Evaluation of the Canada Pension Plan (Disability Component) - Final Report - September 1996

1.1 Overview of the Report

Purpose: This is a report of Phase II of the evaluation of the Canada Pension Plan, namely of the Canada Pension Plan Disability Program (CPPD). The evaluation research was carried out in conformance with Treasury Board policy that Departments and Agencies undertake evaluations of their programs when needed, as part of their strategic management, and to meet the priority information needs of federal departments/agencies on the performance of their programs. A Phase I evaluation examined the CPP retirement benefit.²¹

This Report provides the findings and conclusions of this evaluation.

1.2 Objectives of the Evaluation

The evaluation was commissioned in June, 1995 by Human Resources Development Canada (HRDC), to provide a comprehensive overview of CPPD, and to examine issues of rationale, impacts and objectives achievement, and alternatives.

The evaluation also had a specific objective: to examine the reasons for the increase in the CPPD caseload in recent years, particularly in the period 1991-94, and concerns regarding rapidly increasing costs of the CPPD program. Related questions posed for the evaluation involved resolving the very different program experience for CPPD and the parallel Quebec disability plan (QPPD), especially in the period 1991-94. The most notable of these differences was the fact that the QPPD did not experience the same rapid increase in caseload and costs as CPPD. These differences were seen as somewhat surprising, since the plans were intended to be similar when enacted by statutes of the Parliament of Canada and the Legislature of Quebec, which established public disability insurance (PDI) in Canada in 1966, in the form of CPPD and QPPD.

This question, of why QPPD is different, was an important one for the evaluation and the assessment of the overall efficiency of CPPD.

1.3 Background

1.3.1 History and Purpose of CPPD

The Canada Pension Plan (CPP) was established by an Act of Parliament, namely, an Act to Establish a Comprehensive Program of Old Age Pensions and Supplementary Benefits (hereafter Act), in January, 1966. The CPP provided the only comprehensive PDI program for workers in Canada, ensuring minimum protection against the loss of employment earnings as a consequence of retirement, disability or death.

The operation of CPPD must be considered in the context of a large number of public and private programs which provide complementary benefits for persons with disabilities, particularly Workers' Compensation Boards (WCBs), Provincial/Territorial Social Assistance, private long-term disability insurance (LTDI) and auto accident insurance.

Almost all wage earners, their employers and self-employed workers in the jurisdictions participating in the CPP (all provinces and territories except Quebec, which has its own plan) are required to contribute to the program. The CPPD program is an ancillary benefit of the CPP retirement pension program. However, CPPD does not have a separate set of dedicated contributions within CPP. There are nearly 300,000 beneficiaries and benefits have more than tripled from $841 million in 1986-87 to close to $3 billion in 1995-96.

All contributors meeting a certain number of eligibility requirements - most importantly, number of years of contributions to the plan - are entitled to receive a disability pension in the event of inability to regularly pursue a substantially gainful occupation due to a disabling condition, whether or not the disability was work-related. The program is intended to provide a minimum level of earnings replacement for contributors who become disabled.²². The intention of the Disability Benefits portion of CPP was to use the contributory insurance program to replace a portion of a disabled worker's earnings until the beneficiary qualified to receive the CPP retirement pension at age 65. As well, there is a CPP child benefit payable for the children of a disabled beneficiary.

While the Quebec and the Canada disability programs were originally intended to function along similar lines, they operate under different legislation and fall under the responsibility of different levels of government.

