Accessibility Policy
Multi-Year Accessibility Plan
1. BACKGROUND & PURPOSE
The purpose of the goal of the Accessibility for Ontarians with Disabilities Act, 2005 (the “Act”) is to create a more accessible Ontario, by identifying, and to the extent possible, preventing, and eliminating barriers experienced by persons with disabilities.
The Integrated Accessibility Standards (the “IAS”) is a regulation under the Act the purpose of which is to ensure accessibility for persons with disabilities in the areas of (i) Information and Communication, (ii) Employment, (iii) Transportation and (iv) Design of Public Spaces.
Eldercare Home Health has developed a policy that identifies how Eldercare Home Health currently achieves and will continue to achieve accessibility by meeting the requirements of the IAS and by preventing and eliminating barriers faced by persons with disabilities (the “Policy”).
The purpose of this multi-year accessibility plan (“Accessibility Plan”) is to create a roadmap that describes in more detail the steps Eldercare Home Health will take to meet the accessibility objectives set out in the Policy and the timeline in which these steps will be taken. The Accessibility Plan will help Eldercare Home Health ensure accessibility is incorporated into its regular business operations and its future development plans.
2. STATEMENT OF COMMITMENT
Eldercare Home Health is committed to developing, implementing and maintaining policies, practices and procedures aimed at meeting the accessibility needs of persons with disabilities in a timely manner.
3. COMPLIANCE WITH EXISTING LAW
Nothing in the Accessibility Plan or Policy is intended to replace or negate existing laws regarding accessibility for persons with disabilities including but not limited to the Human Rights Code and the Workplace Safety and Insurance Act (“Accessibility Legislation”).
The compliance deadlines established in this Accessibility Plan correspond with the deadlines set out in the IAS. Eldercare Home Health is working toward compliance in accordance with those deadlines. However, in advance of the compliance deadlines established by the IAS and this Accessibility Plan, Eldercare Home Health will continue to comply with its legal obligations under all applicable Accessibility Legislation
4. REVIEW
The Accessibility Plan must be reviewed and updated at least once every 5 years but may be reviewed more frequently depending on need.
5. TRANSPARENCY
As of January 1, 2014 the Accessibility Plan will be posted on Eldercare Home Health’s website. The Accessibility Plan will be provided to any member of the public in a hard, electronic or other Accessible Format upon request.
6. APPLICATION
Except as otherwise limited herein, this Accessibility Plan applies to Eldercare Home Health’s operations including but not limited to:
a) All persons who provide goods, services or facilities on behalf of Eldercare Home Health to its clients. b) Any person who participates in the development of Eldercare Home Health’s policies, practices and procedures respecting Eldercare Home Health’s operations.
7. IMPLEMENTATION & REVIEW
Responsibility for the implementation, review and update of the Accessibility Plan is shared as follows:
The President & CEO, VP Care Operations and the Manager of Human Resources are responsible for:
a) The development and maintenance of policies required by the Act and this Accessibility Plan b) The development and implementation of training programs required by the Act and this Accessibility Plan c) Implementing the web accessibility requirements d) Maintenance of the Accessibility Standards for Client Service policy and the Accessible Practices for Client Service & Training Program developed in compliance with the Accessibility Standards for Customer Service (“Customer Service Standards”) e) Compliance with the Design of Public Spaces Standards to the extent that they may apply to Eldercare Home Health at some time in the future Compliance with the Employment Standards f) The Manager of Human Resources is responsible for compliance with the Employment Standards as it pertains to Caregivers, g) All Staff are responsible for compliance with the Information and Communications Standards and the Customer Service Standards save and except for accessible websites and web content
8. DEFINITIONS
- Accessible Formats – may include, but are not limited to, large print, recorded audio and electronic formats, and other formats usable by persons with disabilities.
- Client – means existing and prospective clients of Eldercare Home Health.
- Communication Supports – may include, but are not limited to, captioning, alternative and augmentative communication supports, plain language, sign language and other supports that facilitate effective communications.
- Contractor – means an independent contractor, agent, consultant or other third party engaged by Eldercare Home Health to provide goods, services or facilities on its behalf.
