Open Letter To Minister Michael Coteau Regarding Ontario Autism Services

A month ago I posted a blog about my son waiting 6 1/2 years for intensive theropy.  I filed a ministerial complaint on Kinark (the regional provider responsible for my son waiting this long) as a result.  The Minstry's response to that complaint is here.  Below is an open letter to Ontario's Minster of Child and Youth Services I've written in response to the Ministry outlining some very serious policy concerns regarding regional program providers like Kinark, and the Ministry's culture of not providing any solutions for families caught up in the middle of their new autism program.

Minister Coteau,

I received a letter from the central region of your ministry while I had expected an answer regarding my complaint against Kinark directly from your office.  Part of this complaint was to raise policy concerns to your office directly regarding the lack accountability of AIPs while your office further and directly investigated my complaint against Kinark. From the September 22nd Ministry letter underwritten by Ms. Cantkier:

"The Ministry is committed to monitoring the Autism Intervention Program (AIP to ensure that the program achieves its goals and objectives and makes efficient use of public resources).”

Had your office directly followed up on my complaint it would have discovered that the system to apply for AIP’s is deeply flawed.  My son Matthew received a diagnosis of Autism in which it was recommended that we as parents contact Kinark directly and verbally to be put on the IBI wait list only to find for years after we did just that, multiple times Kinark refused to do so.  I’ve also provided the Ministry with documentation from another family that has gone through a similar situation with Kinark.

In an electronic age, recommendations from family support network professionals to AIP programs should be done by those professionals and submitted to Kinark electronically.  I have to question even in 2010 why that wasn’t done in our case. It should be an automatic electronic process.  It should NOT be left for families to connect with AIPs verbally to apply. That should be handled on the back end, and allows the possibility of the AIP to manipulate the process, with little to no evidence of a verbal request to be put on wait lists often pitting the care givers word against the AIP.  This policy doesn’t have any common sense in this day and age whatsoever.

I don’t understand why under these circumstances the ministry is refusing to find a viable solution for my son who has been waiting 6 ½ years for IBI (while others on the wait list who have been waiting far less than my son are entitled to support now) and why the ministry hasn’t taken the initiative to work with Kinark upon my complaint to find a solution, nor properly and fully investigated which would have revealed the policy flaws outlined above that need to be corrected in order for the Ministry too fulfill the mandate to accurately monitor the AIPs ahead of the new program.

Back to the September 22nd letter, in the same paragraph the Ministry stated:

“In situations where families have concerns with transfer payment agencies, including regional autism providers, the ministry encourages families to raise their concerns directly with these organizations and follow their complaint resolution process.  This process may include the senior management, and if necessary, the board of directors to resolve differences.”

Ultimate responsibility for ensuring compliance with policy and legislation regarding transfer payments falls directly under the Minister's portfolio.  There seems to be a lack of enforcement audits by the ministry to ensure AIPs are actually monitored for compliance  to ensure AIP goals and objectives are properly met and use of public resources (such as transfer payments and administered programs) are actually reaching eligible families under these circumstances.  The fact that this Ministry didn’t do proper follow up on my family’s situation now TWICE is representative of that.  Where there is a lack of accountability and compliance audits, one could reasonably without a doubt expect abuse and manipulation of the system as a result.

Instead of this ministry periodically questioning users of this system (parents and caregivers) electronically to ensure legislative and policy enforcement of regional AIPs on a regular basis, it is the Ministry’s position from the statements provided above that compliance with legislation, mandates, and policy, is left to the AIP’s board of directors and complaint resolution officers to self-police.  I find that interesting considering it is well within the legislative scope and jurisdiction of this Ministry to ensure compliance with such upon complaint to this office.

I also find it very interesting that parents who are receiving ACSD support are subjected to compliance audits every few years, yet under the nose of this Ministry Kinark’s administration budget has ballooned yet again, while advocates list this agency as being one of the worst in Ontario regarding the treatment of eligible children and families, and providing the proper care, and following ministerial guidelines under their own mandates.  The Minister even acknowledged recently to some degree that there are problems being reported to this office regarding the conduct of AIPs, and yet I’m referred back to a complaints procedure at Kinark, when it’s this ministry who has direct oversight of this organizations compliance with ministerial guidelines.