Major aspects of the two programs remain similar, but several differences have emerged over the years in terms of eligibility criteria, definition of disability, operational standards, etc.²³

1.3.2 Recent CPPD/QPPD Program Experiences

The most noticeable difference in program experiences between CPPD and QPPD in recent years has been the contrast in the application rates and the number of disability pensions granted. While the CPPD program has experienced a sharp increase in the number of applications in the period covering the fiscal years 1990-91 to 1993-94 (see Exhibit 1), the number of applications to the QPPD Program has since then remained relatively stable²⁴. A second key difference, and one related to caseloads, is the extent to which QPPD, more so than CPPD, has since 1984-85, reflected a strongly pre-retirement orientation, with this emphasis strongly enshrined in Quebec legislation. A somewhat less pronounced pre-retirement orientation in CPPD was manifest in an administrative direction applied in 1989-95. In both programs, older workers were assessed on the basis of their ability to engage in their own job, rather than in any substantial gainful employment. However, caseload characteristics suggest that the QPPD pre-retirement emphasis was much greater. This provision was removed from CPPD by the introduction of new CPPD adjudication guidelines in 1995. Another difference is that the proportion of the working age population, covered by and receiving CPPD is higher than for QPPD.

Specific CPPD Issues: Some reports, particularly the Report of the Auditor General of Canada, 1993, suggest that CPPD evidences antiquated, unresponsive and inefficient systems in such areas as program oversight (financial accountability), case processing (backlogs), appeal reversal rates, reassessment and client service. These very important concerns raised by the Auditor General remain concerns in 1996. However, some of these concerns are being addressed under a major HRDC initiative - the Income Security Programs Redesign Project (Redesign) - which reorganizes the delivery of the Old Age Security and CPP programs. It is currently regionalizing and re-designing CPPD operations to improve access and service to clients, and to upgrade administrative systems, including computer systems. The full effect of these changes will not be known until after the Redesign changes are completed in 1997. Additionally, other valid concerns raised by the 1993 Auditor General's report have been addressed through initiatives such as the CPPD pilot project on reassessment, changes in the structure of appeals, and new adjudication guidelines in September, 1995.

Exhibit 1 Historical CPPD/QPPD Fiscal Year Applications*

* Note: Based on fiscal year program statistics, e.g., 1970 represents the fiscal year ending March 31, 1970. The above graph must be interpreted with care as the scale used to represent both CPPD and QPPD data on the same exhibit tends to minimize variations for QPPD while amplifying variations for CPPD.

The program faces a number of other important issues, such as linkages to other programs, particularly provincial programs such as those of workers' compensation boards (WCBs), provincial social assistance (PSA) and private long term disability insurance (LTDs). Some related issues include the impact on CPPD caseloads of the referral of eligible persons from PSA and LTDs to CPPD. These referrals are thought to have had a significant impact on CPPD caseloads.

1.3.3 Linkages of CPPD to Other Programs

CPPD operates in a complex environment, involving many other organizations, both governmental and non-governmental. Some key features are noted below.

Referral Bodies: When an individual becomes disabled, many sources may provide information: the employer (if the individual is currently employed), a physician, medical institution, or a welfare or unemployment insurance office. Whether a referral is made will depend on the circumstances which caused the disability and which programs the individual may be eligible for. Thus, for example, individuals may be referred to different income support or earnings replacement bodies, such as welfare, an employer's insurance company, or a WCB. Generally, these referrals have been found to be highly varied.²⁵ This may be significant to issues of rehabilitation, since a complex or drawn-out referral process may delay access to rehabilitation at the key time for rehabilitation efforts - that is, shortly after the onset of disability.

Multiple Income Support/Earnings Replacement Bodies: As noted, a wide range of institutions may come into play when an individual becomes disabled. Often these have very different eligibility rules and benefits. Program providers include WCB, LTDI, PSA, and a variety of other programs²⁶, which must often be coordinated with CPPD. Depending on the circumstances of the disablement, and whether the individual is employed at the time, he/she may be covered by different programs. Thus, two individuals with the same disability, generally the same work histories, and the same needs may be treated quite differently.

These bodies often apply different definitions of disability (WCBs compensate for all partial and total disabilities), while CPPD provides benefits only to those who have a severe and prolonged disability) often reduce their benefits by the amount of CPPD benefits, and may make decisions faster than CPPD. These differences often result in duplicate applications and medical reports, overpayments, and delays in payments. The complexity of these problems is exacerbated because of the different rules of the many disability insurance providers.