- Disability – means: a) any degree of physical disability, infirmity, malformation or disfigurement that is caused by bodily injury, birth defect or illness and, without limiting the generality of the foregoing, includes diabetes mellitus, epilepsy, a brain injury, any degree of paralysis, amputation, lack of physical co-ordination, blindness or visual impediment, deafness or hearing impediment, muteness or speech impediment, or physical reliance on a guide dog or other animal or on a wheelchair or other remedial appliance or device, b) a condition of mental impairment or a developmental disability, c) a learning disability, or a dysfunction in one or more of the processes involved in understanding or using symbols or spoken language, d) a mental disorder, or e) an injury or disability for which benefits were claimed or received under the insurance plan established under the Workplace Safety and Insurance Act, 1997
New Internet Website – means either a website with a new domain name or a website with an existing domain name undergoing a significant refresh.
- Performance Management – means activities related to assessing and improving employee performance, productivity and effectiveness, with the goal of facilitating employee success.
- Staff – means employees of Eldercare Home Health.
- Unconvertible Information or Communication – means information or communication that it is not technically feasible to convert, or if it is technically feasible to convert, the technology required to do so is not readily available.
- Web Content Accessibility Guidelines (“WCAG”) – means the international standard for making websites and web content accessible to people with a wide-range of disabilities. The WCAG contain two levels of compliance, Level A and Level AA.
9. ACCESSIBILITY CUSTOMER SERVICE
Eldercare Home Health strives to deliver its services in a manner that respects the dignity and independence of persons with disabilities. Eldercare Home Health is also committed to ensuring everyone has the same opportunity to access its services and benefit from these services, in the same place and in a similar way. To this end, Eldercare Home Health has developed a Customer Service Standard Policy.
For a copy of the Customer Service Standard Policy, please contact:
Lisa Sundarsingh, VP Care Operations, Eldercare Home Health Mailing Address / In-person Request 396 Moore Avenue, Toronto, ON M4G 1C7 Telephone 416.421.4243 Fax 416.421-4617 Email lisa@integracare.ca
10. DOCUMENTATION
Eldercare Home Health reserves the right to request reasonable medical documentation to support a need for accommodation or an accessibility request under this Accessibility Plan.
11. GENERAL ACCESSIBILITY STANDARDS UNDER IAS
Training Compliance Deadline: January 1, 2015
Policy Statement:
| By January 1, 2015 (the “Compliance Deadline for Training”), Eldercare Home Health will provide training to all existing Staff and all persons who participate in the development of AODA Policies. Training will be provided on: the requirements of the IAS; the Human Rights Code as it pertains to persons with disabilities; and iii. the AODA Policies as required by the IAS. The content of the training will be applicable to the individual’s duties. Staff hired after the Compliance Deadline for Training will receive the required training as soon as practicable. Eldercare Home Health will keep a record of the training provided, including the dates on which the training is provided and the number of individuals to whom it is provided. Eldercare Home Health will ensure that contractors providing goods, services and/or facilities on Eldercare Home Health’s behalf have received training as required under the IAS. |
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Accessibility Plan
i. Content of Training
Eldercare Home Health will develop a single training program for all Staff on the Information and Communication
Standards and the Employment Standards. The training program will address the Human Rights
Code as it pertains to persons with disabilities and the requirements of the IAS. Appropriate individuals will receive specialized training on the Design of Public Spaces Standards as require
ii. Format of Training All Staff will receive in-person training where possible
iii. Training for Contractors Eldercare Home Health occasionally engages Contractors to provide goods and services to Clients on its behalf. By the Compliance Deadline for Training, Eldercare Home Health will have in place a process for ensuring that all
Contractors receive the training required under the IAS.
