Thank you, Mr. Chair.
First, I'd like to thank the committee for the invitation to participate in this discussion. I want to thank all the members of Parliament for their incredibly hard work and leadership during this crisis. I'd like to thank the public servants, who are working so tirelessly to put in place these emergency measures: a complex and monumental task in these unprecedented times.
I want to make a few remarks, and then of course welcome questions. My remarks are made within the context of some guiding principles. First is immediacy of response; remediation of administrative errors can come later. Second are straightforward and simplified eligibility criteria and reduction or removal, where possible, of administrative requirements. I can provide some details on that. Finally, just a note I want to put in here, provinces and territories, in the spirit of Team Canada, should not offset any new federal payments by reducing income-related benefits, such as housing subsidies or child care subsidies. Unfortunately, this has happened in the past, and we hope that it won't happen under these circumstances.
I want to make just a few comments about the various components of the emergency measures, and again, I would welcome questions about the details.
In terms of the first benefit announced, the CERB, its scope and eligibility criteria to some extent remain unclear. I know it's extraordinarily difficult to put in place such a complex program so quickly, but even the general description of the CERB on the website—the first two sentences that describe it—is very confusing. For example, the second sentence says, “If you are looking for a job but haven’t stopped working because of COVID-19, you are not eligible”. Many self-employed people are looking at this, and we are receiving phone calls regularly from people. Just the other day, there was an email saying, “I wonder if this is me.” It's not very clear, because most people are in theory in the labour market. They want to be in the labour market, but there are no jobs to be had.
There are also questions with respect to certain aspects of the eligibility criteria that pertain to groups of people. For example, I've had questions from families with children with special needs. They are taking care of children with severe disabilities, for example, or young adults with severe disabilities. Would they qualify for this assistance? They're really struggling right now as programs close and all their sources of support dry up. Would they be eligible? For example, would someone holding a Canadian work visa who just recently came to the country and hasn't accumulated the necessary $5,000 be eligible for this? Would workers over 65 who have modest contractual income be eligible? There is an eligibility floor but not a ceiling, and perhaps that was intended.
My proposal in this regard is to perhaps dedicate a call line on CRA, if possible, or a call centre, to be able to answer some of these specific questions, or even a component on the CRA website where people can write in their questions. A briefing would be really helpful. Just like we're having regular health briefings, a “financial assistance health briefing” on our regular news broadcast would be really helpful. I'm chairing a committee reporting to the Minister of National Revenue, and because of the complexity of a particular tax measure we've recommended a dedicated call line around the disability tax credit. It certainly would be helpful for Canadians around the CERB.
I was pleased to see that the Prime Minister announced today that payments would be advanced on the Canada child benefit and the GST credit. That's really very crucial. We need to make sure that we keep these programs in mind if there is any overload of the system on April 6. I dearly hope there won't be, but in the event there is, these programs can reach the majority of Canadians and we can get to them very quickly. I wanted to point that out as a plan B that we can put in place.
There are some interface problems between the first program and the new emergency assistance announced for businesses. Some of them are just eligibility criteria and how we move from layoff back to rehiring, but there is a real problem I'd like to point out to you. After the initial CERB was announced, there were interviews with many different employment lawyers who warned employers that they could be subject to lawsuits for layoffs that they're making under the program because it's technically not permitted. I just want to point it out to you as a red flag. Perhaps there should be a period during which there would be protection of employers too, for example if a layoff occurred within two weeks following the CERB announcement.
We absolutely need to respect and protect workers' rights—there's no question about that—but in this case I think we've left small business employers open to a new vulnerability that was totally unintended.
I have just one or two more comments. I think the wage subsidy package is excellent. One of the problems, though, in comparing March to March is that many businesses were open for part of March, some of them up to the third week in March, and they may not have experienced the 30% reduction that's required. Nonetheless, they will still now have to lay off their employees while still wanting to retain their relationship with them. How do we deal with those kinds of circumstances? If businesses may have to lay off some people and not others, how do they deal with the on and off?
I have just one or two comments on the business loans, which were, I think, very important. Of course, businesses would prefer not to take on any more debt. That's just a caveat. Many would prefer deferrals on rent, utilities and insurance payments.
One question people have had is whether small businesses that are not incorporated are eligible for the $40,000 loan to be provided by the banks. It appears when people are talking that this is the case, but I've seen some fine print from some organizations saying that they are not, so some clarification would be very helpful.
On the role of the BDC, that's excellent. However, I've seen in very, very recent correspondence that the BDC has been asking for extensive reporting and questions to be answered, even by people who already have an established relationship with that organization. I would hope that under these circumstances we can minimize those administrative and eligibility requirements.
I can speak to charities. I won't do that now, but I can if there are any questions on that aspect.
My final point is this: Now is too soon to say what we could have done in retrospect. I recognize that; we have to get through the crisis. However, what I worry about is that when we come out, I hope sooner than later, at the other end and say we are going to rebuild everything that was in place, in many circumstances—for example, nursing homes for seniors and benefits for Canadians who are really missed in the current income security system—we don't necessarily want to go back to where we were.
What I'm recommending is that there be some kind of reconstruction advisory group, a group that can come together and make some proposals about where we could be going in the future so that we can avoid some of the problems that we have faced and that we're trying to address right now.
Thank you very much for your time and your attention.