1.4 Evaluation Issues and Criteria

1.4.1 The Evaluation Issues and Questions

The terms of reference set out a number of basic questions that this evaluation endeavors to address. Nearly all of these questions are addressed within this report. As well, some additional questions emerged in the course of the evaluation, as is noted within. Some questions are answered in an exploratory manner, with the suggestion that additional research be undertaken. The evaluation questions are organized around three key issues, in accordance with Treasury Board of Canada²⁷ policy on evaluations. These key issues (and related questions) are:

Rationale: What are the program's objectives? Are the program component benefits still relevant? Evaluation questions include, for example, more specific questions such as: Should the Federal government be involved in providing PDI benefits through CPPD?
Program Success: Objectives Achievement: What has been achieved by CPPD? Was this program component successful and efficient? Evaluation questions address more detailed issues such as: What are the detailed characteristics of eligibility criteria, definitions of disability, suitability of adjudication, utilization (increases in beneficiary caseload because of take-up), possibility that legitimate applicants were denied benefits or never applied for them, linkages with other programs, etc.? Impacts and Effects: What happened as a result of these program benefits? Evaluation questions also address more specific issues such as: Were there unintended program effects (abuse, economic grants, the need for monitoring, reassessment, rehabilitation, or assistance in return to work; were the increases in expenditures justified? What were the impacts on other public and private LTDI providers, etc.)?
Alternatives: Are there better and more cost-effective ways of achieving the objectives of CPPD, e.g., via alternative design and delivery approaches?

Treatment of the Detailed Questions: While the three key evaluation issues are addressed throughout, it was difficult to organize the report around the more than 60 sub-topics for a number of reasons. Therefore, a simple question-and-answer framework is neither feasible nor appropriate in every section of the report. The reasons are: first, a number of the specific questions could not be fully answered in this evaluation research. In some cases the data or information were not readily available, or alternatively, could not be answered within the scope of our resources or methodology (these questions are identified with an * below). Second, attention has been given to other detailed evaluation topics which only emerged in the course of the evaluation. Overall, it is our assessment that these added investigations have enhanced the comprehensiveness of the overall evaluation process.

The following section presents the evaluation questions, which were detailed in the Terms of Reference for the evaluation. They are classified according to the major Treasury Board categories of evaluation issues (program relevance, program success and cost-effectiveness).

Program Relevance (Program Rationale): Should the federal government, be involved in providing disability benefits through CPP?

Program Success (Objective Achievement Impacts): Did the program accomplish its goals? Sub-questions are:

