How Bill 148 Hurts Seniors

August 3, 2017

The Honourable Kevin Flynn

Ministry of Labour
14th Floor
400 University Avenue
Toronto, Ontario M7A 1T7

Dear Minister:

I am the owner of a caregiving services company operating primarily in York Region and have very serious concerns about the impact of Bill 148 on senior care in Ontario.  We provide caregivers (mostly companions and Personal Support Workers (PSWs)) for seniors.  All of our staff are employees, fully vetted, insured and bonded. Our mission in providing care is to respect and dignify the lives that our clients have built and lived, and enrich their day-to-day experiences whenever possible.  With the exception of insurance, training, scheduling and bookkeeping software, 24 hour phone support, and a small office with 1 full-time staff member (all non-discretionary needs), all our other costs are labour and the directly associated expenses (CPP, EI, EHT, and WSIB).  We deliver approximately 60,000 hours of care each year, which makes us small but important to many seniors.

Bill 148 will be a disaster for our clients, our industry and my firm. Because almost all of our costs are labour, there is nowhere to offset the increase in wages. It must be passed on to the clients. This will result in a reduction in affordability for private care (at a time when CCAC/LHIN is reducing the hours they provide to seniors) and create a meaningful incentive for clients to use the underground economy and pay caregivers in cash. This of course will result in a loss of taxes paid, contributions to CPP, EI, EHT, and WSIB, and eliminate any controls over the quality of care being provided – and I am pretty sure you are aware of the risks associated with a lack of control over the quality of care for seniors.

Almost every element of the Bill will negatively impact senior care.   In addition to a direct increase in the cost of care, this Bill will hamstring the flexibility needed in providing senior care. Seniors have constantly changing health issues and their needs require last minute changes to shifts, being on call, and the ability to cancel shifts last minute. The rules that are being proposed will further drive up costs if they can even be made doable. As an example, 90% of our clients need care with a few hours to 1 day’s notice. Before a senior who needs home-care in order to return home can be released from a hospital, discharge planners and social workers tell families that care must be in place first. With the 4 day advance notice rule, seniors will have to stay in hospitals those extra days if we can’t get staff to accept the shifts.  Another typical example occurred a few nights ago: a client called me at 12:30am to tell me that their mother had to go to hospital and that they had to cancel the shift that started that morning at 8am. Am I supposed to wake up the caregiver at 12:30am or 5am in order to respect the 3 hour cancellation rule? I understand that all I have to do is pay the caregiver for the 3 hours but then I have to charge the client.

These events happened all the time and removing our flexibility to make the best decision given each situation’s unique circumstance, will drive up the cost of care.

I also think it’s important for you to appreciate the difference between what CCAC/LHIN provides and what private firms provide.  Government funded care providers already pay a higher minimum wage ($16.50) and will not be impacted nearly as much by Bill 148. Private firms who supply the PSWs for CCAC/LHIN shifts are reimbursed by the government by as much as $30/hour which makes it quite easy for them to pay their staff $16.50.  The client never sees the $30/hour charge so the increased rate those PSWs earn has no bearing on the affordability of care. Private firms without CCAC/LHIN contracts charge between $20-$25/hour and given the cost of CPP, EI, EHT, WSIB and insurance, and a bare bones operation, with a $14 or $15 minimum wage, 100% of the labour cost increase will have to be passed on.

To be clear, my staff does amazing work and I try to pay them as much as I can and still make it affordable.  I focus on relatively high need seniors. My average client has 160 hours of care per month. This way I can provide a lot of hours work for my PSWs and get the best staff.  But, with Bill 148, client costs will have to go up $2.50-$3.00/hour Jan 2018 and another $1.20 in 2019.

For seniors, home-care is not discretionary. They need the care. Bill 148 will cost them $5,000-$6,000 more per year – that is a huge cost increase for seniors most of whom have fixed and very limited income. This will drive more and more of them to seek illegal, lower cost, for-cash care or government funded Long Term Care facilities costing taxpayers more and dramatically reducing quality of life.  It was my understanding that the Ontario Government promotes the idea that it is far better if seniors can age at home – Bill 148 is in direct contradiction to that objective.

Would you please guide me in the best way to impact this bill? I can be reached at 416-994-6094 or

Yours sincerely

David Bernstein
President, Caregivers Services Ltd.



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