1. Accessibility Standards for Customer Service
for the mental health and addictions sector
Developed in partnership with the Accessibility Directorate of Ontario by:
Ontario Federation of Community Mental Health and Addiction Programs
Ontario Peer Development Initiative
Ontario Association of Patient Councils

2. What does disability mean to you?
Write down the first word that came to mind when you read the word “disability”.
In your group:
Discuss why that word was top of mind for each member in your group.
How do our answers reflect the general perception of disabilities?

3. Not all disabilities are visible
Read script:
Not all disabilities are visible, but persons with physical disabilities are the people who are shown most often and they stay in our minds.
Anyone in the right-hand picture could be a person with a disability.

4. Objectives of today’s session: Equip agencies with facts & tools
Gain an understanding of the Accessibility for Ontarians with Disabilities Act, 2005
Learn what organizations must do to comply with the customer service standard
Become familiar with the AccessON.
Respond to your questions
Like most legislation, there is the Act and then there are regulations, in this case called the accessibility standards for customer service.
Keep in mind that this is about serving your clients and inquiries from the public, it is not about building accessibility. This session only deals with how to provide customer service to members of the public who have disabilities.
The Act and the customer service standard build on the Human Rights Code which has been in force for 20 years. The Human Rights Code states that:
Every person has a right to equal treatment with respect to services, goods and facilities, without discrimination because of race, ancestry, place of origin, colour, ethnic origin, citizenship, creed, sex, sexual orientation, age, marital status, family status or disability.
This new legislation describes how to provide better client service to people with disabilities and lists what organizations must do.

5. Act and regulations work together
Read script:
We will be learning about two pieces of legislation in today’s session:
The first legislation we will be reviewing is the Accessibility for Ontarians with Disabilities Act, commonly called the AODA.
The act establishes how Ontario will become accessible for Ontarians with disabilities, in several areas, by January 1, 2025.
The AODA:
defines several terms that are used in both the act and the regulations
contains the procedures for establishing accessibility standards and the contents of those standards
details penalties for non compliance
states that if the AODA is in conflict with another act, then the act that provides the greatest accessibility prevails
The second piece of legislation we will look at is the Accessibility Standards for Customer Service.
It is the first regulation to come into law under the AODA.
The standard is the main focus of today’s session.
As you can see, the areas of the standard are aligned with the act and the act and the standard work together and need to be reviewed together.
We will start with the act and highlight the key details and then move to the customer service standard which we will cover in depth.

6. AODA makes Ontario accessible for people with disabilities
The Accessibility for Ontarians with Disabilities Act, 2005 (AODA) became law on June 13, 2005.
The purpose of the AODA is to make Ontario accessible to people with disabilities by January 1, 2025.
Read slide.
Ask:
What factors in our society and population might have provided incentive for the AODA at this time?
If there is not much discussion, provide possible answers such as:
Discrimination against people with disabilities is against the law
People with disabilities have the same rights as anyone else to participate in all aspects of society
Attitudes about disabilities are changing as people with disabilities participate more in all aspects of everyday life
As Ontario’s population ages, the number of people with disabilities will increase
But there is still stigma and discrimination
How does making Ontario accessible for people with disabilities benefit all citizens?
Society is judged by the way it includes its most vulnerable citizens
People with disabilities pay taxes and they are entitled to access the same services as everyone else
Sometimes it takes laws to change attitudes to make society inclusive

7. Standards specify how to make Ontario accessible
The AODA allows government to:
Develop specific standards of accessibility for people with disabilities and enforce them
Standards are then made into regulations that provide details about how accessibility will be achieved
Require organizations to implement the requirements of the standard within the time periods specified or face penalties
Read slide.
Read script:
This Act applies to every person or organization in the public and private sectors of the Province of Ontario.

8. Standards set requirements
Standards address how organizations will achieve accessibility in five broad areas:
customer service
transportation
information and communications
employment
built environment
Standards can require policies, measures, practices or other requirements that need to be met to identify, prevent and remove barriers.
Read slide.

9. Standards developed by consultation
Read slide title only.
Follow script:
Accessibility standards are developed by committees.
Committees set a series of proposed accessibility standards for what needs to happen to make an industry, sector or class of organization accessible.
Proposed standards go through public consultation.
Standards will be phased in over time.

