We have reviewed a number of federal housing policies and programs and have discovered several systemic inequalities which increase the risk of homelessness among low income women, particularly women with children. The abandonment of funding for new social housing in 1993 and the increasing reliance on the private market supply has been particularly detrimental at a time when there is widespread discrimination in the private market against low income women with children, lower vacancy rates and rising rents. New private market units have been largely restricted to condominiums, many in "adult lifestyle" communities which are rarely rented to single mothers. New funding recently proposed by the federal government to generate rental supply seems ill designed for women's needs. It will likely do little to alleviate the scarcity of larger units needed by women with children and there do not appear to be any requirements that housing supply will remain affordable or will be rented without discriminatory restrictions affecting low income women.

Important concerns for women have emerged about trends in existing subsidized housing programs. $2 billion a year is spent by the federal government to provide subsidy to lower income households in subsidized units, but women-led households face many barriers accessing this all-important source of assistance. Because the subsidy is linked to particular units, and because most subsidized housing providers now allocate units on the basis of lengthy waiting lists rather than on the basis of need, those women most at risk of homelessness are largely denied any benefit of federally funded housing subsidies.

Additional concerns relate to discriminatory practices which exist in both non-profit and private housing. There are rarely internal policies and procedures requiring social housing providers to address discrimination in tenant selection, even when these decisions affect both access to housing and access to much needed subsidy.

In the area of homeownership, we have seen that federal programs promoting access to affordable home ownership and renovation and repair of owned homes are not of equal benefit to women because of discriminatory policies maintained by CMHC, disqualifying the majority of single mothers and low income women from homeownership on the basis of the 32% "gross debt service to income ratio". Under this policy, the vast majority of women are denied access to homeownership on the basis of their income, even if they are paying more in rent than would be required by mortgage and property tax payments.

Of equal importance and related to federal housing programs, however, are income support programs and policies. Women's homelessness is almost always related to vulnerability and disadvantage with respect to income. Recent federal program changes have had an immense effect on women's income security, and on whether they have enough money to pay the rent or mortgage payments. Of particular importance are federal programs and initiatives in three areas: social assistance, tax credits designed to address "child poverty" and employment insurance.

Part III of this report provides an overview of federal involvement in income support through funding for social assistance programs, the National Child Benefit Supplement and employment insurance and assesses the impact of these changes and program designs on women's homelessness.

The cornerstone of income and housing security for women is the provision of financial assistance, for persons in need, sufficient to cover housing costs.

In 1997 women accounted for 56% of all Canadians living below the Low Income Cut-Offs (LICO's) and almost 20% of the total female population in Canada (2.8 million women) were living below the LICO's. In 1996, there were close to one million (945,000) female-headed lone-parent families in Canada who have by far the lowest incomes of all family types. 56% of these families, or over half a million single mothers, had incomes which fell below the LICO's.

These statistics are worse when viewed in light of intersecting disadvantage. For example:

• In 1996 a startling 73% of Aboriginal single mothers lived below the LICO's.
• In 1997 approximately 50% of unattached women 65 and older lived below the LICO's.
• In 1996 nearly 50% of newcomer women (who immigrated to Canada between 1991-1996) were living in low income situations.
• According to a 1998 study, 60% of women with disabilities were either partially or wholly dependent on the welfare system for basic daily needs.
• In 1995, 43% of visible minority women under the age of 15 and 41% of those between 15 and 24 were living in low income situations, this compares to 20% of non-visible minority women under the age of 15 and 24% of those aged 15-24 who were living in low income situations.

Women are vulnerable to poverty because they remain primarily responsible for unpaid caregiving for children and older, sick or disabled family members, because of gender inequalities in the distribution of income, as well as biases based on race, sex, age, place of origin, and ability in labour markets and economic and political institutions. As a result, women, particularly Aboriginal women, young women, women with disabilities and recent immigrants, disproportionately rely on social assistance and are particularly affected by the adequacy of social assistance programs.

The most critical protection of women's right to adequate housing for a generation of women was the Canada Assistance Plan Act. In 1966, CAP established 50-50 cost sharing agreements between the federal and provincial governments for social assistance and related services programs. Under CAP provinces which received federal funding for social assistance programs were required to meet national standards. The standards under CAP were as follows: 1) no work requirement to receive assistance; 2) assistance to be "needs" based; 3) to provide an amount that takes into account the cost of basic requirements, including food, shelter, clothing, fuel, utilities, household supplies and personal requirements; 4) no residency requirements, and 5) the right to appeal. The CAP agreement provided that if a province did not comply with all of these requirements, the federal government could withhold funding. Alternatively, an affected individual or group could go to court for a determination as to whether the province was providing assistance "in an amount that is compatible, or consistent, with an individual's basic requirements" If found to be non-compliant, the court could order that the federal cost-sharing be withheld until compliance was achieved.

