in collaboration with financial institutions to meet their needs. In addition, in-person training sessions and webinars are offered to financial institutions to help them to better provide services to people with disabilities. The Program informs financial institutions of changes in program legislation and regulations, and how these changes may impact their administration of the program.

Financial institutions offer the target population different ways to access the program (for example, centralized telephone system, in-person service) as well as alternative formats for information about the program (for example, Braille, website accommodations). Most key informants from financial institutions indicated confidence in their ability to serve clients who were registering for Registered Disability Savings Plan accounts and processing the required transactions. They were also generally satisfied with the training and supports received from Employment and Social Development Canada. Most financial institutions interviewed rated their institution a "5" or above on a scale of 1 to 7 when asked to assess their institution on ‘registration and opening clients' accounts' and ‘processing unusual or usual transactions'.

Financial institutions admitted concerns over the complexity of the program and expressed interest in receiving more information on aspects of the program's policies, rules and regulations, including:

• identifying who is legally able to be a representative or holder;
• processes to follow regarding disposal of Registered Disability Savings Plan assets; and
• whether or not Registered Disability Savings Plans are entitled to creditor protection.^{Footnote 53}

Results from the Survey of Households of Canadians with Disabilities (2017) revealed that the majority of people (74.3%) were satisfied with the information they received and the ease with which they were able to set up their Registered Disability Savings Plan, while 25.7% stated they were not able to get all the information needed.^{Footnote 54} Of those who were not satisfied, the most common observation was that the financial institution representative was not well informed about the program.

Case studies with Registered Disability Savings Plan beneficiaries found some similar results, with about one-half of case study participants reporting that the staff they dealt with at financial institutions were not knowledgeable about the program and had difficulty answering questions.^{Footnote 55}  Areas where information was lacking included specifics of the Assistance Holdback Amount rules and the eligibility requirements to apply for the Registered Disability Savings Plan, Canada Disability Savings Grant and Canada Disability Savings Bond. At the same time, many case study participants also reported that staff was eager to find out needed information about the program to ensure that they received good service.

5.2 Awareness

People with disabilities (and/or their families/caregivers) are aware of the Canada Disability Savings Grant and Canada Disability Savings Bond as incentives to save in a Registered Disability Savings Plan. Program outreach activities were designed to increase awareness of the program with the expectation that would increase take-up.

The Program disseminated plain language print and internet information for people with disabilities and their families about the Registered Disability Savings Plan, Canada Disability Savings Grant and Canada Disability Savings Bond. Subsequent efforts focused on 5 initiatives:

1. Developing a pan-Canadian promotional strategy targeting the parents of children with disabilities, adults with disabilities, and Indigenous people with disabilities
2. Implementing service contracts to deliver information sessions and one-on-one support to people with disabilities
3. Increasing outreach to community based organizations through print, conference attendance and in-person meetings
4. Disseminating print information to provincial/territorial offices that provide income and social support to people with disabilities
5. Producing accessible Canada Disability Savings Program information for the deaf and hard of hearing communities

The Program contracted non-governmental organizations to deliver group information sessions to people who wanted to learn more about the Registered Disability Savings Plan, including people with disabilities, parents, siblings, friends, support workers and financial professionals. Feedback from these initiatives showed that 92% of participants indicated that their knowledge of the Registered Disability Savings Plan, Canada Disability Savings Grant and Canada Disability Savings Bond had increased and 43% of respondents intended to open a Registered Disability Savings Plan in the near future, suggesting these are effective communication methods.^{Footnote 56}

The case studies found that approximately one-half of all cases reported having seen promotional materials about the program. The most frequently reported forms of promotion were pamphlets and posters, either at service provider organizations or financial institutions. A few case study participants mentioned seeing promotion for the program in their annual notice of assessment from the Canada Revenue Agency, and some participants noted seeing advertisements in mass media (for example, newspapers, television). However, feedback from case study participants and from the Survey of Households of Persons with Disabilities (2017), suggests that advertising, posters, and pamphlets have not been highly successful in raising awareness of the program.

