Okay. This is a long history, but in short, we had, from the 1940s to 2012, a system that was referred to as a board of referees. Basically, we had, in most communities in Canada, referees who were selected from business and labour, and also named by the government, to oversee appeal processes locally. This is a system that actually was light-footed. It wasn't particularly expensive, because people were being paid per diems per cause per claim, essentially per cause heard. Basically, it did the job. Here and there, there might have been complaints about an individual or something, but for the most part, when you have a system that works for 70 years....
In 2012, there was an unfortunate decision to do away with that. I don't want to remove the responsibility from whoever was there, but I do think there is a certain mentality in the bureaucracy, if I may say so, that processes can be centralized and made more efficient. I think that there was a great deal of that at work at the time, the belief that somehow we could have cost savings by just pooling the OAS, CPP and EI appeals processes together.
As it turns out, it was not that good an idea. A few years later we had to revisit this because there were problems with it, and I think that there was a lot of rose-coloured thinking when it was all put together.
The SST at the time that this reform was being discussed with constituents out there, business and labour groups, was not delivering. It was wholly inefficient and costly, as I said. The government actually did the right thing and basically got a third party to look at it. It bore out, as I said, what we were hearing on the ground, and then they proceeded to have a working group to redesign something that was pretty darn close to what the board of referees' vision was like. As I said, this was announced with some fanfare back in August of 2019, and for some reason, that vision got translated differently along the way.
Now what we have is not a structure that reports to the commission: It reports to the president of the commission, and that's a big difference. That means it reports to the deputy minister of ESDC. There's nothing wrong with the person, but that's not the same thing. That's not what people were aiming at.
One of the problems we've had with the SST as a commission is the reporting. When the SST started getting dysfunctional, it was impossible for us at the commission to get the proper accountability because they were independent. Now what we're doing is exactly the same thing. We're recreating an independent structure that doesn't report to the commission. To us, this does not reflect the stakeholders and the discussions we've had with the government.
Then there is this notion that somehow we're going to have full-time members who will be transferred from the Social Security Tribunal and tagged on with some part-time members on per diems to do.... It's not going to work. It's going to create an acrimonious culture. You're going to have people who are full-time with full benefits, full everything, and then part-timers, who will feel constantly disadvantaged. It's not a good way to start a new slate.
One thing that is absent and is absolutely crucial in all of this—this was really what we heard the most over the years—is the local presence, having members in at the regional level, the local level, who can hear cases in person so that it's not just a theoretical possibility to be heard in person, but it's actual. On this, the bill is absolutely silent, and it's key.
This means that essentially we're going to create a new management structure that will have quite a bit of latitude as to how this thing will be set up in the end. We think that's a mistake. There should be a requirement in there that there is regional representation—reasonable, of course—from all communities across the country so that people can be heard by peers from local communities across the country.
I'll stop here.