The repeal of CAP was legislated by the Budget Implementation Act, 1995. On April 1, 1996, the Established Programs Financing (EPF) and CAP were replaced by the Canada Health and Social Transfer (CHST). Transfer payments under the CHST to the provinces and territories are now provided as a lump-sum and not designated specifically for health, post secondary education and social assistance and accompanying services. The introduction of the CHST has resulted in the elimination of four of the five standards under CAP. The only remaining feature is the requirement that there be no residency restriction. There is no requirement that rates be adequate to cover the cost of housing.

The revocation of CAP and the introduction of the CHST has exacerbated women's poverty as it has allowed for the tightening of eligibility criteria for social assistance and the erosion of social assistance rates across Canada. While there were problems with inadequate rates prior to CAP being revoked, it is clear that provincial governments have felt free, perhaps even encouraged, to forego the requirement that social assistance rates take into account the cost of housing and other requirements. Scarce dollars have been redirected to health funding, where national standards remain in place, while social assistance rates have become more inadequate to cover the cost of housing.

To understand the significance of these changes to CAP on the housing and living conditions of low income women, the following chart compares changes to social assistance rates and shelter benefits between 1994 and 2000 with changes in average rents during the same period of time. While some may argue that women on social assistance should be able to pay less than average rents, studies of single mothers who move have actually shown that the majority must pay significantly more than average rents. Widespread discrimination forces them into the most over-priced units on the market and as we have seen their access to subsidized units is extremely limited.

In these six years the cost of rental housing has gone up by varying amounts in Canada's urban centers. The average rent for a two bedroom apartment has increased by 4% in Montreal, 5% in Halifax, 16% in Vancouver and 32% in Toronto. What is more significant in terms of affordability, however, is that social assistance recipients' income have failed to keep pace with increased costs and in some provinces have been significantly reduced. Total income for single mothers relying on social assistance has decreased by 11% in Halifax, and by 1% in Montreal, increased by 3% in Vancouver and decreased by 18% in Toronto. The critical determinant of homelessness - the amount left over after paying rent - has decreased by 13% in Vancouver, by 69% in Toronto, by 5% in Montreal and by 22% in Halifax. To have simply kept pace with inflation, this amount should have increased by 15% over this period of time.

The impact of the repeal of CAP and the erosion of social assistance entitlements on women's homelessness is further reflected in the increased numbers of low-income women using food banks and shelters, the increases in evictions because of arrears and the experiences of disabled women with respect to homecare:

Securing income equality for women across Canada is an ambitious goal that will require a number of different types of strategies to be pursued simultaneously. CERA offers the following two legal strategies to complement efforts to reach this goal.

1) The loss of legally enforceable standards in social assistance allowed unprecedented erosion of income adequacy for women in Canada - particularly for single mothers, women with disabilities, Aboriginal women and racialized women. These changes have been condemned by two United Nations Committees as violations of international human rights law because of their discriminatory consequences for women's access to adequate housing.

Despite the dramatic rise in homelessness among women and the strongly worded concerns of United Nations Committees, nothing has been done to reinstate enforceable standards with respect to social assistance. During the review of the Social Union Framework Agreement women should press the federal and provincial governments to include an enforceable right to adequate financial assistance in a renewed agreement.

2) Women have turned to the Charter of Rights and Freedoms and to human rights legislation as alternative sources for enforcement of the right to an adequate standard of living. A critical case was heard on this issue by the Supreme Court of Canada on October, 29, 2001. This type of litigation must continue to be initiated.

Support for including the right to an adequate standard of living, including adequate food, clothing and housing, in a revised Canadian Human Rights Act, was virtually unanimous among women's and other equality seeking groups across Canada when the Canadian Human Rights Review Task Force held consultations on the Canadian Human Rights Act in 2000. Though this recommendation was not included in the Task Force report, women's groups could lobby the federal government directly on this issue.

The primary initiative undertaken by the federal government in recent years to address poverty was the introduction in 1997 of the National Child Benefit Supplement (NCBS) as an additional tax credit for some low income families. This benefit was added onto existing child benefits, which were incorporated into the new National Child Benefit (NCB).