Financial institutions and program staff in the key informant interviews reported that the most effective outreach strategy was the Canada Revenue Agency mail-outs. Since 2013, the Program has conducted 6 mass mail-outs, in partnership with the Canada Revenue Agency, to Disability Tax Credit-eligible individuals. While causality is not certain, after each mail-out, the 1-800-O-Canada line experienced increased call volumes (on average a 125% increase)^{Footnote 57} and visits to the website. The Canada Disability Savings Program call centre and financial institutions that issue the Registered Disability Savings Plan also reported increased interest in the Registered Disability Savings Plan at the time of the mail-outs.^{Footnote 58}

5.3 Registered Disability Savings Plan take-up

There has been steady increase in registered accounts, with a total of 168,567 at the end of 2017 (see Figure 1).

Text description of Figure 1

Year	Number of registered accounts
2009*	24,259
2010	34,630
2011	44,007
2012	56,656
2013	71,770
2014	91,761
2015	120,090
2016	149,684
2017	168,567
Total	168,567

Source: Canada Disability Savings Program Administrative Data Analysis

*Registered Disability Savings Plans were made available to Canadians in December 2008; therefore, 2009 covers the period of December 2008 to end of December 2009.

The number of Registered Disability Savings Plans is almost evenly distributed and relatively high across younger age groups (about 30% for each age group) (see Figure 2). This number drops significantly for the older age groups (50 to 59 and 60+). This is due to the fact that eligibility for Canada Disability Savings Grant and Canada Disability Savings Bond payments ends after December 31 of the year when the beneficiary turns age 49 and people over age 60 are not eligible to open a Registered Disability Savings Plan.

Text description of Figure 2

Take-up by Age	% of accounts by age
0 to 18	25%
19 to 34	32%
35 to 49	29%
50 to 59	13%
60 and over	1%
Total	100%

With respect to gender, females held about 40% while males held about 60% of the Registered Disability Savings Plans opened between 2008 and 2017.^{Footnote 65} These results align approximately with the Participation and Activity Survey (2006) finding that about one third of all children with more severe disabilities are female, and the Canadian Survey on Disability (2012) that approximately half of people aged 15 to 64 with more severe disabilities are women.^{Footnote 66}

Eligibility for the Disability Tax Credit is required for Registered Disability Savings Plan eligibility. Therefore a key metric is the percentage of the Disability Tax Credit eligible population that has a Registered Disability Savings Plan. By 2016, approximately 29% of those aged 0 to 49 in Disability-Tax-Credit-eligible population had a Registered Disability Savings Plan while almost 24% of those under age 59 had one (See Figure 3).

Text description of Figure 3

% of Disability Tax Credit Eligible Population with Registered Disability Savings Plan	Ages 0 to 49 Take up rate	Ages 0 to 59 Take up rate
Year
2009	9.10%	5.62%
2010	15.57%	9.87%
2011	13.24%	8.76%
2012	15.69%	12.89%
2013	14.28%	12.40%
2014	20.38%	17.02%
2015	24.33%	20.38%
2016	28.99%	24.54%

Program administration data show that take-up rates vary considerably by province. Rates are highest in British Columbia (over 30%). Alberta, Saskatchewan, Manitoba, and Ontario have take-up rates in the mid to high twenties. Quebec and Prince Edward Island take up is in the low twenties. The remaining Atlantic Provinces have take-up rates below twenty percent.

5.4 Contributions to Registered Disability Savings Plans

Savings accumulated in a Registered Disability Savings Plan come from 3 principal sources: (1) contributions from the Registered Disability Savings Plan holder or others, (2) Canada Disability Savings Bond and (3) Canada Disability Savings Grant deposits made by the program. Total annual contributions have been increasing slowly as the number of registered plans increases (see Figure 4). By the end of 2017, total cumulative contributions amounted to $1.239B.

Text description of Figure 4

Year	Total annual contributions ($ million)	Total cumulative contributions ($ million)
2009	$55	$55
2010	$83	$138
2011	$91	$229
2012	$114	$343
2013	$129	$472
2014	$165	$637
2015	$173	$810
2016	$205	$1,015
2017	$223	$1,239

Source: Canada Disability Savings Program Administrative Data

The average contribution has dropped slowly since 2009 (see Figure 5). This is likely due to maximization of contributions in the first year or 2 in order to attract the maximum Canada Disability Savings Grant and Canada Disability Savings Bond payments. Once full retroactive payments have been received, contributors may prefer to reduce their contributions.

