“Though we represent different disabilities and diverse approaches to
supporting children, youth, and families, we are in broad agreement on
what we believe are shortcomings in MCFD’s process and proposed plan
for Family Connection Hubs.”

Thirty-four organizations supporting families across disabilities from around the province have united for a letter to MCFD Minister Mitzi Dean. The letter expresses shared concerns about the proposed framework for Children and Youth with Support Needs (CYSN) services, including the lack community consultation and transparency, issues with needs-assessment tools, insufficient levels of qualified service providers, and the loss of family autonomy to choose the services their children receive. 

Download this letter as a PDF

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December 3, 2021

Honourable Mitzi Dean
Ministry of Children & Family Development
PO Box 9724 Stn. Prov Govt
Victoria, BC V8W 9S2­­

RE: MCFD System Changes for Children and Youth with Disabilities

Dear Minister Dean,

We (the undersigned) cumulatively represent 34 BC-based organizations, as well as clinicians, researchers, and businesses with hundreds of years of combined experience supporting tens of thousands of children and youth with disabilities and complex needs. We are jointly writing this letter to express our concerns with the Ministry of Children and Family Development’s (MCFD) sudden decision to transform the existing support network for children and youth with disabilities to a system of generalist hubs while simultaneously eliminating individualized funding.

As a group, we are certainly pleased to hear that MCFD is committed to ensuring all children will finally have equitable access to disability supports and services—including those who live outside major population centres—and that this support will be available with or without a diagnosis. Collectively, we agree that the current system is in dire need of change, particularly when it comes to ensuring equitable and adequate funding for all neurodivergent and disabled children. There are currently far too many underserved individuals, families, and communities throughout BC. We share MCFD’s ambition to reach these populations with essential services that are necessary for all children, youth, and families in this province to thrive. 

Though we represent different disabilities and diverse approaches to supporting children, youth, and families, we are in broad agreement on what we believe are shortcomings in MCFD’s process and proposed plan for Family Connection Hubs.

There has been an acute lack of meaningful engagement and collaboration with our community regarding changes to the Children and Youth with Support Needs (CYSN) Framework. Although MCFD claims to have conducted consultations prior to announcing the new system, none of our organizations were invited to or included in these discussions in any meaningful way, if at all. The announcement of these major funding changes has caught the majority of BC’s disability community by surprise, as the recent statement from the Representative for Children and Youth also describes. As you know, the First Nations Leadership Council does not support the changes you have announced, nor the process you have undertaken. Consultation with Indigenous leaders and communities is necessary to reconciliation given the disproportionately high rates of Indigenous children and teens in MCFD’s foster care system.

There continues to be a lack of transparency about the changes to the CYSN Framework. The initial announcement included big promises but few details. Subsequent information releases have failed to reveal further insight into how the hubs will provide more support compared to the current system. Like Dr. Jennifer Charlesworth, we are especially concerned with the lack of clear plans to significantly increase funding or increase the number of service providers within the proposed hub model. Since the funding change announcement, all of our organizations have been inundated with questions from concerned parents and community members–questions that we can’t answer due to the scarcity of information from MCFD. Unfortunately, this lack of transparency and clarity continues even after information sessions were held this week for families, service providers, and sector partners.

Changes to the CYSN Framework should be guided by principles such as flexibility, choice, equity, access, cultural safety, trauma-informed practices, empowerment, and dignity. As disability organizations, we know from experience how vital it is for families to have agency and autonomy over the services their children receive and the supports they need. These benefits are a critical element that is missing from the proposed plan. For this reason, a hybrid model would better meet families’ diverse circumstances by allowing a variety of ways to access services, funding, and support, avoid disruption of already established supports and minimize the need to jump through unnecessary hoops or seek additional diagnoses. Rather than minimizing the role of diagnosis, waitlists for diagnostic assessment must be shortened to a maximum of three months and efficiencies in the public assessment system must be created. Additionally, eligibility must be streamlined for all disabilities, ensuring all children receive time-sensitive early intervention supports during their most critical years of development, even while waiting for a diagnosis. Families shouldn’t have to prove that they deserve financial, social, and political support for their disability-related needs, nor should they have to continuously prove need or eligibility when their disability is genetic or lifelong.