10. Standards apply to most organizations
An accessibility standard applies to a person or organization that does at least one of the following activities:
provides goods, services or facilities
employs people in Ontario
offers accommodation
owns or occupies a building, structure or premises
plays a part in a business or other activity that the regulations may identify
Read slide title only.
Add this information:
The specific standard will state which people and organizations the standard will apply to and by what timeframe.
You’ll soon see who is required to comply with the customer service standard.

11. Standards specify reporting requirements
Organizations that are required to comply with a standard must also comply with the reporting requirements of that standard.
Due dates and frequency of reporting are contained in each standard.
If a report is required, it must also be available to the public.
Read slide title only.
Follow script:
Each standard that is developed will include reporting requirements for that standard. We’ll discuss the reporting requirements for the Customer Service Standard in a few minutes.
The purpose of the reports is to determine if organizations are in compliance with the requirements of an accessibility standard.

12. Failing to comply with standards can incur penalties
Administrative penalties may result if an organization does not:
comply with the accessibility standard within the time specified
file an accessibility report on time, if required by a standard
file a report that was requested by the government
comply with a previous order
Read slide.
Add:
The AODA spells out the penalties that may be imposed if an organization does not comply with a standard and file reports that are required under the standard.

13. Fines for not complying may be substantial
If guilty of an offence under the AODA
an individual is liable to a fine of not more than $50,000 per day as long as the offense continues
a corporation is liable to a fine of not more than $100,000 per day as long as the offense continues
Read slide title only.
Add:
Non-compliance with a standard can have serious financial consequences for an organization.
Penalties are a last resort and it’s hoped they won’t need to be invoked.
The standards can really help organizations improve how they provide service to consumers and become more client-focused and client-driven.

14. Directors and officers have duty to prevent offences and are liable
“Every director or officer of a corporation has a duty to take all reasonable care to prevent offenses.” Section 37 (4)
“Every director or officer of a corporation who has a duty under subsection (4) and who fails to carry out that duty is guilty of an offence and on conviction is liable to a fine of not more than $50,000 for each day or part of a day on which the offence occurs or continues to occur.” Section 37 (5)
Read slide title only.
Add:
It’s important your board of directors and ED or CEO understand that they have responsibilities under the AODA for ensuring your organization complies with standards.
Board members need to know what their duties are under the AODA and the penalties for which they may be liable.
We’ll see when we get into customer service standard, that they most likely have specific roles in policy development and ensuring, if reports are required, that they are completed accurately and filed on time.
Under PART X, you’ll see the penalties for not complying.

15. AODA & standards relate to other laws
Follow this script:
This slide shows how the AODA and the customer service standards fit with other laws.
It gives an idea of the other acts and regulations that your organization might need to refer to when complying with the regulations.
Note that where two laws address accessibility, the AODA states the law that provides the greatest accessibility prevails.
Standards may refer to other acts or regulations such as using existing definitions or describing when a standard may or may not apply. For example, the Blind Persons’ Rights Act regulation provides the definition of “guide dog”.
Under “Customer Service” there are 2 regulations 429 and 430.
429 is the “Accessibility Standards for Customer Service”.
430 is the regulation that specifies the reporting requirements for organizations that come under this standard.
You can go to the website of the Ministry of Community and Social Services and under Business Sector find the status of each of the standards that are in progress. (Before each session, check the status of the other regulations and update the slide.)

16. “Disability” is defined in the AODA
“Disability” covers a broad range and degree of conditions, some visible and others not.
“Disability” in the AODA means:
“any degree of physical disability, infirmity, malformation or disfigurement caused by bodily injury, birth defect or illness
a condition of mental impairment or a developmental disability
a learning disability, or a dysfunction in one or more of the processes involved in understanding or using symbols or spoken language
a mental disorder
an injury or disability for which benefits were claimed or received under the insurance plan established under the Workplace Safety and Insurance Act, 1997.”
Read slide title only.
Add:
The AODA uses the same definition of “disability” as the Ontario Human Rights Code.
As you can see, the definition covers many types of disability.