Text description of Figure 5

Years, 2009 to 2017	2009	2010	2011	2012	2013	2014	2015	2016	2017
Average annual contribution amount	$3,224	$2,907	$2,742	$2,922	$2,811	$2,950	$2,622	$2,508	$2,489

Analysis of contribution trends by income level since the beginning of the program revealed that it is the low-income group^{Footnote 67} that had the highest total aggregate personal contributions (see Figure 6). Total contributions increased each year for all 4 income groups from 2010 to 2017. Both program administration data and the survey of Registered Disability Savings Plan holders conducted for the evaluation found that Registered Disability Savings Plan holders in the lowest income group made the highest average contributions,^{Footnote 68} though the differences in average contributions across the 4 income groups are relatively small. Thus the differences in total contributions are almost entirely explained by the relative number of plans in each income group. For example, the low-income group comprised 48% of all Registered Disability Savings Plan holders,^{Footnote 69} and total contributions by this group is slightly larger than the total contribution by the other 4 income groups combined.

Text description of Figure 6

Total Contributions by Income Group	High Income Above second income threshold	Upper Middle Income Below second income threshold	Middle Income Below first threshold	Low Income Below the phase out income*	Other / income not reported
Year
2009	$12,869,193	$8,428,166	$5,637,225	$38,878,539	$2,703,336
2010	$10,722,914	$9,138,104	$6,110,996	$42,255,189	$1,684,737
2011	$11,369,937	$11,845,214	$7,892,124	$57,566,764	$1,870,896
2012	$15,403,866	$15,632,931	$10,340,711	$69,336,679	$3,742,881
2013	$17,555,058	$18,269,224	$12,074,016	$79,226,473	$4,729,398
2014	$23,159,966	$21,751,108	$15,726,918	$98,933,473	$5,594,687
2015	$23,978,352	$24,930,264	$16,596,398	$104,797,520	$7,098,029
2016	$27,345,284	$29,593,413	$20,547,643	$117,888,729	$8,047,641
2017	$28,810,557	$30,298,057	$18,192,957	$129,978,814	$9,135,107
Total	$171,215,127	$169,886,480	$113,118,989	$738,862,180	$44,606,712

Source: Canada Disability Savings Program Administrative Data

Registered Disability Savings Plan beneficiaries/holders from all income categories might continue to contribute to their Registered Disability Savings Plan after maximizing Canada Disability Savings Grants (see Table 3). The reasons for doing so include that, even without the Canada Disability Savings Grant, the Registered Disability Savings Plan is a tax deferred savings account^{Footnote 70} and because Registered Disability Savings Plan income and assets are fully exempt for the determination of disability income supports in most provinces/territories.

Source: Canada Disability Savings Program Administrative data (timeframe from December 2008 to December 31, 2017)

*Includes contributions made after contributing $1,500, that is contributions > $1,500 in a given year

5.5 Canada Disability Savings Grant and Canada Disability Savings Bond take-up

Program staff key informants noted that when Registered Disability Savings Plans were opened, applications for the Canada Disability Savings Grant and Canada Disability Savings Bond were made simultaneously. Informants were aware that the number of Canada Disability Savings Grants and Canada Disability Savings Bonds being paid out was increasing.

For over two-thirds (69.4%) of respondents, the largest part of their Registered Disability Savings Plan holdings came from the Canada Disability Savings Bond and/or Canada Disability Savings Grant (see Table 4). Similar proportions of the remaining respondents stated that the Canada Disability Savings Bond/ Canada Disability Savings Grant and the personal contributions were about equal (14.0%) or that their personal contributions made up the larger part of the Registered Disability Savings Plan (16.5%). These custom survey findings are broadly consistent with published information based on administrative data showing that 32% of total Registered Disability Savings Plan assets are derived from personal contributions, while 68% are derived from Canada Disability Savings Grants or Canada Disability Savings Bonds.^{Footnote 75}

Gender differences were observed in the survey findings, with women more likely to say that the larger part of their Registered Disability Savings Plan holdings came from the Canada Disability Savings Bond and/or Canada Disability Savings Grant.^{Footnote 76}

A majority of respondents (64%) indicated that the Canada Disability Savings Bond and Canada Disability Savings Grant made up the larger portion of their Registered Disability Savings Plan. ^{Footnote 77} When the data were reviewed on the basis of income, respondents in the highest income group were significantly more likely to state that the Canada Disability Savings Bond/ Canada Disability Savings Grant and the personal contributions were about equal or that their personal contributions made up the larger part of the Registered Disability Savings Plan, while lower income individuals were less likely to say the same. This indicates that financial matching from the program is being received primarily by those least financially able to provide for their support needs. Indeed, this is how the program is designed. It suggests that the lowest income groups would be more financially vulnerable in the absence of the program.

