Thank you very much, Mr. Chair.
I want to begin by thanking the committee for giving as an opportunity to speak.
My presentation today will essentially focus on division 32 of part 5 of Bill C‑19.
My name is Luc Beauregard, and I am secretary-treasurer of the Centrale des syndicats du Québec, CSQ.
The CSQ represents 200,000 members, 125,000 of whom are education staff, including in higher education, which makes it the most representative organization in that sector in Quebec. It also has 11 federations, which bring together some 240 affiliated unions, and one retiree association. We are also present in the sectors of health and social services and early childhood education, as well as municipal, recreation, cultural, community and communications sectors across Quebec.
A few days ago, we shared our concern with Minister Qualtrough regarding division 32 of part 5 of Bill C‑19, which pertains to the Employment Insurance Board of Appeal and the Social Security Tribunal of Canada, commonly known as the SST. We asked her to remove that division from the bill so that it can be analyzed separately.
The SST was created in 2013 as a single point of contact to replace four administrative tribunals, including boards of referees. Prior to that, tripartite boards rendered first-level appeal decisions for insurance employment clients, which ensured better access to justice and participation by sector representatives who were familiar with the labour market and their region.
In 2019, the government announced, in a press release, that, at the suggestion of the KPMG firm, in its report on the review of the SST, reforms would be made to the tribunal, including a return to true tripartism as of April 2021. The announcement assured us that people would be at the heart of the appeal process and that the process itself would be accelerated, simpler and better adapted to Canadians' needs. That announcement also implied that sector stakeholders would be consulted.
The bill provides that the SST will report solely to the chairperson of the Canada Employment Insurance Commission. It is essential for the structure to be tripartite in order to ensure monitoring of how union and employer representatives will be deployed and trained and to ensure that they will fulfil their mandate on the board of appeal.
The board of appeal will not be a truly tripartite institution if social partners are not directly involved in the selection and appointment of members, workers and employers. In addition, the right to regional representation and to an in‑person hearing is missing from the bill. The necessary reforms should focus on the client, and they should be flexible and accommodating. Concrete access to an in‑person hearing was recognized as a key aspect of any reform of the employment insurance appeal system, and the presence of a tribunal member with expertise and knowledge of local markets is necessary.
Finally, the board of appeal is supposed to consist of two types of statuses: full-time tribunal members appointed by the Governor in Council and part-time members from the community of employers and insured people appointed by the commission. That distinction between statuses is a concern for us, as it necessarily causes inequity among members, but also a different level of commitment. Full-time members will have the special status of public service employees, which is reinforced by the fact that they will be the only ones able to hold the positions of chair, co‑chair and coordinating members. We feel that inequity is obvious.
In short, we would have liked to be consulted beforehand and given an opportunity to help develop the appeal process.
The provisions proposed in the bill do not reflect what was advanced and proposed by the government since the beginning of the process. Of course, we understand the delays caused by the health crisis, but that should not have limited the consultation of social partners in such an important file.
If no amendments are made to the provisions in division 32, we think the division should be removed from the bill in order to be studied separately.
Thank you for listening.