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Cardus Presentation to Parliamentary Committee on Bill C-35

April 21, 2023

Peter Jon Mitchell


Policy Brief

Child Care Parents & Children

Funding families directly is the most equitable option to make child care more accessible and affordable.

Thank you for the invitation to appear today, and thank you for the work of this committee in support of families across Canada.

Cardus is a non-partisan think tank dedicated to clarifying and strengthening, through research and dialogue, the ways in which people, institutions, and governments work together for the common good.

I direct our family program at Cardus, which explores how to strengthen family stability.

Childcare is the care of a child, regardless of who provides that care, whether by a licensed provider, in-home caregiver, neighbour,  relative, or parent who forgoes income. Statistics Canada data show that Canadians rely on diverse forms of care to meet their needs.

Bill C-35 supports only a limited number of care options. The bill enshrines inequitable treatment of families based on the type of care they use. Canadian data and international examples show that higher-income families are more likely to access subsidized, licensed care compared to lower-income families.

There are better and more equitable options to support the care needs of Canadian families.

However, should Bill C-35 proceed, I recommend three amendments.

First, section 5(e) should reflect that parents and guardians have the primary responsibility for the upbringing and development of their children. Parents are best positioned to make the care choices for their children. In the brief we submitted to the committee, we provide wording that reflects the phrasing found in article 18 of the Convention on the Rights of the Child—the same article from which section 5 of Bill C-35 draws its inspiration.

Second, section 7(1)(a) discriminates against licensed independent operators in favour of public and not-for-profit providers. This discrimination harms families and hampers the government’s own goals. This discrimination contravenes an early statement in the bill supporting the importance of flexible early-learning and childcare programs. Many of the agreements prevent funding intended for space creation and growth from going to licensed independent providers who currently serve Canadian families.

This discrimination hampers accessibility. Currently there are only enough licensed spaces for about a third of children under age six. The aggressive space-creation targets within the Canada-wide agreements are proving difficult to achieve. In the first year of its agreement, Saskatchewan exceeded its space-creation budget but achieved only 37 percent of its space-creation target. The Financial Accountability Office of Ontario estimates that by the end of the agreement in that province, families of 25 percent of children under the age of six who want a highly subsidized space will be unable to access one.

It is very unlikely that space-creation targets will be met without independent licensed providers.

Third, section 16 regarding annual reporting must be strengthened. The desire to report on progress within the bill should be applauded, but section 16 should be more specific. The federal government collects detailed financial data and progress toward targets from the provinces annually. The agreements in most cases state that provinces “may” report progress to the public. To my knowledge, only two provinces have publicly reported on the progress made during the first year of their agreements within the timeline specified in the agreements.

One way to remedy this is to strengthen federal reporting requirements within the bill, requiring the federal government to release detailed expenditures and progress toward stated targets for each province.

How well are families being served by the Canada-wide program? Caring for vulnerable populations such as children is complex and expensive. We should be striving for higher levels of accountability.

Childcare is the care of the child regardless of who provides that care. We should strive for policy options that treat families fairly and offer true flexibility to families as they select the care that best meets their needs.

Thank you for your time.