5.6 Improvements in long-term financial security

Participants in the Survey of Households of Canadians with Disabilities were asked how helpful they found the Registered Disability Savings Plan, Canada Disability Savings Grant and Canada Disability Savings Bond to be in saving for the future. Key informants were also asked for their views on this question.

Survey for the Evaluation of the Canada Disability Savings Program (2017), Unweighted total n=884

*Total does not add to 100% due to rounding

The Registered Disability Savings Plan and the Canada Disability Savings Grant received similar helpfulness ratings as recorded in Table 4, while the score for the Canada Disability Savings Bond was lower for ‘greatly helped’ and higher for ‘no help’. This may reflect the fact that fewer people qualify for the Canada Disability Savings Bond, and those that do may qualify for only a portion of the Canada Disability Savings Bond and thus may not find it as helpful as the Registered Disability Savings Plan or Canada Disability Savings Grant.^{Footnote 78} Overall, informants supported the program but some believed that improvements to better reach very low-income and marginalized populations are still needed.

6.1 Administrative costs^{Footnote 79}

To examine how the administrative costs of the Canada Disability Savings Program compared to a similar program, the Canada Education Savings Plan was chosen. The design of the Canada Disability Savings Program was based on the Canada Education Savings Program with program staff representatives confirming that most aspects of the Canada Disability Savings Program "piggy-backed" onto the Canada Education Savings Program (for example registration of plans, issuer agreements) in order to achieve administrative efficiencies.^{Footnote 80}  As a result, the Canada Disability Savings Program has a similar delivery mechanism and components to that of the Canada Education Savings Program with grants and bonds delivered through partnerships with Canadian financial institutions.

Figure 7 compares the administration costs per beneficiary for the most recent 4 years of program operation.^{Footnote 81}  The first few years of the Canada Disability Savings Program are excluded from this comparison as the program incurred substantial start-up costs to build the systems and other supports required to launch and operate the program during that period. While the program’s annual administrative costs have declined somewhat, the number of beneficiaries has risen substantially,^{Footnote 82}  resulting in a significant decline in unit costs. The number of beneficiaries of the Canada Education Savings Program also grew over this period, but at a slower percentage rate due to the relative maturity of the Canada Education Savings Program compared to the Canada Disability Savings Program.

Analysis of cost/$1000 of savings held in registered plans shows an even steeper downward trend (chart not shown), as the total amount of savings held in Registered Disability Savings Plans (savings + bonds + grants) has increased even more rapidly than the total number of registered plans.

Text description of Figure 7

Registered Disability Savings Plan	Unit cost	RESP	Unit cost
2013	$61.54	2013	$3.95
2014	$41.45	2014	$3.73
2015	$27.02	2015	$3.46
2016	$16.94	2016	$3.12

The analysis here suggests that unit costs to administer the Canada Disability Savings Program have dropped rapidly as the number of registered plans rises while administration costs have also been declining. In light of other evaluation findings that many potential beneficiaries have not yet accessed the Registered Disability Savings Plan, this cost analysis suggests that there may be room to make new investments in reaching out to the target population and in overcoming obstacles to Registered Disability Savings Plan enrollment.

6.2 Effectiveness

In order to evaluate the effectiveness of the program, the evaluation considered whether the outcomes of the program were being achieved and whether the results-to-date demonstrate that the program is moving towards fully achieving its objectives. To address this issue, program staff key informants (10 of the 31 key informants) were asked whether they thought the program was achieving outcomes in the most effective way.^{Footnote 83} Almost all program staff interviewees reported being unaware of any redundancies or duplication of work in the delivery of the Canada Disability Savings Program.

Are the Registered Disability Savings Plan, Canada Disability Savings Grant, and Canada Disability Savings Bond helping to improve the long-term financial security of Canadians with disabilities?

The majority of financial institutions' and program staff key informants (17 of 25 interviewees) who responded to this question) stated that the program was contributing to improved financial security for persons with disabilities. A few of these interviewees stated that it was too early to tell, yet, whether the program would meet that long-term goal. A few others stated that the program, as it is currently designed, is helping to improve the long-term financial security of Canadians with disabilities, but that the help is being delivered to those who appear to need it less and they expressed concerns that very low-income and very marginalized groups are not benefiting as much as they could.