This self-policing approach to AIPs is leaving families such as mine without services (while we qualify) at great expense to the province and tax payer.  As a result of the lack of compliance audits and self-policing of AIPs, this Ministry cannot at all guarantee that families in the new Ontario Autism Program (OAP) in June 2017 will meet any sort of mandate, while currently several parents are left battling out who said what because the first point of contact with AIPs is left to one that is verbal rather than professional electronic and traceable referrals to the program!

Politely, it is this minister's legal responsibility to follow up properly with Kinark’s board of directors to get this matter resolved since it is entirely a complaint based on mandates, policy, legislation and this agency's conduct in which the minister has direct oversight.  It should not be the job of the caregiver or parent upon complaint into the ministry to be chasing a moving target, adding to the frustration, stress, mistrust, and anxiety over a transition to the new autism program which should be seamless and transparent if the government at all was listening to parents concerns over the past few months.

Finally from the Ministry’s letter dated September 22nd 2016:

“The ministry funds a range of supports and services that may be of assistance to your family.  I suggest that you contact with Kerry’s Place Autism Services who provide ASD consultations and respite and Applied Behavior Analysis (ABA) program.  I encourage you to re-refer Matthew to the ABA program at which time service length and intensity will be determined”

Also from the September 22nd letter:

“The Ministry of Children and Youth Services is investing in ABA services to increase their capacity, intensity and length.  In 2017 the ministry will start implementing the new Ontario Autism Program that will adjust the intensity of services to correspond with the children’s needs and will offer a single access point to autism services in each region”

I’ve been in contact with Children’s Treatment Network (CTN) who diagnosed my son and referred us to Kinark for IBI.  There is currently NO community supports that are in place that are even close to the intensity he needs (as a result of the government’s policy decisions since March 2016) in which CTN is in full agreement of, along with descending views of your own expert panel your government is trying to keep quite through non-disclosure agreements.

We’ve placed my son on the ABA wait list in which the ministry acknowledged was a total of 2 – 4 hours/week as a supplementary which was sold to the people of Ontario as a transition program to the new OAP, even though he would not benefit from this program.   The current wait list for that in York region is 1 ½ years which extends past the date of the new OAP which is supposed to replace this ABA program.  This leaves many in “transition” with NO services while the new program is put into place.  It’s been over 6 months since the announcement of this program and investments into ABA “transitional” services seem to be nonexistent. In fact the last time we applied for this useless block of ABA was in 2013, and the wait list back then was 1 year.  It’s now grown to 1 ½ years wait with the government investing 6 months ago to “increase” capacity.

In conclusion Minister Coteau, your office has direct responsibility under its mandate to ensure AIPs are being compliant with legislation, transfer payments, and ministry guidelines.  As outlined and acknowledged by the Ministry in its September 22nd, 2016 letter, the ministry doesn’t have the proper enforcement regime in place, nor does it investigate compliance issues properly with AIPs, all the while you directly acknowledged to parents recently you are aware of concerns regarding AIPs yet have done nothing to date to resolve those accountability concerns, nor has the ministry added any acknowledgement of that in response to my complaint against Kinark.

This ministry is refusing to work with parents upon complaint, and is refusing get involved in finding a solution for my 11 year old boy who has been eligible for IBI for 6 ½ years.

When is the ministry under your leadership Mr. Coteau, going to start following its mandate to the people of Ontario,  and understand that neglect in doing so has severely impacted many families and the futures of our kids.  I believe this Ministry’s responses to date regarding my son's situation and unwillingness to get involved to find solutions to those caught up in an imperfect system closely align to that in which was reported by the Ombudsman in August regarding adult services with a different Ministry which launched a multiyear systemic investigation.  The culture in your office needs to change Mr. Coteau if you are expected to put forth viable solid solutions to a crisis your ministry is directly responsible for creating due to lack of enforcement and accountability mechanisms on AIPs.  Do parents have to go through yet another round of protests, fights, and complaints before your office does the right thing?

We shouldn’t be fighting for services at all Mr. Coteau.  I don’t think your government quite understands that point yet. We have enough on our plates, than to be dealing with this mess in which the people of Ontario pay you handsomely for.  I would like a resolution to my sons situation please.

Warm Regards,

Jason Koblovsky