17. There are several types of barriers people with disabilities face
Attitude
can be based on lack of knowledge, fear of doing the wrong thing or discomfort
Technology
not having access to technology can prevent people from getting information
Systemic
can occur through policies, procedures, practices, rules or values
Read slide.
Ask:
How would you define “barrier” in the context of disability?
Summarize by saying:
A barrier is anything that keeps someone with a disability from fully participating in all aspects of society because of their disability.
Why would attitude be a difficult barrier to overcome?
If there isn’t much response, you can say:
attitudes may not be based on fact but on stereotypes
sometimes we don’t even know why have we a certain attitude making it difficult to change
it’s hard to change the way people think and behave
attitudes get reinforced through the media, peers, or generalizing from one experience
What barriers people face in the mental health and addictions sector?
Summarize answers.

18. Customer service standard is aimed at making service accessible
Accessibility Standards for Customer Service (the standard) came into force on January 1, 2008.
People, businesses and other organizations that provide goods or services to the public or to other businesses or organizations in Ontario (“providers”) have legal obligations under the standard.
The standard is aimed at making their customer service operations accessible to people with disabilities.
Follow this script before discussing this slide:
That was an overview of the Act.
Now we will turn to the customer service standard and take an in-depth look at what the requirements are.
Read slide and add:
“Customer service operations” mean existing services that your organization currently provides. It does not mean providing more programs.

19. Most organizations must comply
The standard applies to all people or organizations in Ontario that:
are private, not-for-profit, public
provide goods or services
have one or more employees
Organizations under federal jurisdiction may be exempt:
banks, airlines, telecommunications
organizations on First Nation reserves managed by the band council or programs under federal works
Read slide.
Follow this script:
Very few organizations will be exempt.
One example may be a strictly volunteer organization that has no employees.
However, if a volunteer organization has even one part-time employee, then that organization must comply with the standard.
Complaints about accessibility of organizations under federal jurisdiction would go to the federal government.

20. If have 20 or more employees, documentation requirements apply
Employees mean:
full-time, part-time, seasonal and contract
All must be counted when determining the number of employees in an organization.
Exclude from the count:
volunteers and independent contractors/consultants
Counts may vary on when counting is done:
anytime there is one or more employees, compliance with the standard is required
if employee count reaches 20 or more, compliance with documentation requirements is required
Read slide.
Follow this script:
If your organization is just under 20 employees, then you will need to comply with documentation requirements if your organization reaches 20 employees.
Your organization will need to build in an alert to take action to comply with the standard requirement for documentation if it reaches 20 employees.

21. Deadlines for compliance varies with organizational type
Deadlines for complying with the customer service standard depend on whether or not an organization is a designated public sector organization.
January 1, 2010 – for all designated public sector and broader public sector organizations.
January 1, 2012 – for all other providers with at least one employee.
Read slide.
Add:
Most of you are in the not-for-profit sector so your compliance date is 2012.
Designated means the government boards, commissions, authorities and agencies such as the Child and Family Services Review Board, Social Assistance Review Board that are listed in Schedule 1.
Broader public sector includes school boards, most hospitals, universities and community colleges and public transportation providers as listed in Schedule 2.
If your organization is part of a hospital such as a program run by the hospital or part of a municipality such as a public health unit, then your compliance date is 2010.
Compliance date does not depend on sources of funding. It depends on whether or not the organization is a designated in Schedules 1 and 2.

22. Summary of requirements
1 to 19 employees
20 or more employees
Comply with standard 
Comply with document requirements
File accessibility report
Say:
All organizations that have at least one employee must comply with the customer service standard.
Organizations with at least 20 employees must also comply with the document requirements.
We’ll learn about the specifics of the Accessibility Standards for Customer Service next.
Before we move on, what questions do you have about anything we’ve talked about up to this point?

23. Develop a work plan Sample work plan
Follow this script before discussing this slide:
It’s good practice, before delving into to complying with the standard, to establish a work plan.
Remember, for most of us, all work must be completed by January 1, 2012.
Read step 3 of the work plan. Add these points:
The audit is not of every policy, procedure or practice.
It is only those that have implications for client service.
Some types of policies, procedures or practices may be outreach policy, intake procedures or case management procedures.
The budgeting procedure might be included if you want to make your agency more accessible through purchasing assistive devices.
Point to step 4 and add:
Your organization may need to update some policies and add new ones.
Point to step 6 and add:
You will need to train staff on your own policies.