An analysis of administrative data reveals that the program has been effective in progressing towards its ultimate result of contributing to the financial security of people with severe and prolonged disabilities. The Canada Disability Savings Grant and the Canada Disability Savings Bond are designed to encourage people with disabilities who have low incomes to open, and contribute to, a Registered Disability Savings Plan.^{Footnote 84}  Indeed, the value of the matching Canada Disability Savings Grant paid into a plan is dependent upon the income level of the beneficiary. As described in section 2.3, for family income under the highest threshold^{Footnote 85}   the matching Canada Disability Savings Grant is 3:1 for the first $500 and 2:1 for the next $1,000 for a maximum of $3,500. For families with incomes greater than the threshold, the Canada Disability Savings Grant is 1:1 for the first $1,000 for a maximum of $1,000. Thus, examining the number of Canada Disability Savings Grants paid at the 300% and 200% level demonstrates the percentage of beneficiaries whose income is below the highest income threshold.

As presented in Figure 8, most of the Canada Disability Savings Grants being paid out are at the 300% and 200% levels, from a low of 84% in October-September 2011 to a consistent level of 88% beginning in October, 2015. Correspondingly, in terms of the dollar amounts paid out, most are also in the 300% and 200% levels. The percentage of the Canada Disability Savings Grant dollars paid out at the 300% and 200% ranged from 92% to 95%, with the remainder paid to families with incomes greater than the income threshold. Thus, both the number of Canada Disability Savings Grants being paid out and the dollar amount of Canada Disability Savings Grants paid out show that those below the income threshold are making contributions and receiving most of the benefit paid by Canada Disability Savings Grants.

Text description of Figure 8

Period of months from April 2010 to March 2018	% of grants paid at 300% and 200%	% of total dollars of grants paid at 300% and 200%
Apr-Sep 2010-11	85%	95%
Oct-Mar 2010-11	84%	94%
Apr-Sep 2011-12	84%	94%
Oct-Mar 2011-12	87%	94%
Apr-Sep 2012-13	86%	92%
Oct-Mar 2012-13	86%	93%
Apr-Sep 2013-14	86%	92%
Oct-Mar 2013-14	86%	93%
Apr-Sep 2014-15	87%	92%
Oct-Mar 2014-15	87%	93%
Apr-Sep 2015-16	87%	92%
Oct-Mar 2015-16	88%	93%
Apr-Sep 2016-17	88%	93%
Oct-Mar 2016-17	88%	94%
Apr-Sep 2017-18	88%	93%
Oct-Mar 2017-18	88%	93%

The Canada Disability Savings Bond is targeted at low income individuals and as income increases, the Canada Disability Savings Bond decreases. Those who receive a full Canada Disability Savings Bond represent those at the lowest income level. Analysis of program data indicates that 77% of Canada Disability Savings Bonds were paid out at full value over the years from 2010 to 2017, representing 89% of total dollars paid out. Thus, the vast majority of Canada Disability Savings Bonds paid out are for the full Canada Disability Savings Bond amount, which means they are being paid to beneficiaries who are in the lowest income category.

The analysis thus shows that both Canada Disability Savings Grant and Canada Disability Savings Bond are effectively distributing most of the benefits to those in the lower income groups. The Canada Disability Savings Grant is effective in encouraging those below the income threshold to contribute to their Registered Disability Savings Plan. In addition, the Canada Disability Savings Bonds that have been distributed have been mostly full Canada Disability Savings Bonds, showing that they are reaching the lowest income beneficiaries.

The Survey of Households of Canadians with Disabilities, conducted for the evaluation, showed that people in the low income category (below $26,021 in the year of the survey) have the largest amount ($36,700) in their Registered Disability Savings Plans and the lowest amount ($9,200) in other savings/investment vehicles relative to those in other income categories. Those in the high income category (above $89,400 in the year of the survey) are in the opposite position, having less money in their Registered Disability Savings Plan ($22,800) and more money ($37,700) in other savings/investment vehicles relative to other income categories.^{Footnote 86} This distribution indicates that the Canada Disability Savings Program is successful in targeting those who have low incomes.

Some key informants had expressed concerns that the program was not benefitting enough low-income beneficiaries. However, these findings demonstrate that for those low- and modest-income individuals who do choose to participate in the program, the results are quite positive.