Are current eligibility criteria appropriate for the disability benefits in light of work force trends? How do these benefits compare with those of Canada's key trading partners?
What are the claim patterns, profiles and activities of these claimants?
Why has there been an increase in CPPD claims during the last 15 years, including the recent recession? Is the increase in CPP Disability caseload and expenditure levels justified or is it caused by inappropriate factors, which, if addressed, would lower incidence levels?
Are the claims being assessed properly? How effective are reassessment procedures for determining whether persons receiving disability benefits should continue to receive them?
Is the definition of "disability" applied in a consistent and equitable manner by program adjudicators? What are the differences between CPP, QPP and other countries in defining disability, coverage and claim rates, and their implications? Are criteria applied in a consistent and equitable manner by medical practitioners and appeal boards?
What proportion of income (earnings) replacement is supplied by CPP Disability benefits? What are the impacts of the Year's Basic Exemption (YBE) and the Year's Maximum Pensionable Earnings (YMPE) on disability payment levels?
Is there any duplication of earnings replacement benefits/coverage for public (federal, provincial) and private sources, i.e., CPP Disability, provincial Workers' Compensation and private long-term disability benefits?
Within the Canadian income security system, what kind of offsetting practices have been adopted, especially in light of the interaction of CPPD/QPP Disability benefits with other government benefit programs, other earnings, or private insurance benefits?
What proportion of CPP Disability recipients also receive private insurance benefits or provincial Workers' Compensation Board benefits, and do these offset CPP benefits?
What proportion of these benefits are recovered through the tax system and/or lower complementary program costs?
Are there special challenges posed by special target groups (e.g., the doubly disadvantaged), and, if so, can these be addressed?
What are the levels, if any, of misuse and abuse of disability benefits e.g., extent of receipt of benefits by those who are not entitled to them (*or non-application for eligible benefits)?
Do CPP Disability benefits constitute economic grants (act as a form of unemployment benefit or bridge-to-retirement benefit, where pensions are awarded to persons with mild or moderate disabilities primarily for the above economic reasons, rather than on medical disability grounds)?
Should the eligibility requirements of disability claimants (the extent to which applicants meet them) be monitored more rigorously?
What steps are needed to verify continued disability of recipients of CPP Disability pensions on a cost-effective basis?
Are resource constraints preventing efficient and cost-effective monitoring activities? Are sufficient resources being allocated to reassessments, rehabilitation and fraud investigation?
Do current provisions for disability benefits support rehabilitation and return to the labour force? What are the rehabilitation efforts under CPP? What is the relationship between the rehabilitation efforts under CPP and those under complementary provincial and federal programs (e.g., Vocational Rehabilitation of Disabled Persons Program (VRDP)?
Why have the expenditures on disability benefits increased significantly in recent years above those projected in the CPP Fourteenth Actuarial Report?
What were the causes for the increase in CPP Disability benefit payments?
Is this recent increase in CPP Disability payments a permanent or temporary trend?
What are the implications of long-term CPP Disability for private insurance coverage?
In the absence of CPP Disability benefits, what would have been the likely effects on private long-term disability insurance (LTDI) contribution rates needed to provide the same protection?
How would an absence of CPP disability benefits have likely affected the disability coverage through employer-sponsored RPPs or welfare payments? What are the comparative costs of CPP Disability and private insurance coverage?

Cost-Effectiveness and need, if any, for alternative approaches: Sub-questions are:

Should the CPP disability program be modified to improve the attainment of its objectives? Should it be modified in any way to improve its effectiveness and administrative efficiency? Should it be modified to improve its efficiency in delivery?
Are the disability benefits affordable currently and in the future?* Would it be desirable, feasible and cost-effective to develop some form of separate, individually based, experience-related CPP Disability program? Should such a federal employment-related disability program be provided on a fully-funded basis? Would income-testing or repayment of disability benefits above certain income levels be desirable, feasible and cost-effective?

1.4.2 Some Evaluation Criteria and Indicators

The evaluation questions require not only a wide range of information, but also criteria against which the answers can be evaluated. Some criteria against which the program was assessed include for example, the extent to which the program is Client Responsive (responds in a timely manner to applicant and beneficiary needs, with information, decisions, etc.); Meets Needs Efficiently (provides benefits to eligible contributors who qualify (who have a severe and prolonged disability which prevents them from pursuing regular substantially gainful employment); maintains Equity (treats similar individuals in similar ways; decisions are consistent and replicable).

As well, the evaluation questions reflect concerns with such criteria as Societal Efficiency (the PDI program protects members of society, reduces the societal risks of individuals being uninsured, and supports societal needs for economic competitiveness, etc.); maintains Work Incentives, and facilitates Client Rehabilitation.

Finally, the evaluation questions include concerns for such underlying features as System Efficiency (duplications of services are minimized, linkages among programs and differing levels of government, differing PDI providers, and LTDI providers are smooth, timely, and efficient; the program is consistent with and reinforces the income security system); and Cost-effectiveness (the program minimizes costs, particularly public costs, while maximizing other PDI objectives as noted above).