There is also much concern about the proposed needs-assessment tools. More robust consultation needs to be done to ensure that the tools being used to assess needs will not cause harm or exclude children and families from supports and services they need. We feel that assessors should not serve as gatekeepers but instead open the door to exceptional support for all children and youth who need it. We are concerned the hubs will not accomplish the latter.

Supporting all children will require accurate data on the number of children and youth that require supports. The province has not shared a true reflection of the population that will be served. While the government speaks of serving an additional 8,300 children, we know that is not an accurate number representing the need. Thus, service providers and modelling are needed to understand the full extent of this gap today and in the future.

Currently, there are not even enough service providers to meet the needs of all children and youth currently accessing CYSN services. We need more pediatricians, speech-language pathologists, occupational therapists, physical therapists, psychologists, behaviour analysts, and other support professionals who work directly with children with disabilities throughout the province. Without more of these essential professionals and access to services, especially in rural communities, supports will remain constrained with or without a hub system. Service providers with unique expertise in a specific disability or support need represent one of the province’s most valuable assets. These specialists have the knowledge and experience to offer targeted, individualized support that cannot be matched by a hub that caters to all disabilities. Families are deeply concerned that they will receive generic services at a hub that lack this depth of knowledge about their child’s specific disability. We also can’t assume that all service providers will be culturally safe for all children, youth, and families. Families must have the option to choose service providers to build on strengths and prevent harm and trauma. This may require them to be at arms-length from MCFD.

As concerned stakeholders, we share the objectives that the proposed MCFD plan intends to achieve, especially in terms of supporting families that are underfunded or completely without government funding. We particularly welcome the objective of guaranteeing support for those without a diagnosis. Therefore, a hub system may be an appropriate complement in creating a hybrid system that maintains individualized funding for the families for whom it’s already working and expands this option to include all families as a choice. To this end, MCFD must invest substantially more funding into the CYSN Framework to meet the needs of all children and youth with support needs and to avoid reproducing the pitfalls of the Ontario model, in which 50,000 children await access to promised needs-based supports.

We call on MCFD to immediately extend more funding to all children with disabilities, with or without a diagnosis. A failure to do so will continue to push unfunded families beyond their breaking points.

We also call on MCFD to immediately engage and collaborate with the undersigned in the restructuring and decision-making process of the proposed service system. 

Respectfully,

Cc: Hon. John Horgan, Premier and President of the Executive Council, and MLA for Juan de Fuca: [email protected] & [email protected]

Ms. Allison Bond, Deputy Minister, MCFD: [email protected]

Ms. Shirley Bond, MLA for Prince George-Valemount, BC Liberal Party Interim Leader and Official Opposition critic for Seniors Services and Long-Term Care, and Health: [email protected]

Ms. Karin Kirkpatrick, MLA for West Vancouver-Capilano and Official Opposition critic for Children, Family Development, and Childcare: [email protected] 

Mr. Trevor Halford, MLA for Surrey-White Rock and Official Opposition critic for Mental Health and Additions: [email protected]

Ms. Sonia Furstenau, MLA for Cowichan Valley, Leader of the BC Green Party and House Leader: [email protected]

Ms. Stephanie Cadieux, MLA for Surrey South and Official Opposition critic for Gender, Equity, Accessibility, and Inclusion: [email protected]

Ms. Jackie Tegart, MLA Fraser-Nicola Opposition critic for Education: [email protected]

Mr. Dan Davies, MLA Peace River North, and critic for Social Development & Poverty Reduction: [email protected]

Ms. Teresa Wat, MLA for Richmond Centre and a former member of the Select Standing Committee on Children and Youth: [email protected]

Ms. Melanie Mark, MLA for Mount Pleasant and Minister of Tourism, Arts, Culture and Sport: [email protected]

Ms. Brenda Bailey, MLA for Vancouver-False Creek and Parliamentary Secretary for Technology and Innovation: [email protected]

Mr. David Eby, MLA for Vancouver-Point Grey, Minister Responsible for Housing, and Attorney General: [email protected]