24. 1. Establish service policies, procedures and practices
Establish policies, procedures and practices on how your organization will provide services to people with disabilities.
The standard does not specify what policies, procedures and practices on providing goods or services to people with disabilities must contain.
Number of employees
Policy requirements
1 to 19
policies, etc. may be informal
20 or more
policies, etc. must be in writing
Say:
This is the first requirement of the standard.
Read slide.
Add:
The standard leaves it up to the organization to determine what its customer service policies, procedures and practices about serving people with disabilities contain.
Informal means they are not in writing.
Remember we saw that there were documentation requirements. This is one of those requirements that if your organization has more than 19 employees, you must document all your policies, practices and procedures that deal with how your organization serves people with disabilities.

25. 2. Standard requires consistency with four principles
Ensure your organization uses all reasonable effort in policy, procedure and practice development to be consistent with the principles of:
dignity
independence
integration
equal opportunity
Read slide.

26. 3. Develop personal assistive devices policy
Develop a policy on allowing people to use their own assistive devices to access your services.
Include in the policy any assistive devices or other measures your organization offers to help people with disabilities use your services
Provide information to consumers about how they can access those devices or measures
Before reading slide state:
The next requirement in the customer standard is that you organization must develop a personal assistive device policy
Read slide.
Explain the following:
Assistive devices may be devices that people bring with them, such as: walkers, magnifiers, or oxygen tanks.
Assistive devices that an organization might provide include: assistive software for people with visual, hearing or mobility impairments, wheelchairs or TTY (telephone teletype), real-time captioning or assistance from a staff person.
Organizations should inventory the assistive devices it has.
Providing information about assistive devices might include posting on agency website, in brochures and other publications such as event notices.

27. Newer assistive devices
Braille cell & text message
Braille ‘n Speak used to take notes in Braille
Screen magnifier
Script
Here are pictures showing newer assistive technology for people who are visually impaired.
Most people who have low vision, do not use Braille. These pictures simply illustrate that there are many ways in which technology has improved and that Braille is not a high-priority option today for people with low vision.
If participants ask about prices of assistive devices, here are estimates.
$50 and up for a screen magnifier
$200 for the TTY combination
$1,500 for the Braille ‘n speak
$3,000 for electronic glasses.
Telephone, TTY & amplified phone combination
Woman using electronic glasses
Telescopic glasses for distances

28. 4. Address communicating with people with disabilities
Determine how your organization will take into account a person’s disability when communicating with that person.
Read slide.
Explain the following:
This requirement does not require a policy, but your organization must make some type of statement or have procedures that describe how your agency will communicate with people with disabilities.
Communicating with people who have disabilities may include range of options from speaking clearly, writing instructions down on a person’s pad to more sophisticated options such as Braille, large print or audio format.
Organizations do not have to provide all these alternative formats.
The most common would be large print and electronic text.
Your organization is expected to work with its clients to find a way to communicate that is satisfactory to the client and the organization.

29. 5. Allow use of service animals
If a person with a disability is accompanied by a guide dog or other service animal, permit them access to all areas of the premises which are open to clients, consumers or other third parties.
If service animals are excluded by law, then provide alternative ways for clients or consumers with disabilities to access services.
Before reading slide explain:
The standard does not specifically state you must have a policy on the use of service animals.
But your organization must allow use of service animals.
However, it’s a good practice to have policies and procedures to provide guidance to staff and ensure compliance.
Read slide.
Explain these terms:
Guide dog: This is a dog that has successfully completed the training program at any of the facilities listed in the Blind Persons’ Rights Act and has been qualified as a guide dog.
Service animal: May also be called “assistance animals”, “assist animals”, “support animals” or “helper animals”. An animal is qualified to be a service animal if:
It is readily apparent the animal is used by the person for reasons relating to his or her disability; or
The person provides a letter from a physician or nurse confirming the person requires the animal for reasons relating to the disability.