12. INFORMATION AND COMMUNICATION STANDARDS
I) Feedback Procedures Compliance Compliance Deadline: January 1, 2015 Policy Statement:
| By January 1, 2015 Eldercare Home Health will ensure that its processes for receiving and responding to feedback Are accessible to persons with disabilities by providing or arranging for the provision of Accessible Formats and Communications Supports, upon request. Eldercare Home Health will notify the public that Accessible Formats and Communications Supports are available in respect of its feedback procedures. |
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Accessibility Plan:
Eldercare Home Health currently accepts feedback from employees, clients and the public in a number of different ways including but not limited to: (i) in person, (ii) over the telephone, (iii) in writing (i.e. handwritten, by mail or email), (iv) delivered on a USB key etc.
In addition to the above, Eldercare Home Health will provide or receive responses to feedback in an Accessible Format or with Communication Supports upon request.
II) Accessible Formats & Communication Supports Compliance Deadline: January 1, 2016
| By January 1, 2016 Eldercare Home Health will, upon request, provide or arrange for the provision of Accessible Formats and Communication Supports in order to make its communications or information about the goods, services and/or facilities it offers accessible to persons with disabilities. |
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i) Exempt Information
The Information and Communication Standards do not apply to (i) products and product labels; (ii) Unconvertible information or communications; and (iii) information that Eldercare Home Health does not control directly or indirectly through a contractual relationship.
The Information and Communication Standards do not apply to (i) products and product labels;
ii) Unconvertible information or communications; and (iii) information that Eldercare Home Health does not control directly or indirectly through a contractual relationship. Should Eldercare Home Health determine that information or a communication is Unconvertible it will explain why this is the case and provide the person making the request with a summary of the said information or communication.
ii) Consultation
Staff who receive a request from a Client or the public for information in an Accessible Format or with Communication Supports should consult with the requesting individual to determine how the information may best be made accessible.
A Contractor who receives a request from a Client or the public for information in an Accessible Format or with Communication Supports should report the request to Eldercare Home Health immediately.
The Managing Director is responsible for assisting Staff with the consultation process where required.
iii) Providing Accessible Formats At No Additional Cost
Eldercare Home Health may not have Accessible Formats immediately available upon request. If a Client makes a request for accessible documentation in these circumstances, Eldercare Home Health will contact and obtain the services of a company that specializes in converting written documentation into accessible formats (i.e. pdf document that can be read by a screen reader, Braille etc.)
Accessible Formats and Communication Supports will be provided in a timely manner and at a cost that is no more than the regular cost charged to other persons.
iv) Accessible Websites and Web Content Initial Website Compliance Deadline: January 1, 2014 Final Website Compliance Deadline: January 1, 2021
| By the Initial Website Compliance Deadline Eldercare Home Health will take reasonable steps to ensure that, where practicable, new content posted on its website conforms with WCAG 2.0 Level A. By the Final Website Compliance Deadline Eldercare Home Health will ensure that, where practicable, all content published on its website after January 1, 2012 conforms with WCAG 2.0 Level AA to the extent required by the IAS. When determining whether meeting the requirements of this section is practicable, Eldercare Home Health will consider: (i) the availability of commercial software or tools required to achieve web accessibility; and (ii). the impact meeting the requirements of this section will have on projects planned before January 1, 2012. The commitment to provide accessible websites and web content only applies to websites and web content that Eldercare Home Health controls directly or indirectly through a contractual relationship that allows for modification of the website or web content in question. |
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Eldercare Home Health operates a website to service Clients and members of the public. Effective September 30, 2013, Eldercare Home Health’s website was compliant, in part, with the WCAG 2.0 Level AA. Eldercare Home Health will take reasonable steps to ensure that web content posted on Eldercare Home Health’s website as of January 1, 2014 conforms, where practicable, with WCAG 2.0 Level A. By January 1, 2021, Eldercare Home Health will ensure that, where practicable, all content published on its website after January 1, 2012 confirms with WCAG 2.0 Level AA
13. EMPLOYMENT STANDARDS
The Employment Standards only apply to Staff. They do not apply to Contractors.