Mr. Ravi Kahlon, MLA for Delta North and Minister of Jobs, Economic Recovery, and Innovation: [email protected]

Ms. Selina Robinson, MLA for Coquitlam-Maillardville and Minister of Finance: [email protected]

Mr. Nicholas Simons, MLA for Powell River-Sunshine Coast and Minister of Social Development and Poverty Reduction: [email protected]

Ms. Anne Kang, MLA for Burnaby-Deer Lake and Minister of Advanced Education and Skills Training: [email protected]

Mr. Mike Farnworth, MLA for Port Coquitlam, Minister of Public Safety, Solicitor General, and Deputy Premier: [email protected]

Murray Rankin, MLA Oak Bay-Gordon Head and Minister of Indigenous Relations and Reconciliation: [email protected]

A Statement from Deborah Pugh, ACT’s Executive Director

I have been asked a number of times just what happened at the Minister’s Advisory Council on Children and Youth with Support Needs set up in the Spring of 2021 by MCFD Minister Mitzi Dean. Having signed a non-disclosure agreement, I am not free to provide details. However, I can share my critique of the process which led me to resign in July 2021. [Read my resignation letter]

My expectations of the Council were never high, shaped by 25 years of participating in MCFD’s community consultations in my capacity as a parent, as ACT’s Executive Director and now as the grandmother of a child with a genetic condition. However, I am observing a new low, in terms of MCFD’s willingness to listen to families. The previous Liberal government virtually ignored the needs of children with disabilities and their families, haphazardly and stealthily cutting funding and programs to meet their budgetary goals. In contrast, the NDP government appears determined to dictate to families a whole new system based on “Family Hubs”. Their process negates the diversity of family and child needs and the complexity of system change. This process is being promoted as “‘consultation” but MCFD’s tight control of meetings using Zoom technology, yet another consequence of the pandemic, smacks of a rubber stamp.

In the MCFD session held on November 29th, for example, parents were not permitted to see each other or share comments via the chat in response to what was largely a lecture by MCFD representatives. One parent described the process to me as “putrid”. This degree of control appears to be key to MCFD’s effort to repair the damage done to the tattered reputation of the long promised ‘Framework for Children and Youth with Support Needs’. The rallies, avalanche of protest letters, and the 21,000 signatures now added to the petition presented to the legislature on November 24th, have clearly spooked the government which appears totally unprepared for the degree of outrage their “framework” has ignited.

As Rob Shaw explains in his brilliant analysis, Consultatio post facto, “The NDP has adopted a bad habit of going through the motions of consulting, only to plow ahead regardless of objection or concern.” Shaw points to the searing letter from the First Nation’s Leadership Council which echoes sentiments from across the BC disability community that “Inviting us to your town halls, after you have made your unilateral decision – a decision that is inconsistent with the UN Declaration and not based on any UN Declaration analysis – demonstrated how disastrously off-course your approach is”.

The current consultations can be seen as the third stage of MCFD’s deeply flawed process. The first was in 2019 when families explained in a series of meetings how their children were being denied therapy to address their disabilities and families were struggling without respite. Many expressed that the current system is not working. An overview of the concerns can be seen here. The assumption that all families want and need the same supports is reflected in the final statement: “Families regard a one-stop, hub infrastructure as ideal.” Given the current level of protest, that is clearly an inaccurate statement. 

The second phase of MCFD efforts to create a community consultation ‘paper trail’ followed the first year of the pandemic in Spring 2021. Throughout the pandemic, MCFD’s senior staff and former Minister Katrine Conroy were harshly criticized for their failure to support families dependent on CYSN services, as revealed by researchers from Simon Fraser University. Following the re-election of the NDP government with a majority, Mitzi Dean was appointed as the new MCFD Minister. Ms. Dean, whose background includes being a child protection social worker, quickly moved to create the Minister’s Advisory Council on Children and Youth with Support Needs. The Council members were a group of committed not-for-profit leaders and parents of children with a range of disabilities who struggled to provide a reality check to government.