30. Service animals at work
Dog inserts debit card
Dog answers phone
Dog presses walk button
Script
Here are pictures showing service animals in action.
Monkey feeds owner
Parrot assists owner
Dog loads dryer

31. Public health prohibits service animals where food is prepared
The Health Protection and Promotion Act states that rooms where food is prepared, handled, served or sold must be kept free of live birds and animals.
However, guide dogs and service dogs are allowed where food is served or sold.
Read slide.
Explain:
Guides dogs and service dogs are not allowed where food is prepared, but are allowed where food is served or sold.
Service animals, other than dogs, are excluded from areas where food is prepared, handled, stored or sold.
The exclusion of animals may apply to your agency if you have a kitchen and serve meals, have catered events or fundraisers where food is sold.
Ask:
How would you provide food service to a person whose service animal was not a dog?
If there are no responses, provide answers:
Ask the client if he or she has a suggestion.
Offer to provide a place where the animal can be kept while the client is in the eating area.
Offer that staff can assist the client in being seated or going through the food line.

32. 6. Allow support persons
If a person with a disability is accompanied by a support person your agency must ensure
both persons are allowed to enter the premises together
the person with a disability is not prevented from having access to the support person while on the premises
Follow script:
The next few slides show the requirement about support persons.
These requirements do not require a policy, but again, it’s a good idea to have a policy and procedures.
Read slide.
Provide this information about the definition of a support person:
The definition of a support person is “This is another person who accompanies a person with a disability in order to help with communication, mobility, personal care or medical needs or to help with accessing goods or services.”
May also be called “support professional”, “caregiver”, “interpreter” or “friend” to name a few.
Support persons do not require any specific training.
They may be a professional, relative, volunteer or friend.
The consumer and the support person are allowed on all areas of the premises that are open to the public or third parties.
You cannot make the support person wait outside until you verify who he or she is, but he or she must be able to enter the premises with the consumer and can go to any program or session with the consumer.

33. There are different types of support persons
Positive behaviour support person
Script
Here are pictures showing three types of support persons.
Remember that support persons do not need to be professionals to be considered a “support person”. They may be friends, relatives or volunteers.
Tactile signing for deafblind person
Recreational support person

34. 8. Provide notice of temporary disruption of facilities
If your agency has facilities or services that people with disabilities need to use to access your services, then you must provide public notice when those facilities or services are:
temporarily unavailable
if they are expected to be unavailable in the near future.
Provide this notice as soon as possible.
Read slide.
Explain:
Facilities may include:
elevators
computer equipment
wheelchair accessible washrooms
staff members who provide sign-language interpretation

35. Include details about interruption in notice
When a disruption of the facilities or services, occurs the agency must include this information in the notice:
Reason for the disruption.
How long the disruption is expected to last.
If there are alternative facilities or services available for the duration of the disruption that will allow clients or consumers with disabilities to continue to have access to services.
Read slide.
Explain:
Notice must contain each piece of information stated here.
Ask:
What action could you take if an elevator was out of service and consumers with mobility disabilities were unable to attend programs on the second floor?
If no answers, suggest:
ask if staff could assist the person in using the stairs, if staff were trained in proper procedures
move sessions to rooms on the first floor or to an accessible location off premises

36. Post information about disruption in obvious places
Post the notice of disruption in places where people are likely to see it such as:
on the front door of the agency
on the agency’s website
at the site of the disruption such as at an elevator or computer that is out of order
Read slide.

37. 9. Deliver training programs to those who provide service
Provide training on customer service to people with disabilities.
Deliver training to everyone in your agency who:
deals with members of the public such as staff, students and volunteers
provides services to the public on the agency’s behalf: agents, consultants or other contractors
Read slide.
Explain:
Anyone in your agency who deals with the public or clients and consumers must receive training on the topics outlined in the standard.
This includes contract staff, part-time and temporary employees and volunteers and students.
Organizations need to make sure everyone who interacts with clients or consumers receive training on all your updated and new policies, procedures and practices that refer to dealing with consumers or clients.
MCSS has developed a range of training resources.
Point out:
Serve-Ability is an online course about serving people with disabilities
Training Resource which is a full-length manual
Except for requirements that deal with your own policies and procedures for customer service, all the training needed is available at MCSS website

38. 10. Deliver training to policy, procedures and practices developers
The agency must provide training to everyone who develops policies, procedures and practices for your agency about the provision of services to clients and consumers.
Read slide.
Mention:
In addition to senior management, this includes members of the board or committees and other volunteers, staff, consultants or others who are involved in developing policies, procedures or practices for your agency.
They need to be trained on the Act and the standard in order to develop policies, procedures and practices to comply with them.