6.3 Factors influencing program effectiveness

Data from key informant interviews indicate the following factors influence program effectiveness:

• Complexity of the process involved in applying for the Disability Tax Credit. Interviewees noted that both the complexity of the application process (medical practitioner verification is required) along with the potential expiry of the Disability Tax Credit (if it expires it must be renewed), create obstacles for people to apply.^{Footnote 87}
• Assistance Holdback Amount rules. Several key informants expressed concerns about the severity of the rules and the length of time before funds could be withdrawn from the account. Interviewees indicated that waiting until the beneficiary is 60 years old is too late in life for many to access their funds.^{Footnote 88} Performance of financial institutions in issuing Registered Disability Savings Plans. Issuers are primarily responsible for explaining the Registered Disability Savings Plan and its requirements to clients and assisting them to set up a Plan. While the number of financial institutions offering Registered Disability Savings Plans appears to be sufficient to meet consumer needs, some persons with disabilities in remote/Northern and rural areas may not be adequately served. Also, as noted above, the Survey and Case Studies^{Footnote 89} found that financial institution staff could not always answer questions around the specifics of the program.

Some interviewees indicated that rules around Lifetime Disability Assistance Payments limit program effectiveness, expressing 2 main concerns:

• By the time the beneficiary is 60 years old, the parents or caregivers of a beneficiary requiring significant care will likely be elderly. As such, they will likely need care themselves prior to that point, and will not be able to “fill the gaps” in provincial care, for about a decade before the beneficiary becomes eligible for Lifetime Disability Assistance Payments from an Registered Disability Savings Plan; and
• Many people with disabilities face shortened life expectancies and may not live long enough past 60 to fully realize the benefits of the funds accrued in Plans. Although exceptions can be made and Lifetime Disability Assistance Payments started early,^{Footnote 90} if a doctor can certify that the beneficiary is unlikely to live beyond 5 years, for many disabilities it is not possible to specify life expectancy.

Potential areas for future research towards improved program effectiveness:

Figure 9 suggests 3 broad areas which may hinder Canada Disability Savings Program effectiveness: (a) lack of awareness of the Registered Disability Savings Plan and/or motivation on the part of potential beneficiaries to move forward; (b) knowledge gaps about key plan features and administrative requirements; (c) administrative or service barriers that hinder action to open / maintain, invest in, or withdraw funds from a Registered Disability Savings Plan. Further research would focus and guide the following:

1. Awareness: A survey of a sample of Disability Tax Credit-eligible non-clients could capture their awareness and knowledge of the Registered Disability Savings Plan, perceived obstacles to opening a Registered Disability Savings Plan, and potential motivation to do so.
2. Awareness: Develop a systematic review of Registered Disability Savings Plan promotion efforts and their results across jurisdictions, including those targeting specific groups such as low income, Indigenous, newcomers to Canada, rural/Northern, and LGBTQ.
3. Knowledge gaps: Conduct focus groups and/or surveys of Registered Disability Savings Plan beneficiaries, families, financial service organization customer service staff, and third party intermediaries to identify knowledge gaps.
4. Knowledge Gaps, Administrative or Service Barriers: Examine Registered Disability Savings Plan take up and holdings according to level and sources of household income (for example earnings, social assistance), deductions claimed (for example Medical expenses), age, sex, province of residence, marital status and other personal or family characteristics available on the T1 file.
5. Administrative or Service Barriers: Conduct a survey of Registered Disability Savings Plan clients focusing on their service experience with their financial institution, government of Canada departments, and any other third party provider.

Recommendation 1:

Continue working with all partners to increase awareness amongst people with severe and prolonged disabilities, and their families of the benefits of having a Registered Disability Savings Plan and accessing the Canada Disability Savings Bond and Canada Disability Savings Grant.

Recommendation 2:

Continue working with all partners involved in delivering the Registered Disability Savings Plan, the Canada Disability Savings Bond and Canada Disability Savings Grant to identify and address the knowledge gaps^{Footnote 92} that persist within partner organizations and among Registered Disability Savings Plan holders and beneficiaries.

Recommendation 3:

Continue working with all partners to identify and address the barriers^{Footnote 93} that hinder people with severe and prolonged disabilities who are aware of the Registered Disability Savings Plan from opening or maintaining one and to improve the service experience of those who attempt to do so.

Document and file review:

This included previous evaluation final report and program documentation and project files provided by the program.