Beginning in May 2021, I was a member of the Minister’s Advisory Council. Minister Dean attended, backed by a large number of MCFD staffers – few of whom had clinical understanding of children who needed therapeutic/medical supports. MCFD representatives smiled a lot but none of the serious concerns raised penetrated the shell of their conviction that ‘Hubs’ would be the magic bullet for all families and children. It felt like we were listening to an exercise in magical thinking as opposed to a well developed plan of action. I remain frightened at the chaos that this plan, if implemented, will trigger.

In July, I resigned, after a number of sessions in which we received no information on budgets or staffing for these ‘hubs’, despite persistent questions. Cancelling the autism funding programs was never mentioned but as no new funding had been committed, it was obviously central to the plan. Ethically, I could not lend legitimacy to the process by remaining on the Council. I wrote a second letter to Minister Dean on August 9, 2021, again raising concerns and calling for “ethical equity, otherwise the push will be on to remove responsibility for providing therapy to children from MCFD.”

MCFD’s continuing unwillingness to heed warnings from ACT and from many others, demonstrates how resistant senior bureaucrats within MCFD are to the concerns of families struggling to protect their children with disabilities. This has been evident throughout the pandemic. This is a ministry, and a minister, which see families of children with disabilities through the lens of child protection. Even frontline CYSN social workers with expertise in the complexities of providing therapy and support to families of children with disabilities are ignored.  Few are left in the higher echelons of the Ministry with this expertise. I don’t think MCFD expected this degree of opposition because they don’t understand the implications of what they are proposing. 

Clearly senior bureaucrats, like Deputy Minister Allison Bond, believe they can force a new system on families of children with disabilities. It is ACT’s view that it is time to move families of children with disabilities out of the Ministry of Children and Family Development and to provide CYSN with an expanded stand-alone budget, that is fully funded with cross party support to guard against inflation. Our children deserve no less.

“While a long-term plan is admirable, action is needed now. We believe a fully resourced, short-term strategy by MCFD is required to solve lengthy wait lists for assessments, respite and services until the new system is fully functional.“

The Representative of Children and Youth, Dr. Jennifer Charlesworth, has released a statement addressing the new Ministry of Children and Family Development (MCFD) framework for its Children and Youth with Support Needs (CYSN) program. See the full statement from the Rep below.

Download this letter as a PDF

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Nov. 24, 2021
For Immediate Release

Since the Ministry of Children and Family Development (MCFD) announced long-term plans to fundamentally
change its Children and Youth with Support Needs (CYSN) program, many parents, volunteers and others
who work with children and families have expressed serious concerns about those changes. Sadly, the
announcement has resulted in uncertainty, fear, anxiety and stress for many families, particularly for those
whose children have autism.

At the same time, the announcement was greeted with cautious enthusiasm by other families who saw a
glimmer of hope that they might finally be able to access much-needed supports and care for their children.
Now they, too, are fearful that their children’s needs might not be met if the new CYSN framework is
abandoned, and some have been criticized and shamed on social media as they expressed hope that their
children would finally get supports.

It is time to take a step back to address the uncertainty and fears and ensure clear information is available to
families and advocates, while not losing sight of the need to build a much better system of care for CYSN.
As B.C.’s Representative for Children and Youth, I have long been calling for a fundamental shift in the CYSN
system. Like many others, I have questions and concerns about the framework as announced on Oct. 27.
However, I also see within MCFD’s plan the potential for much-needed and long overdue improvements. In
this regard, I am in favour of the long-term direction as laid out by Minister Mitzi Dean.

In particular, I support the shift towards a needs-based rather than a diagnostically driven CYSN system. This
shift will enable children to receive timely supports based on assessed developmental needs even before
they receive a diagnosis – which currently can take many years. I also support the intention to enhance
community-based access to a diverse array of care and supports, from infancy through to young adulthood.
The minister described the current CYSN system as “patchwork” and said that it leaves too many children on
the outside without services. I couldn’t agree more and, therefore, long-term improvements are absolutely
necessary.

In my three years as Representative, I have released three reports that illuminate the weaknesses in the
current CYSN system. These challenges include lengthy and growing wait lists for assessments and diagnoses,
lack of access to assessments and quality care in many communities, lack of timely developmental supports
to enable young people to thrive, lack of wrap-around support and resources for families who are
endeavouring to meet the exceptional needs of their children, discriminatory screening and referral patterns,
and inequity in services provided depending on a child’s diagnosis.

Through thousands of RCY advocacy cases and reports of critical injuries and deaths, as well as through deep
engagement with young people, families and community partners, we see the extent of the weaknesses in
the current system. While some current CYSN services might be adequate for some children, youth and
families, we know the system as it exists today does not work at all for many. It does not work for children
with fetal alcohol spectrum disorder, with undiagnosed neuro-cognitive developmental disorders, with
complex medical needs or with complex developmental and behavioural concerns. It also does not work well
for many children with autism and their families and caregivers, as we described in our 2018 report entitled
Alone and Afraid.

If we as a society are going to meet the call of Article 23 of the UN Convention on the Rights of the Child,
which speaks to the rights of all children and youth with special needs to access care and support and live a
life of dignity, belonging and connection, then the current system needs to be transformed.

Despite the concerns about the CYSN framework announcement that have been raised during the past few
weeks, I trust that we can all agree on some basic facts and principles: The current CYSN system does not
work for many children with support needs and their families and must be transformed. All children and
youth with support needs deserve access to equitable, timely, culturally attuned and community-based care,
resources and supports. Families, young people, caregivers and service providers need to be meaningfully
engaged in the design and development of a transformed system of care. And, finally, a transformed CYSN
system that works for all children will require significant government investment.

While I support the long-term direction of the CYSN framework, I also share many of the concerns expressed
by families and those in the sector and have a number of questions about the announcement that require
answers in order to ensure that children and families who need support are provided with the confidence
that they will receive it – both now and into the future.

MCFD’s plan is long-term and does nothing to help children and families who are struggling right now. As my
Office documented in our report Left Out last December, many of these children and families are in crisis and
a plan that won’t be fully rolled out for at least 3 ½ years is not enough. The Community Partners we worked
with on that report tell us that things are even worse for the families they serve now, nearly a year after the
Left Out report.
While a long-term plan is admirable, action is needed now. We believe a fully resourced, short-term strategy
by MCFD is required to solve lengthy wait lists for assessments, respite and services until the new system is
fully functional.

Aside from an urgency to address current needs, I am concerned that there has been no indication that
increased resources are on the horizon, which will be critical if the system is to serve more children and
families and do it faster and more effectively. MCFD says its plan will expand services to 8,300 additional
children across B.C. but the ministry does not have the resources to properly serve the children currently on
its caseload.

After three recent RCY reports and one by the Select Standing Committee on Children and Youth that
addressed shortfalls in the current CYSN system, I am pleased to finally be seeing a plan for change. But how
will even more families be served without more money and resources being put into a system that is already
very under-resourced? A commitment to significantly enhance investments will go a long way towards easing
the understandable concerns that there will be a watering down or elimination of services and supports,
particularly for those receiving autism funding, in order to serve more children with the same funding.

I have other questions about the MCFD plan, including how the proposed service hubs will be rolled out, and
how they will serve families who do not live in a hub community as well as hard-to-serve families? And how
will this plan support Indigenous communities to either develop their own robust array of supports or ensure
that they are well-served and have access to culturally attuned and safer supports within community hubs?
Autism advocates and parents, quite understandably, are concerned that a move away from individualized
funding will erode services that they rely upon. Meanwhile, advocates and parents of children with other
support needs argue, quite understandably, that their children deserve equity when it comes to supports and
services provided by government. Better and ongoing communication and engagement by MCFD with
parents and advocates of all children with support needs is needed to ease those concerns.

Having said that, I reiterate that changes to the current CYSN system are necessary. I urge government to
offer short-term help to struggling children and families while its long-term strategy is rolled out. I also urge
government to fully engage with parents and advocacy organizations of all children with support needs to
ensure that the long-term result is a revamped system that is well-resourced and that works for everyone.

Sincerely,
Dr. Jennifer Charlesworth
Representative for Children and Youth