39. Training content includes the Act, standard and instructions
Deliver training that includes:
Review of the purpose of the Act and the requirements of the customer service standard.
Instructions about:
How to serve people with disabilities who use assistive devices, guide dogs or other service animals or the assistance of a support person.
How employees are expected to use equipment or devices that are available within your organization that may help with the delivery of services to a person with a disability.
What staff should do if a person with a particular type of disability is having difficulty accessing the organization’s services.
Read slide title.

40. Provide timely & ongoing training
Provide timely training:
Provide training as soon as practicable after a staff member, volunteer, student or others is assigned to provide service to your clients.
Provide ongoing training:
Whenever policies, procedures or practices change regarding providing service to people with disabilities, conduct on-going training.
Meet applicable deadlines:
Complete training requirements for current staff.
Read slide.
Add:
This would include new hires and people assigned to new positions that now include interacting with clients.
Ongoing training needs to happen as soon as practicable for staff, volunteers, students and others who act on behalf of your agency.
All other training must be completed by January 1, 2012.
However, if your organization is a designated public sector organization, then training must be completed by January 1, 2010.

41. 11. Establish feedback processes
Set up a feedback process that:
allows anyone to give feedback on the way in which the agency provides services to persons with disabilities
describes how the agency will receive and respond to this feedback
makes information about the feedback process readily available to the public
Read slide.
Add:
The standard requires that service providers set up a feedback process so that anyone can comment on the provision of services to people with disabilities.

42. Provide options for providing feedback
The feedback process must:
describe the ways people can provide feedback
ensure the communication method takes into account the person’s disability.
Feedback options must include at least one of:
in person
by telephone
in writing
sending an electronic text, or on diskette or other electronic means
Read slide.
Add:
The options for providing feedback are specifically stated in the standard.
Keep in mind that the standard also requires that the communication method must take into account the person’s disability.
Your planning may want to consider that people with various disabilities will use your feedback mechanism.

43. Specify complaint-handling process
The feedback process must describe the actions that will be taken if a complaint is received about how services were provided to people with disabilities.
Read slide.
Explain:
The standard does not describe what actions need to be taken when a complaint is received.
However, complaints are the best source of ways to improve service to consumers, so having a solid complaint-handling process makes good operational sense.

44. 12. Comply with documentation requirements for 20 or more staff
Prepare documents describing your policies, practices and/or procedures:
governing the provision of good and services to people with disabilities
with respect to the use of service animals and support persons
that set out the steps to be taken in connection with a temporary disruption
for training and include a summary of the contents of the training, details of when the training is to be provided and keep records of the training provided
describing the feedback process and how complaints are handled
Introduce slide.
We talked briefly about documentation requirements near the beginning of the session.
Now we will get into the details.
Putting policies, procedures and practices in writing is required only if your organization has 20 or more staff.
Employee count must include part-time, casual, contract employees.
Read slide title and first bullet point.
Explain:
These documents are your policies, procedures or written practices.

45. 13. Comply with availability and format requirements for documents
Post information in a conspicuous place letting consumers know that the documents are available on request.
Provide the documents in a format that takes into account the requestor’s disability.
Read slide.
Explain:
You can post the information on your premises, your website or use any reasonable ways to ensure people are aware the information is available.
If the requestor is a person with a disability, you must provide documents in a format that takes into account the person’s disability.
You and the person with a disability may agree upon the format to be used for the document or information.
For example, a person with vision loss might prefer a document in Braille, but will accept an electronic copy that he or she can use with a screen reader or screen magnifier.

46. Key learning from the session
What were the most important points you are taking away from today’s session?
What ideas have you learned to help with challenges?
Read first point.
Allow for a few answers.
Read second point.
Remind people to use the resources provided and to contact the Accessibility Directorate if they have questions.