Many of the evaluation questions can be answered in a straightforward manner. Some others cannot be directly addressed in this report. However, many other questions can be considered only by examining proxy indicators - often with multiple lines of evidence.

Extent of Disability: Recognizing the ultimate purpose of the evaluation in serving the Canadian public, the treatment of some of these issues involves the application of operational indicators in relation to CPPD. One indicator of this sort is the evaluation's examination of extent of disability among CPPD beneficiaries.

While eligibility for CPPD has to do with far more than just disability per se - contributory requirements, expected duration of disability, and capacity to engage in substantially gainful employment - disability is central to public concerns about the program. This is particularly so because some have suggested that the program has become an income support program for many individuals who are not really disabled at all.

Thus the impact of the disability of CPPD beneficiaries is examined using data from Statistics Canada surveys, the 1991 Health and Activities Limitation Survey (HALS) and the 1995 Survey of CPPD Beneficiaries.²⁸

QPPD as a Point of Comparison: The evaluation draws a number of comparisons with QPPD. However, it must be emphasized that the use of QPPD as a test of the reasonableness of CPPD is an operational convenience. It should be remembered that while the evaluation draws on considerable data on QPPD, the evaluation addresses the CPPD, and not the QPPD, and is in no way an evaluation of QPPD.²⁹

1.5 Method of the Evaluation: Component Studies

The CPPD evaluation builds on the methodologies employed in a number of background research studies which provide multiple lines of evidence on key evaluation issues. These evaluation component studies include a wide range of research into Canadian and international experience with PDI programs. The research components of the evaluation are briefly described as follows.

Literature Review on PDI Programs: This background paper was conducted examining Canadian and international research on PDI. More than 50 research sources were examined in detail in the review. The literature review outlined a number of fundamentals, including the rationale for PDI, the role of economic factors in the increasing use of PDI benefits in all countries and various administrative features of PDI programs.³⁰

QPPD as a Comparison Case for the CPPD Program: This background paper examined the QPPD to identify similarities and differences between these two key programs, particularly in eligibility criteria, definitions, adjudication and administration.³¹ Linkages to other programs, most importantly the Quebec WCB (CSST) and provincial social assistance were also closely examined.

This background paper outlined a number of features of the Quebec plan which could be emulated by CPPD (especially in linkages among different income replacement programs), and some operational features potentially worthy of emulation (e.g. more extensive use of independent medical examinations). Equally important, the study demonstrated the difficulties of making simple comparisons between CPPD and QPPD because of their different contexts and levels of government administration (one Federal and the other Provincial).

As part of the QPPD comparison, A Statistical Comparison of CPPD and QPPD using the Statistics Canada Health and Activities Limitation Survey (HALS) of 1991 was conducted, to examine differences in the beneficiary populations of CPPD and QPPD.³² This analysis allowed for the examination of the extent to which objective criteria (i.e. severity of disabilities, age, sex, need for assistance, whether or not individual was in receipt of Federal disability tax credit), can be used to predict CPPD and QPPD decisions to grant pensions, in order to examine the relative generosity of the two programs. This analysis also tested hypotheses about the level of severity of disability of CPPD beneficiaries as compared to QPPD beneficiaries, and was used to examine other issues, such as the extent to which CPPD or QPPD beneficiaries are persons with potential for rehabilitation or potential to return to full-time work.

A Survey of CPPD Beneficiaries was reported on, highlighting demographic factors, nature of disabilities, and the orientation of beneficiaries to work.³³ A part of this analysis was an examination of CPPD beneficiaries in 1991 and 1995, using identical indicators of extent of disabilities. The analysis compares disabilities of CPPD recipients as assessed in the 1991 Health and Activities Limitation Survey, and the 1995 CPPD Beneficiaries Survey (both studies conducted by Statistics Canada).

