What we examined (see Focus of the audit)

This audit examined whether Employment and Social Development Canada (the Department) assessed applications for the Canada Pension Plan Disability (CPPD) benefit in a consistent and timely manner. The audit also examined whether the Social Security Tribunal of Canada (the Tribunal), supported by the Administrative Tribunals Support Service of Canada, decided CPPD appeals in a timely manner.

We did not examine the Department’s efforts to ensure the accuracy of benefit payments or the eligibility of applicants’ dependents for benefits. We also did not assess the Department’s outreach activities, vocational rehabilitation programs, or efforts to combat fraud. We also did not examine Tribunal activities that were unrelated to the CPPD program.

Why we did this audit

This audit is important because Canadians who have contributed to the Canada Pension Plan and cannot work because of a severe and prolonged disability may have to rely on the CPPD program as a source of income. The Department and Tribunal must manage the program as efficiently as possible to ensure the timely provision of the benefit to applicants who are entitled to it.

What we concluded

We concluded that Employment and Social Development Canada (the Department) assessed applications and reconsiderations for Canada Pension Plan Disability (CPPD) benefits in a timely manner as it met its service standards. However, it did not respect its guidelines for making faster decisions for applicants with terminal illnesses or grave conditions.

We also concluded that the Department did not ensure that it assessed applications for CPPD benefits in a consistent manner because the Department did not have a quality assurance framework in place.

Finally, we concluded that the Social Security Tribunal of Canada (the Tribunal), which was supported by the Department until November 2014 and afterwards by the Administrative Tribunals Support Service of Canada, did not decide CPPD appeals in a timely manner.

What we found

Application process

Overall, we found that applying for the Canada Pension Plan Disability (CPPD) benefit was a lengthy and complex process, requiring the completion of many forms. It can take several months for an applicant to complete a regular application, partly because of the complexity of the application documents. We also found that the process was largely paper-based, creating an administrative burden for Employment and Social Development Canada (the Department). This contrasted with programs, such as Employment Insurance, that offered online services. Finally, we found that the Department had not surveyed applicants’ satisfaction with program accessibility or assessed the efficiency of the application process.

These findings are important because an applicant with a severe and prolonged disability may find completing the complex application forms challenging. A paper-based process may be difficult for applicants with mobility-related or visual impairments, whereas an online process may be more accessible. Moreover, the date on which the Department receives an application affects when the benefit begins, so delays in completing an application may result in the applicant’s loss of several monthly payments.

• The initial application process for the Canada Pension Plan Disability benefit was lengthy and complex

  Recommendation. Employment and Social Development Canada should assess ways to streamline and simplify the initial application process for the Canada Pension Plan Disability program.

  Recommendation. Employment and Social Development Canada should regularly seek feedback from applicants and beneficiaries to identify ways to improve access to the Canada Pension Plan Disability program.

Initial, reconsideration, and appeal decisions

Overall, we found that Employment and Social Development Canada (the Department) met its service standards for initial and reconsideration decisions on Canada Pension Plan Disability (CPPD) applications. However, it did not respect its guidelines for making faster decisions for applicants with terminal illnesses or grave conditions. Moreover, some applicants who were granted the benefit after reconsideration or appeal had waited more than a year. We also found that the Department did not have a quality assurance framework in place to ensure that medical adjudicators followed the adjudication framework to make appropriate and consistent decisions.

We also found that the Social Security Tribunal of Canada (the Tribunal) did not decide appeals in a timely manner. This was partly because of the Department’s poor transition planning before the Tribunal was established. Once established, the Tribunal was not ready to handle the inherited backlog of 6,585 CPPD appeals. We also found that the backlog continued to grow, reaching 10,871 appeals in December 2014, and it took longer for the Tribunal to decide appeals. The Tribunal explained this was partly because it had to wait for appellants and the Department to indicate that they were both ready to proceed, as required by the Social Security Tribunal Regulations. The Tribunal also faced operational challenges. A study completed for the Tribunal in March 2015 identified more than 60 opportunities for improvements. Finally, we found that to assist the Tribunal in reducing the backlog, the Department reviewed appeals waiting to be decided and determined that some previously denied applicants were in fact eligible to receive the benefit.

These findings are important because delays in appeal decisions may significantly affect applicants’ ability to support themselves financially. According to the Department, people with disabilities tend to have lower incomes. The Tribunal was created to make the appeal process more timely and efficient.

• Employment and Social Development Canada met its service standards for initial and reconsideration decisions, but did not respect guidelines for making faster decisions for applicants with terminal illnesses or grave conditions

  Recommendation. Employment and Social Development Canada should review its Canada Pension Plan Disability service standards for initial and reconsideration decisions to determine whether they are appropriate.

  Recommendation. Employment and Social Development Canada should establish specific service standards for processing Canada Pension Plan Disability applications from applicants with terminal illnesses or grave conditions. The Department should also measure and report on its performance in meeting the standards.

  Recommendation. Employment and Social Development Canada and the Social Security Tribunal of Canada, supported by the Administrative Tribunals Support Service of Canada, should collect and accurately capture robust data to allow better monitoring of the Canada Pension Plan Disability program and accurate reporting of results.

• The Department did not review whether its medical adjudications were appropriate and consistent

  Recommendation. Employment and Social Development Canada should implement a formal quality assurance framework for the Canada Pension Plan Disability Program to review whether its medical adjudications are appropriate and consistent. This framework should include a process to inform medical adjudicators of the reasons why their decisions were overturned, and to support Department officials’ efforts to improve processing procedures and provide training to adjudicators.

• Poor transition planning by the Department led to the transfer of an unmanageable backlog of appeals to the Social Security Tribunal of Canada

  Recommendation. We made no recommendations in this area of examination.

• The backlog of appeals increased, and decisions took longer, after the Tribunal was established

  Recommendation. The Social Security Tribunal of Canada, supported by the Administrative Tribunals Support Service of Canada, should review its policies and practices to ensure that they adhere to the intent of the Social Security Tribunal Regulations, to ensure the most expeditious appeal decisions.

• For about one third of appeals further reviewed by the Department, appellants were found eligible for benefits despite being denied twice previously

  Recommendation. Employment and Social Development Canada (the Department) should analyze the results of its triage review to identify ways to modify its policies and processes to ensure that the benefit is granted earlier to eligible applicants. The Department should also consider the lessons learned in developing a quality assurance framework, to ensure that its decisions are appropriate and consistent.

Entity Responses to Recommendations

The audited entities agree with our recommendations, and have responded (see List of Recommendations).

Related Information

For more information

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