i) Recruitment/Selection/Assessment Compliance Deadline: January 1, 2016
| By January 1, 2016, Eldercare Home Health will notify its employees and the public of the availability of accommodation during the recruitment process. Eldercare Home Health will further notify all job applicants who are individually selected to participate in an assessment or selection process that accommodation is available upon request in relation to the assessment or selection process if the applicant requires accommodation due to a disability. If an applicant requests accommodation, Eldercare Home Health will consult with the applicant and provide or arrange for the provision of a suitable accommodation in a manner that takes into account the applicant’s accessibility needs |
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i) Notification to the Public & External Applicant: Accessibility Plan: Accommodation During Recruitment This Accessibility Plan posted on Eldercare Home Health’s website will serve as notice to the public of the availability of accommodation during the recruitment process. Eldercare Home Health may occasionally post open positions on various job search websites. Where such postings are made, Eldercare Home Health will include a notification of the availability of accommodation during the recruitment process.
ii) Notification: Accommodation During Assessment & Selection Eldercare Home Health employs different assessment and selection processes depending on the position for which it is hiring. Assessment and selection process may include but is not limited to standard interviews and Eldercare Home Health skills tests.
Where an applicant is individually selected to participate in any assessment or selection process Eldercare Home Health will notify the applicant of the availability of accommodation in respect of same.
Where, by reason of a disability, an applicant requests accommodation in respect of an assessment or selection process, Eldercare Home Health will consult with the applicant for the purposes of determining an appropriate accommodation.
Where Eldercare Home Health determines an applicant, due to a disability, does require accommodation during the assessment and selection process, Eldercare Home Health will provide accommodation up to the point of undue hardship.
iii) Notice to Successful Applicants
Compliance Deadline: January 1, 2016 Policy statement
| By January 1, 2016, Eldercare Home Healthwill ensure that when making offers of employment, it notifies the successful applicant of its policies on accommodating employees with disabilities. |
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Eldercare Home Health will notify successful candidates for employment of its policy regarding the accommodation of employees with disabilities in its offer letters and/or contracts of employment.
iii) Informing Employees of Supports Compliance Deadline: January 1, 2016
Policy Statement
| By January 1, 2016, Eldercare Home Health will inform its existing employees of its policies on supporting employees with disabilities, including, but not limited to, policies on the provision of job accommodations that take into account an employee’s accessibility needs due to disability. Eldercare Home Health will provide employees with updated information whenever there is a material change to its policies on the provision of job accommodations for employees with disabilities. |
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Eldercare Home Health will circulate a notification informing employees of the availability of accommodation during employment as well as its policies for the development of documented individual accommodation plans and return to work plans. Eldercare Home Health will update this notification as necessary, such as where there is a change to existing policies on the provision of job accommodations that take into account an employee’s accessibility needs due to disability.
iv) Accessible Formats and Communication Supports for Employees Compliance Deadline: January 1, 2016
| By January 1, 2016 Eldercare Home Health will, upon the request of an employee with a disability, provide or arrange for the provision of Accessible Formats and Communication Supports in order to ensure that (i) information required by the employee to perform his/her job; and (ii) information generally available to employees in the workplace, is accessible to the employee with a disability. Eldercare Home Health will consult with the employee making the request to determine the suitability of any Accessible Format or Communication Support. However, Eldercare Home Health reserves the right to determine the Accessible Format or Communication Support that will be provided in the circumstances. |
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A request for the provision of information in an Accessible Format and/or with a Communication Support may be made to the Managing Director. Such requests will be addressed in accordance with Eldercare Home Health’s regular procedure for accommodating employees with disabilities, which includes the development of a documented individual accommodation plan in consultation with the employee.
v) Workplace Emergency Response Information Compliance Deadline: January 1, 2012
| If an employee has a disability and Eldercare Home Health is aware that, due to that disability, the employee requires an individualized workplace emergency response, information addressing such response will be provided to the employee as soon as practicable after Eldercare Home Health becomes aware of such requirement. In such a case, with the employee’s consent, Eldercare Home Health will designate a colleague(s) to provide such individualized assistance and will ensure that this colleague is provided with a copy of employee’s individualized emergency response information. Eldercare Home Health will review the individualized workplace emergency response information when (i) the employee moves to a different work location; (ii) the employee’s overall accommodations needs or plans are reviewed; and (iii) when Eldercare Home Health reviews its general emergency response policies |
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i) Existing Employees
A notification regarding Eldercare Home Health’s emergency response procedures as well as the availability of individual emergency response information has been circulated to current employees. Individual emergency response information has been developed as required. Eldercare Home Health will continue to update individualized workplace emergency response information as necessary.