The evaluation used these indicators of disability for comparison purposes only, since the 1995 CPPD Beneficiaries Survey was not specifically designed to develop an index of severity, and does not capture all CPPD eligibility criteria. By examining the extent of disabilities of CPPD recipients at two points in time, this analysis was designed to test the hypothesis that CPPD program administration has been relaxed in recent years, thus contributing to the 1991-94 increase in CPPD applications. It is noted, however that changes in eligibility criteria prior to 1991 may have exhibited lagged effects that manifested themselves in the 1991-94 period.

An International Comparison of PDI Programs was conducted examining CPPD in relation to public disability benefit programs in seven other countries including the United States, the United Kingdom, Australia, Germany, the Netherlands, New Zealand and Sweden.³⁴

The international comparison considered program eligibility, definitions, adjudication, appeals and administration, reassessment, rehabilitation and work incentives, and also experiences in PDI caseloads since 1983. The comparisons highlighted many similarities between the experiences of CPPD and PDI programs of many of these leading trading partners. As well, many differences and potential lessons were identified.

An Analysis of CPPD Stakeholders' Perceptions: The views of CPPD stakeholders were obtained through interviews with a wide range of parties familiar with CPPD.³⁵ Interviews were conducted with such stakeholders as Provincial representatives (Workers' Compensation Boards and Provincial Social Assistance (PSA) Ministries), private LTDI companies, which provide disability insurance for employers and workers, voluntary organizations representing disabled persons, and other groups such as employers' associations and organized labour. Interviews were also conducted with Federal officials, including staff of the CPPD, and others such as the Chief Actuary of the Office of the Superintendent of Financial Institutions.

Statistical Analyses of CPPD Caseloads: Exploratory analyses were conducted, examining the potential impacts of program factors (legislation, eligibility, administrative practices, benefit rates) and economic factors (unemployment rates, duration of unemployment) on CPPD program applications and benefits granted in the period 1981 to 1994.³⁶ A related background study used data from CPPD administrative files, tax files and related sources to examine the relationship between levels of CPPD claims with unemployment levels in different periods and the relationship between claims and regional employment conditions.³⁷

Earnings Replacement Simulations: Estimations were prepared to assess the impact of CPPD on individuals' post-disability incomes - the extent to which CPPD can replace gross and disposable pre-disability earnings. The simulations relied on the Modular Analysis Package for Systems of Income Transfers (MAPSIT) computer modeling package previously developed by HRDC. For this evaluation, MAPSIT models were updated by HRDC for four provinces³⁸ to calibrate earnings replacement impacts of CPPD - the extent to which CPPD replaced pre-disability earnings of individuals with disabilities under various conditions, such as different pre-disability earnings levels.

Simulations of Net Program Costs: Simulations of net program costs were developed by HRDC, using the Simulation-Tabulation (SIMTAB), a computer simulation estimating net recoveries of CPPD expenditures in the form of other program offsets, income tax revenues for Federal and Provincial governments resulting from the taxation of CPPD benefits, and other recoveries. These simulations were based on data from the 1992 Survey of Consumer Finances projected to 1995.

Findings of an Evaluation of the CPP National Vocational Rehabilitation Project (NVRP): An evaluation of the NVRP was conducted in Summer, 1996, to assess the extent to which this program met the rehabilitation objectives of the Canada Pension Plan Disability (CPPD) program. The evaluation focused on identifying the strengths and weaknesses of the current pilot project, and to ascertain the need and rationale for a permanent longer term rehabilitation function within the CPPD.

Other Research: A variety of other analyses were undertaken. These included reviews of administrative file data reports, audits, the 1990 Evaluation of the Canada Pension Plan and HRDC's 1995 CPP Disability Incidence Study, which collected a wide range of information on administrative practices and a recent CPP/QPPD comparison study, which examined how many CPPD beneficiaries would be eligible using QPP rules and practices.³⁹ These reports provided perspective on the administration of CPPD, including adjudication practices and quality controls. Other data were also examined, including PSA statistics, benefit rates, and data on the private LTDI sector.

Limitations: The evaluation did not complete a file review, as called for in the Terms of Reference. This review was deferred, on the grounds that initial data were already available from a file review, conducted for the HRDC CPP Disability Incidence Study,⁴⁰ and that more useful information could be obtained from the several analyses noted above which examine characteristics of beneficiaries, or other administrative data.⁴¹ However, as discussed at length in the conclusion of this report, an on-going file review, with a prospective methodology,⁴² could provide additional data on key questions, such as those relating to the extent of economic grants.

1.6 Previous Research

Previous research provided many useful starting points for the development of this evaluation and facilitated the development of its methodology in a relatively short time. For example, the researchers benefited greatly from HRDC Income Security Programs Branch's Disability Incidence Study, 1995, which provided an extensive and important knowledge platform for this evaluation. Other studies of value included the thorough historical review of CPPD developed by HRDC.⁴³

1.7 Organization of the Report

The evaluation analysis considers the main evaluation issues and questions in three parts:

Rationale;
Impacts, Effects and Objective Achievement; and
Alternatives/Ways of Improving CPPD.

In each section, evidence is drawn from the background research to describe program features, impacts and success, alternatives, etc. In several places the analysis returns to specific issues such as the 1991-94 CPPD caseload increase and its causes, and the question as to why CPPD and QPPD caseload/cost experiences have been so different over the past ten years.

Section 2 examines the rationale for the CPPD Program. Section 3 provides a summary assessment of the success of the program (objectives achievement, impacts and effects of the CPPD, including areas for improvement). Section 4 suggests alternatives and potential changes for the CPPD Program.

Throughout, this report will rely on abbreviations to provide a brief reference to the variety of programs involved in income security for persons with disabilities. As a rule, short forms or abbreviations (e.g. PDI, CPPD, QPPD, WCB, PSA, LTDI) are used over long forms; generic references are used over specific references, particularly for provincial and international programs; and English abbreviations and short forms are also used for Quebec programs.

Thus the analysis will generally speak about CPPD and QPPD, and for example, about "the American PDI". Exceptions will be made only where necessary for clarity. Specific questions posed for the evaluation (see Section 1.4.1) are referenced throughout the report.

²¹ * See, CPP Phase I Retirement Benefit, Evaluation Report, Evaluation and Data Development, Strategic Policy, Human Resources Development Canada, July, 1995.

²² There is no requirement that the contributor must be working at the date the disability begins.

²³ Report of the Auditor General of Canada, 1993. Also, see Experience of the QPP Disability Program, A Comparison Case for the CPP Disability Program, a working paper for the CPPD Evaluation, SPR Associates Inc., March 1996.

²⁴ While the number of applications to CPPD declined from about 109,000 in 1993-94 to about 93,000 in 1994-95, it slightly surpassed 90,000 in 1995-96. The grant rate has significantly declined and caseload numbers were flat in 1996. The most recent data also shows significant reductions in new grants at both the initial application and appeals levels. Canada Pension Plan Disability Benefits Caseload Growth Analysis Report (draft), June 1996.

²⁵ See: Canada Pension Plan Evaluation, Communications Study, SPR Associates Inc., 1989. There were no discernable trends in these referrals. The individual (or agent) must submit the application to the CPP ; the WCB or other external bodies can't do it for them.

²⁶ CPPD claimants may also have been supported through such programs as Unemployment Insurance Sickness Benefits, or Automobile Insurance.

²⁷ Treasury Board of Canada Policy (1977-47) on Evaluation of Programs by Departments and Agencies. This was reconfirmed in 1992 in Treasury Board Manual, Evaluation and Audit.

²⁸ When these data are examined within this report, it should be remembered that these surveys were not designed specifically to generate an indicator of CPPD's definition of disability, but rather more general indications of activity limitations. Further, these survey measures of disabilities are based on self-reporting. It should also be noted that the sample of QPPD beneficiaries in HALS was proportionately low vis-à-vis that for CPPD beneficiaries.

²⁹ In addition to sub-studies of this evaluation, a report on QPPD has recently been prepared by the QPPD administration. See: Rapport sur l'invalidité : Comparaison et orientations, Direction de l'évaluation, Régie des rentes du Québec, September, 1995.

³⁰ See: A Literature Review on Public Disability Insurance Programs, a working paper for the CPPD Evaluation, SPR Associates Inc., March 1996.

³¹ See: Experience of the QPP Disability Program, A Comparison Case for the CPP Disability Program, a working paper for the CPPD Evaluation, SPR Associates Inc., March 1996. The examination involved in-depth interviews with representatives of the Régie des rentes du Québec, the agency responsible for administration of the QPPD. Note, as a rule, English translations/acronyms are used in this report.

³² See: Experience of the QPP Disability Program, A Comparison Case for the CPP Disability Program, a working paper for the CPPD Evaluation, Technical Analysis #1, SPR Associates Inc., March 1996. The limitations of this analysis were previously detailed in footnote 7, page 11.

³³ See: An Examination of the 1995 Statistics Canada Survey of Beneficiaries, a working paper for the CPPD Evaluation, SPR Associates Inc., March 1996.

³⁴ See: International Comparison of Public Disability Insurance Programs, a working paper for the CPPD evaluation, SPR Associates Inc., March, 1996.

³⁵ See: Overview of Stakeholder Interviews, a working paper for the CPPD evaluation, SPR Associates Inc., January 1996.

³⁶ The analysis also examined factors affecting QPPD over approximately the same time period, although the same type of data was not always available for the same time period for both programs. See: Experience of the QPP Disability Program, A Comparison Case for the CPP Disability Program, a working paper for the CPPD Evaluation, Technical Analysis #1, SPR Associates Inc., March 1996.

³⁷ See: A Labour Market Analysis of CPP Disability Claimants, Abt Associates, January 1996.

³⁸ Alberta, Newfoundland, Ontario and Saskatchewan.

³⁹ Commentaires et observations (Étude comparative des dossiers RPC/RRQ du 27 mai au 7 juin 1996) par Roger Dorion et Claude Sarra-Bournet du Régime des rentes du Québec.

⁴⁰ That file review examined some 523 CPPD cases, and estimated that about 3% of grants were not fully consistent with prevailing adjudication guidelines, while another 4% would have required further development to make a proper determination. The review involved a reconstruction of adjudication decisions for a sample of cases granted benefits in 1994, and examined only one side of the error equation - inappropriate grants. No assessment was made of inappropriate denials. See: CPP Disability Incidence Study, Main Report, HRDC, 1995. As well, the evaluation examined HRDC overpayment studies, program integrity assessments including the recently completed 1995 assessment, and program internal audit reports.

⁴¹ Specifically, the HALS analysis allowed examination of disability characteristics of a sample of CPPD beneficiaries and a smaller sample of QPPD beneficiaries; an anticipated CPPD/QPPD cross-adjudication study by QPPD adjudicators; and a statistical/economic analysis of program data to examine the factors affecting participation and the effectiveness of program administration.

⁴² By this is meant a methodology that would collect the file-process data in course of adjudication, rather than as a historical reconstruction. It was judged that a historical reconstruction would have led to incomplete or missing information on which to base a re-creation of the adjudication decision. The notion of a prospective file review is discussed in Section 4 of this report.

⁴³ Historical Development of the Canada Pension Plan, 1966-1991: Twenty-Five Years of Service to Canadians (draft, no date), and the several previous evaluations of CPPD. As well, a variety of other studies have provided important data, such as the 1991 Health and Activities Limitation Survey (HALS), conducted by Statistics Canada.

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