Administrative data

A data file prepared for evaluation was extracted from Canada Disability Savings Program administrative data and was analysed: Administrative Data Analysis for the Evaluation of Canada Disability Savings Program December 2008 to October 2015 (January 2017) (update – March 2017)

Key informant interviews:

Initially 36 interviews were planned; 31 interviews were conducted. Interviews were carried out by an external contractor and were conducted by telephone. Interview guides, based on the evaluation questions set by the Employment and Social Development Canada Evaluation Directorate, were prepared for each of the 4 stakeholder groups. Representatives from 4 stakeholder groups participated: program staff (Employment and Social Development Canada, Canada Revenue Agency and Finance Canada) (n=10), provincial/territorial representatives (income assistance programs) (n=8), non-government organizations (service provider organizations that advocate on behalf of persons with disabilities) (n=5) and issuers (financial institutions) (n=7) Interviews were carried out by between February 14 and March 10, 2017.

When reporting key themes, the following descriptors were used to summarize responses from key informants:

• "All/almost all" – findings reflect the views and opinions of 90% or more of the key informants in the group.
• "Large majority/most" – findings reflect the views and opinions of at least 75% but less than 90% of key informants in the group.
• "Majority" - findings reflect the views and opinions of at least 51% but less than 75% of key informants in the group.
• "Half" – findings reflect the views and opinions of 50% of the respondents in the group.
• "Some" - findings reflect the views and opinions of at least 25% but less than 50% of key informants in the group.
• "A few" - findings reflect the views and opinions of at least 2 respondents but less than 25% of key informants in the group. "A couple" refers to the opinions of 2 respondents.

Case Studies:

Thirty case studies were conducted of Canadian families that hold Registered Disability Savings Plans (Registered Disability Savings Plans) and that were determined to be broadly representative of a range of income brackets, age groups and regions.

Budget 2010^{Footnote 96}

• Canada Disability Savings Act (CDSA) was amended to allow the carry forward of any unused grant and bond entitlements from the previous 10 years (starting in 2008), up to an annual maximum of $10,500 for grants and $11,000 for bonds.
• Introduction of a rollover provision which allows for the tax-deferred transfer of proceeds from a deceased individual’s Registered Retirement Savings Plan, Registered Retirement Income Fund, and/or Registered Pension Plan into the Registered Disability Savings Plan of a financial dependent child or grandchild with a disability.

Budget 2011^{Footnote 97}

• Amendments to withdrawal rules to provide greater flexibility for beneficiaries with shortened life expectancy. For beneficiaries with a life expectancy of 5 years or less, the change allowed annual Registered Disability Savings Plan withdrawals of up to $10,000 in taxable plan savings, as well as a pro-rated amount of non-taxable savings, without requiring the repayment of grant and bond paid into the plan in the preceding 10 years.

Budget 2012^{Footnote 98}

• Expanded the definition of who may open an Registered Disability Savings Plan for a person with disabilities;
• Proportional Repayment Rule introduced so persons with disabilities will have greater access to their savings, as they only have to repay, at a fixed rate, part of any grants and bonds paid into their Registered Disability Savings Plan in the 10 years before the withdrawal;
• The annual maximum withdrawal limit for Registered Disability Savings Plans under certain conditions was increased to make withdrawals more flexible; a minimum amount must be withdrawn from an Registered Disability Savings Plan from the year that the beneficiary turns 60, to ensure that Registered Disability Savings Plan assets are used for beneficiaries during their lifetime;
• Rollover of Registered Education Savings Plan Investment Income to allow, under certain circumstances, the income earned on investments in a beneficiary’s Registered Education Savings Plan, to be moved, on a tax-deferred basis, into that person’s Registered Disability Savings Plan, further deferring taxation;
• Amending the rules around closing an Registered Disability Savings Plan when Disability Tax Credit eligibility ceases: Registered Disability Savings Plans can remain open for a longer period, under certain circumstances, after an individual ceases to be eligible for the Disability Tax Credit;
• Administrative changes to improve how financial institutions administer the Registered Disability Savings Plan, the grant and the bond for persons with disabilities: the 60, 120 and 180 day rules were eliminated and Employment and Social Development Canada committed to transferring the historical information related to the existing plan to the new issuer, when a plan is transferred from one issuer to another.

Budget 2015^{Footnote 99}

• Extend, until the end of 2018, the temporary federal measure that allows a qualifying family member to become the plan holder of a Registered Disability Savings Plan for an adult individual who might not be able to enter into a contract.