The NCB has two components - the base or basic benefit and the Supplement. The Canada Child Tax Credit, or basic benefit, combined the previous baby bonus and child tax credit and did not provide any additional benefit to families over what they previously received. The Supplement constitutes additional funds which, according to the federal government, are allocated to address the "welfare wall" phenomenon. The term "welfare wall" refers to the concept that employment related expenses, increased income tax, and Canada/Quebec Pension Plan contributions, for example, hinder low income people from moving off welfare and into the labour market.

The maximum basic benefit is available to families whose net income is below $32,000. Until June 2002, the maximum basic benefit is $1,117 per year ($93.08 per month) for first and second children who are under 18 years of age. This amount increases incrementally based on the numbers and ages of children in the family. There is also an additional supplement of $221/year or $18.41/month provided for each child who is less than 7 years of age for whom no child care expenses were claimed.

On top of this, some low income families are eligible for the National Child Benefit Supplement of $1,255 per year ($104.58 per month) for the first child; $1,055 per year ($87.91 per month) for the second child; and $980 per year ($81.66 per month) for each additional child.

The above amounts incorporate changes which took effect in July 2001. At that time, the Supplement was increased from the previous year by a substantial 28.4% whereas the basic benefit was increased by a mere 1.2%, not even keeping up with the cost of living. As a result, for the first time since the inception of the NCB, the amount of the Supplement exceeds the amount of the base benefit.

Though the NCB is administered through the tax system (individuals must file a tax return to apply), according to the federal government it is more fundamentally an anti-poverty program, not a tax provision, and while it is a federal tax provision, it was designed as a joint initiative with provincial and territorial governments.

The NCB has three stated objectives:

All three of these objectives are directly related to women's housing and homelessness. Child poverty is almost always linked to women's poverty and a major determinant of women's / child's poverty is the relation between housing costs and income. Surely, an essential component of ensuring that families are better off working than when on social assistance is to address the fact that in many provinces, a variable shelter allowance adjusted to housing costs and family size is only available when a family is on social assistance. And harmonizing benefits, one would think, should involve integrating housing subsidies with social assistance shelter allowances and assistance to working families. Despite these connections, with its emphasis on changing the labour market behaviour of parents, the Supplement completely ignores the issue of housing costs, the need for shelter allowances for low income working families and the need to harmonize housing subsidies with other forms of income support. There is no consideration of housing costs in a determination of eligibility for the Supplement or amount of the benefit and there has been no attempt to target the benefit to those in deepest poverty or at highest risk of homelessness.

The distinctive feature of the Supplement in comparison to the basic benefit is that by agreement with the provinces and territories, the Supplement may be "clawed back" from social assistance recipients. In all provinces and territories, except New Brunswick, Newfoundland and Manitoba, the Supplement is clawed back from social assistance recipients. What is most offensive to low income women about the NCBS in the remaining provinces is that a benefit designed to ameliorate child poverty is clawed back from the poorest women and children simply because they are recipients of social assistance. The result is that the majority of single mothers, who are most in need of the benefit, are denied it. This exclusion, of course, has a significant impact on women's homelessness.

In a 1998 report by the National Council of Welfare entitled, Child Benefits: Kids Are Still Hungry, it was estimated that of the one million plus lone parent families in Canada, only 17% would keep the Supplement, as compared to 59% of two-parent families who would keep it. The rest of the lone parent families - 83% - would not benefit from the Supplement at all. In 1997 single mothers comprised 67% of families in receipt of social assistance (388,426) whereas single fathers comprised only 6.4% (37,374) and couples with children comprised 26.6% (157,675). The clawback was thus largely a clawback from single mothers. Despite the fact that women on social assistance may be most in need of this benefit and most unable to pay for housing and related expenses they are excluded from the federal government's only initiative to address child (family) poverty.

While the Supplement clawback may appear to be a strictly provincial and territorial policy, it was in fact by agreement with the federal government that provinces and territories claw back the tax credit provided to families on social assistance. The Building a Better Future for Canadian Children paper provides the only public record of this agreement. Under the section on 'How the National Child Benefit will Work', the paper notes that:

The clawbacks have resulted in significant savings for provinces and territories. For the 1999-2000 fiscal year, reinvestments across provinces and territories totaled an estimated $484 million. While the agreement was that these savings are to be reinvested in community programs and services, as time goes by the distinction between "reinvestment" and simply using these funds to pay for other programs becomes increasingly blurred. There is no evidence that families in the provinces that claw back the benefit from social assistance receive improved programs because of the clawback.

In the end, the Supplement is more about a discriminatory denial of a necessary benefit to single mothers than it is about addressing the difficulties of the transition to work. The following examples demonstrate the kinds of disparities that result from the discriminatory nature of the agreement and the way in which these disparities have a direct impact on single mothers' risk of homelessness.

Maria, a young single mother with two children, a boy aged 4 and a girl aged 6, lives in a run down two bedroom apartment in Toronto. She pays $850/month in rent. Maria is in receipt of social assistance and does not have paid employment. Like all families in receipt of social assistance, every month she receives a cheque from the federal government for the NCB base amount and the Supplement. She also receives a monthly welfare cheque which is reduced by the amount of the NCB Supplement. Her total income less her rent, leaves Maria with $459 at the end of the month for all expenses for her and her two children, including heating costs, food, phone and all other necessities.

Maria's friend Anthea rents a 2 bedroom apartment in the same building at the same rent and has 2 children the same age. She has subsidized childcare. She has worked full time at a doughnut chain for over two years earning just more than minimum wage. Her income is $10,920 a year or $910 per month. Anthea is eligible for a monthly top-up to her wages of close to $500 from social assistance but the NCB Supplement is clawed back from this amount, so she only receives a monthly top-up of just over $300. Anthea is not entitled to the NCB additional supplement for children under 7 because she claimed her child care expenses when she filed her taxes. As a result, her total monthly income is almost $1,600. After paying rent, Anthea has just under $750 to cover all of her expenses associated with working including transportation to daycare and to work as well as basic, everyday necessities for her and her two children.

Across the street, Geoff and Lori-Anne also have two children, a boy aged 4 and a girl aged 6. They live in a three bedroom townhouse in a co-op. The market rent of $1250/month is reduced by a substantial subsidy ($545 a month) to $705/month. Geoff is a part-time municipal worker and has a net yearly income of $24,000 or $2000 a month. Lori-Anne does not work outside the home. Because Geoff is in paid employment they are entitled to the NCB Supplement. Because they have not claimed child care expenses for tax purposes, they are entitled to receive the NCB additional supplement for children under 7. In turn, Geoff and Lori-Anne have $1,630.70 left over after paying their housing charge every month.

The disparities between these scenarios widens further when considered in light of available assets. To qualify for social assistance Maria and Anthea would both have to exhaust virtually all of their assets. That is, to be eligible for social assistance Maria would have to deplete any assets, such as savings in a bank account, bonds, or RESPs/RRSPs, to a maximum value of $1,957. Similarly, once in receipt of social assistance Maria's and Anthea's assets could not increase beyond the maximum limit. Geoff and Lori-Anne, on the other hand, are able to retain their assets. So, not only might Geoff and Lori- Anne have an adequate monthly income after paying rent, they may also have a substantial financial cushion upon which they could rely in the event of a crisis or need.

The discriminatory aspects of the Supplement clawback go beyond the financial components as well. The agreement reinforces a prevailing trend in federal social policy of obscuring or ignoring the realities of women's poverty and homelessness and focusing on protecting their children from the potential "damage" inflicted by poverty. It has become an imperative to refer to "child poverty" rather than "women's poverty". The disassociation of child poverty from the poverty experienced by their mothers reinforces negative stereotypes of single mothers and obscures systemic inequalities in society which deprive single mothers of the resources necessary to feed, clothe and house themselves and their children.

This is not to say, however, that there are not important concerns to address in the situations of women on social assistance making the transition to paid work. Women with children frequently find that the loss of a shelter allowance geared to family size, of drug and dental coverage, winter clothing allowance, community start-up allowance and other benefits which are adjusted to family size (and which are available through social assistance), combined with the additional costs of transportation and childcare, make this transition financially difficult and may jeopardize their ability to pay for housing. However, rather than acknowledging the complexities of these issues and designing a benefit that is sensitive to the financial realities which increasingly place women and their children at risk of homelessness, the NCBS agreement adopts a crude division between those on social assistance and those who are not. The result is that many women in dire poverty, and at serious risk of homelessness, are denied a benefit which could make the difference between paying the rent or facing eviction and homelessness.

An obvious solution to the discriminatory aspect of the NCBS is to eliminate the clawback in all provinces and territories where it is currently clawed back. In fact, campaigns to this effect have been launched at various times across the country, for example, the Ontario New Democratic Party currently has such a campaign. In October 2001, the NDP Community and Social Services Critic, Tony Martin, brought a petition with over 7,000 signatures to the legislature demanding the Ontario government stop clawing back the Supplement.

There are, of course, potential difficulties with such a solution as it may jeopardize the availability of funds to address the problems facing some women transitioning from social assistance to paid employment. However, rather than reinforcing the division between "being in receipt of social assistance" and "working" and excluding social assistance recipients from the benefit of a much needed child poverty initiative, new benefit programs must be designed to address the complex inter-connections of various programs and benefits to ensure the availability for working women of a shelter allowance or housing subsidy adjusted to family size and housing costs.

To complement these types of strategies, CERA recommends the initiation of Charter litigation challenging the claw back as violating the right to life, liberty and security of the person and to equality rights for single mothers in receipt of social assistance.

Surveys of renters facing eviction have found that the majority of evictions result from unexpected job loss or reduction of income. For women paying a high proportion of income toward rent, protection from unforeseen loss of employment income is thus an essential component of homelessness prevention. To the extent that the necessity for such protection has been recognized in Canada, it comes in the form of the federal Employment Insurance Act ("EI"). This Act establishes what is essentially a worker-funded program derived from premiums paid by employees and their employers to provide temporary income replacement and other income security for insured employees who become involuntarily unemployed.

The federal government's EI scheme thus links income security with attachment to the paid labour force. EI is available to meet a number of circumstances giving rise to women's loss of income security - not only job loss, but also long term disability, maternity, infant care - but it is only available to women who work. To the extent that the EI scheme contributes to protecting women from homelessness then, this protection in enjoyed only by working women. The EI scheme offers nothing to women who have not paid into the system. For these women, the only alternative is social assistance, which they cannot receive unless they have exhausted virtually all of their assets. On the one hand then, EI contributes to the realization of the broader goal of ensuring income and housing security for women. On the other hand, however, it is at best only a partial contribution. Situating EI within the broader context and objective of providing women with income and housing security illuminates the ways in which EI needs to improve to ensure that on its own terms it is really addressing the type of income loss most likely to place women at risk of homelessness.

This review of and recommendations with respect to EI is not intended to suggest that women's poverty and housing disadvantage should be exclusively addressed through EI. Rather, it is to suggest that EI must respond equally to the needs of women who are at risk of homelessness. This chapter considers the ways in which the structure and design of the current EI program disqualifies women who are most at risk of homelessness. This chapter also provides an opportunity to reflect on the broader notion of income and housing security, to consider what is most appropriately addressed through an insurance scheme linked with employment and what is more appropriately addressed through universal income programs.

Rather than refining the program to ensure that those households most vulnerable to homelessness as a result of job loss or income fluctuation are adequately protected, and receive income replacement when needed in order to meet housing costs, the federal government has reformed this insurance scheme in a very different direction. The new EI program disqualifies many of the women who are most vulnerable to homelessness by moving from a weeks worked to an hours worked entitlement system; tightening eligibility criteria for new entrants and re-entrants into the workforce and, rather than providing a supplement to those with dependents based on current income, supplement funds have been tied to eligibility for the NCB and to household income of the previous taxation year.

In January 1997, the Liberal government changed EI eligibility criteria from a "weeks worked" to an "hours worked" system. The formula now used to determine who qualifies for insurance is based on a 35 hour work week. This standard also governs the allocation of maternity benefits.

This change has a detrimental impact on part-time workers who now face a greater risk of ineligibility for benefits:

The majority of part-time workers are women:

Women work fewer hours in the paid labour force than men because they cannot obtain full-time work, and because they carry more responsibility for unpaid care-giving duties. As a result of this change to eligibility criteria, those most likely to pay a high percentage of income on rent may be in grave risk of not being able to pay their rent without EI, and are the most likely to be paying into the program without receiving any benefits.

Under the new EI system new entrants and re-entrants to the labour force face even tougher eligibility criteria to qualify for benefits. The number of hours required to qualify has been increased from 700 to 910 (from 20 weeks to 26 weeks). The result of this change in policy is to disqualify many young people and single mothers.

New and re-entrant workers represent 26% of all workers who experience job separation. Over 50% of workers who fall into this category earned less than $10.00/hour and over 75% earned less than $15.00/hour. Young people, aged 15-24, comprise over half of this category of workers and slightly more women than men fall into this category. In particular, single mothers with a youngest child between 6-10 years old, are much more likely to be re-entrants than are married mothers and fathers. The overrepresentation of young people and the propensity for single mothers to fall into this category is not surprising given that many young people will be entering the workforce for the first time, and women are more likely than men to periodically leave and re-enter the labour force to balance family and work responsibilities.

Under both the former Unemployment Insurance (UI) and current Employment Insurance systems, provisions exist for extra benefits for claimants with dependent children. Under UI it was called the "dependency rate" and under EI it is called the "family supplement".

The family supplement is designed to provide additional assistance and security to low-income families with children. Under EI the regular benefit rate is 55% of insured earnings up to a maximum of $413/week. Under the family supplement, claimants in low-income families can receive a higher percentage of their insured earnings (up to 80%) as long as their weekly benefit does not exceed the $413 maximum entitlement. To qualify for the family supplement, claimants must have at least one dependent child, have a net family income of not more than $25,921 and be in receipt of the Canada Child Tax Benefit (discussed in the previous chapter).

There are two significant changes in the switch from dependency rate to the family supplement. First, eligibility for the family supplement is based on family income whereas under UI it was based on individual earnings. This means that a woman living with a male partner who is in the labour force is considerably less likely to be entitled to the family supplement. Under UI in 1995-1996, 33.6% of women received the benefit whereas in 1997 under the new EI scheme only 13.8% of women collected the family supplement and under EI only 62.6% of supplement recipients are women, whereas under UI over 80% of recipients were women.

Under the new eligibility criteria, a higher proportion of single mothers receiving benefits are able to access the family supplement than under the previous system. This gain, however, must be viewed in light of the fact that it is very difficult for women, particularly single mothers, to qualify for EI benefits under the new system.

The second significant change is that rather than basing the supplement on earned income during qualifying weeks, the family supplement is based on eligibility for the NCB, thus on household income, from the previous taxation year. For women who have separated in the last year and who would otherwise be disqualified for the NCB because of a higher household income in the previous taxation year, there is a provision to qualify for the NCB Supplement on the basis of current income. Nevertheless, apart from this limited provision, many women who have experienced a dramatic drop in their household income and therefore are at risk of not being able to pay the rent or meet mortgage costs would likely not qualify for the family supplement because their income in the previous taxation year was too high.

A program designed to provide extra financial assistance to low income families upon job loss should be concerned to ensure that women do not lose their housing. In turn, basing entitlement to family supplement on income levels in the previous taxation year makes little sense. For the program to be of real assistance to low income families, it needs to be targeted at families who are currently low income not only those who had a low income in the previous taxation year. Moreover, many of the most vulnerable women with children are likely excluded from receiving the family supplement because they failed to file income tax in the previous year and because they did not know about the provision which allows them to claim the National Child Benefit upon separation.

As a result of these three major policy changes, women are failing to qualify for EI benefits in larger numbers then men despite the fact that their payments into the system are proportionate. In 1997 - 1998 the number of women claiming EI regular benefits decreased by just under 20% from the year prior. The changes to EI exacerbate inequities already present in women's segment of the labour force. For example, Aboriginal women, women of colour, newcomer women and women with disabilities are over-represented in the "marginal" labour force. Under the new EI system, they face increasing difficulties meeting the requirements to qualify and when they do qualify, they have to contend with lengthy waiting periods before they receive any benefits at all.

1) Employment Insurance requires a thorough overhaul to ensure that women who are vulnerable to unexpected job loss or income reduction are adequately protected so they can continue to pay their rent or make their mortgage payments. This means:

• Rather than disqualifying young women and women who are re-entering the workforce after having stayed at home caring for children, eligibility criteria should be developed that consider and accommodate women's participation in the paid and unpaid labour force, with particular attention focused on women's work patterns, young women and women re-entering the labour force after an absence;

• Ensuring eligibility for the family supplement is based on current income and housing security needs rather than on income in the last taxation year and receipt of the National Child Benefit;

• Adjusting regular benefit levels and the family supplement so as to provide the necessary protection to those who, as primary caregivers, have little flexibility to absorb a reduction of income. Benefit and supplement rates would have to take into consideration actual housing costs of EI recipients.

2) Surveys of women dealing with eviction should be undertaken to document the extent to which improved employment insurance could prevent homelessness.

3) A more efficient delivery system is required so that low income women receive their first EI cheques immediately upon application rather than having to wait between four and six weeks, or alternatively a fast track system could be developed for those in need of immediate income to meet housing costs.