ii) New Employees
A copy of Eldercare Home Health’s emergency response procedures will be included in the Office Manual that is provided to employees upon commencement of employment. Information regarding the availability of individual emergency response information is provided to employees as soon as practicable upon commencement of employment.
vi) Documented Individual Accommodation Plans Compliance Deadline: January 1, 2016
| By January 1, 2016, Eldercare Home Health will have in place a written process for the development of documented individual accommodation plans for employees with disabilities. The process will include the following elements: i. The manner in which an employee requesting accommodation can participate in the development of the individual accommodation plan. ii. The means by which the employee is assessed on an individual basis. iii. The manner in which Eldercare Home Health can request an evaluation by an outside medical or other expert, at its own expense, to assist in determining if accommodation can be achieved and, if so, how accommodation can be achieved. iv. The manner in which the employee can request the participation of a representative from his or her bargaining agent, where the employee is represented by a bargaining agent, or other representative from the workplace, where the employee is not represented by a bargaining agent, in the development of the accommodation plan. v. The steps Eldercare Home Health will take to protect the privacy of the employee’s personal information. vi. The frequency with which the individual accommodation plan will be reviewed and updated and the manner in which it will be done. vii. If an individual accommodation plan is denied, the manner in which the reasons for the denial will be provided to the employee. viii. The means of providing the individual accommodation plan in a format that takes into account the employee’s accessibility needs due to disability. Where requested, an employee’s individual accommodation plan will include any information regarding the provision of Accessible Formats and Communications Supports. Where required, an employee’s individual accommodation plan will include individualized workplace emergency response information. An employee’s individual accommodation plan will include any additional accommodation that is to be provided. |
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Eldercare Home Health has a written policy on the development of Individual Accommodation.
vii. Return to Work Process Compliance Deadline: January 1, 2016
| Eldercare Home Health has a documented return to work process for its employees who have been absent from work due to a disability and who require disability-related accommodations in order to return to work. The return to work process outlines the steps Eldercare Home Health will take to facilitate the employee’s return to work and will consider any documented individual accommodation plan that may exist. |
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Eldercare Home Health has a written policy on the development of a documented return to work process.
viii. Performance Management Compliance Deadline: January 1, 2016
| When applying its performance management process, Eldercare Home Health takes into account the accessibility needs of employees with disabilities, and, by January 1, 2016, will take into account written individual accommodation plans. |
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Individuals responsible for evaluating employee performance are aware of their obligations under the Human Rights Code and do not discriminate against an employee on the basis of disability. By January 1, 2016, individuals responsible for performance management will also take into account written individual accommodation plans as applicable.
ix) Career Development and Advancement Compliance Deadline: January 1, 2016
| When evaluating employees for the purposes of career development and advancement, Eldercare Home Health takes into account the accessibility needs of employees with disabilities, and, by January 1, 2016, will take into account written individual accommodation plans. |
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Individuals responsible for evaluating employees for career development and advancement are aware of Eldercare Home Health’s obligation under the Human Rights Code not to discriminate against an employee on the basis of disability. By January 1, 2016, individuals responsible for evaluating employees for career development and advancement will also take into account written individual accommodation plans as applicable.
14. DESIGN OF PUBLIC SPACES STANDARDS
Compliance Deadline: January 1, 2017 Policy Statement:
| Eldercare Home Health will comply with the accessibility requirements of the Design of Public Spaces Standards when redeveloping or constructing new public spaces on or after January 1, 2017 |
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Eldercare Home Health is not currently responsible for redeveloping or constructing any of the public spaces covered by the Design of Public Spaces Standards. However, should Eldercare Home Health have such responsibility in the future it will ensure compliance with the requirements of the IAS.
15. QUESTIONS ABOUT THE POLICY OR ACCESSIBILITY PLAN
For more information about the Policy or Eldercare Home Health’s Accessibility Plan please contact: