A Comparative Analysis of Barrier-Free Housing: Policies for Elderly People in the United States and Canada

Peter A. Dunn, PhD, 1997
Associate Professor, Faculty of Social Work, Wilfrid Laurier University, Waterloo, Ontario, Canada N2L 3C5.

SUMMARY. This paper identifies policy issues in creating barrierfree housing for elderly people with disabilities in the United States and Canada. A range of policy options are described including: government housing construction; housing vouchers and certificates; community service programs; grants, loans and reimbursements; building codes and regulations; and human rights legislation. The strengths and weaknesses of these policy approaches are contrasted. The present emphasis in the United States is on individual housing rights compared with a more social welfare approach in Canada. Finally, one possible comprehensive model is described and practical next steps are outlined for making the housing environment more responsive to the needs of elderly people with disabilities. [Article copies available for a fee from The Haworth Document Delivery Service: 1-800-342-9678. E-mail address: getinfo@haworth.eom]

INTRODUCTION

Housing adaptations are one of the key supports which enable older people to remain in their own homes and lead more independent lives (Gutman & Blackie, 1986). Modifications such as grab bars, handrails and ramps can assist elderly people to be more self-sufficient in their homes (Sherwood, 1981), enable them to get outside and be more active in the community (Dunn, 1990a) and even help in reducing the likelihood of institutionalization (Ratzka, 1984). However, policies and programs which promote accessible housing in many countries have been insufficient, uncoordinated and not very comprehensive. This paper will examine the need for barrier-free housing for elderly people in the United States and Canada, contrast the policy models which have been formulated in these countries and discuss a future framework for policy development. The United States and Canada were selected for analysis because, despite many similar needs of elderly people in these adjacent countries, two distinct policy models have evolved in these countries. This paper will compare the housing rights emphasis of the United States with the social welfare approach in Canada (Anderson, 1989).

Recent research studies have indicated the potential social and economic benefits of adapted housing (Chollet, 1979; Sherwood, 1981; Ratzka, 1984; Dunn, 1990a). Although the potential benefits of housing adaptations may be substantial, home modifications can often be made at a very reasonable cost. Project Open House, a program which adapts housing in New York City, spent an average of only $1,500 in 1986 to adapt existing homes of their clients. In fact, research has indicated that older people often require only small adaptations such as handrails and grab bars which are relatively inexpensive (Dunn, 1990a). The costs of adapting housing prior to construction are even less expensive than retro-fitting homes. In addition, units can be constructed to be "adaptable" to the individual needs of residents. For example, doors and corridors can be made wider, counters adjustable and bathrooms designed so that grab bars can be easily installed. Adaptable housing can be constructed so that everyone can use this universal design and the adaptation features are blended in inconspicuously.

A substantial number of elderly people in both the United States and Canada require barrier-free housing. Struyk (1982) found in his analysis of data from the 1978 U.S. Annual Housing Survey that out of 15 million elderly-headed households, approximately 8.6 million (57%) had a major health problem or mobility limitation. He estimated that approximately I million elderly households still needed housing adaptations. Dunn (1990b) determined in his analysis of data from the 1986 Statistics Canada's Health and Activity Limitation Survey that out of the 2.7 million elderly persons in Canada living in the community, 1.03 million (46%) had a physical, developmental or mental disability. Canada has a population approximately one-tenth of the United States. Roughly 33% of the 191,000 disabled elderly persons in Canada who required housing modifications did not have them. Although these surveys were undertaken at different times and utilized different definitions of disability and methods of calculating needs, they reveal that there is a sizeable number of elderly people in both countries who are disabled and require barrier-free housing. For the purposes of this paper, barrier-free housing will be considered as housing which is accessible and adapted to the individual needs of a person with a disability.

POLICY ISSUES

It is important to consider different housing policy approaches which can be undertaken to respond to this sizeable need. Donald Chambers (1986) explains that it is essential to consider the most effective form of benefit or service delivery when responding to a policy concern. However, he indicates that many social policies must pursue their objectives through multiple instruments or methods because of the complexity of social policy issues. In order to ensure a barrier-free housing environment for older people, several policy issues must be addressed. Housing policies must be developed to promote barrier-free housing in existing housing, new construction and rehabilitation. These policies may be different for private, public or non-profit housing as well as for single family homes or multi-unit construction. There are a number of other issues in formulating comprehensive barrier-free housing policies. For example, policies may have to deal with multiple jurisdictional levels of government and may need the support of public, private and voluntary sectors. In addition, the effective implementation of policies is also very important. Even the most progressive barrier-free guidelines can be problematic, if not implemented effectively.

Given the complexity of these issues, there are several policy approaches or options which government, non-profit and private organizations have undertaken to create barrier-free housing for elderly people. These policy options include: (1) Government Housing Construction Programs: national, regional or local governments can help finance or directly construct new housing for older people which is barrier-free including funding private, non-profit and/or cooperative housing agencies to develop new accessible housing; (2) Housing Vouchers: organizations can provide vouchers or certificates for elderly people to obtain and to pay for existing adapted housing units; (3) Community Service Approach: agencies can assess the housing needs of their clients and adapt existing housing units for qualified clients; (4) Grants, Loans and Reimbursements: government agencies can provide grants and loans directly to homeowners, tenants and/or landlords to adapt existing dwellings or health care insurance organizations can reimburse consumers for adapting their existing homes; (5) Building Codes and Regulations: different levels of government can ensure that new housing is barrier-free through enacting building codes and regulations; and (6) Human Rights Legislation: governments can establish legislation that prohibits discrimination against people with disabilities and requires that housing accommodate their disability. Figure I adapts a general matrix developed by Chambers (1986) to classify these policy options for barrier-free housing.

THE UNITED STATES RESPONSE

The United States has undertaken a number of different approaches which create more barrier-free housing. One of the major U.S. responses has been the financing of public housing for the elderly. These programs have increasingly emphasized barrier-free units, so that individuals can age in place. For example, the U.S. Department of Housing and Urban Development (HUD) has paid for the construction and some of the operating costs of public housing units for people with low incomes. These public housing projects are operated by over 3,300 local public housing authorities throughout the U.S. The local housing authorities provide housing in some projects for people of all ages; some projects have certain units designated for the elderly and some projects are entirely for elderly people. By 1990 there were 1.2 million federally supported, low-rent public housing units which were occupied, and approximately 40% or 482,000 units had elderly tenants (Special Committee on Aging, 1991). However, only about 25,000 new public housing units were constructed from 1986 to 1990 including 11,000 units for the elderly. Federal funding for the construction of new public housing units has virtually ended (HUD, 1990).

FIGURE 1. Policy Options for Barrier-Free Housing

HUD's loan and assistance programs have been the major instrument for developing housing for elderly and handicapped persons. The Section 202 Direct Loan Program, which began in 1959, is HUD's primary program for producing housing for the elderly. This program has provided loans to community based non-profit organizations to construct or rehabilitate housing for the elderly. From 1974 to 1990, approximately 226,000 units were constructed for elderly people under this program. However, this program has been dramatically reduced with only 40,000 units being constructed from 1986 to 1990. HUD also operated the Section 231 and 236 programs which provided mortgage insurance programs for people with low incomes including the elderly, but these two programs were terminated in 1974. Approximately 66,700 units were constructed for elderly people under Section 231 and 82,170 units under Section 236. In addition, the Section 221 Mortgage Insurance Program for Multi-family Housing has created 155,734 units for elderly tenants of all incomes. Since 1981 HUD has dramatically reduced its budget for new construction. Section 202 is virtually the only new construction program currently being funded by HUD, albeit on a greatly reduced basis (HUD, 1990). In response to the dramatic decrease in federally sponsored housing programs, some state governments have created a range of innovative and cost-effective housing options for older people such as congregate housing, home equity conversions and homesharing.

There is no available data about what percentage of the federally sponsored housing units are barrier-free. However, in 1968 Congress passed the Architectural Barriers Act which required that federal government construction be accessible. The Rehabilitation Act of 1973 created the Architectural and Transportation Barriers Compliance Board under Section 502 to enforce this law and also required under Section 504 that all existing and new federally-funded programs be accessible in both the public and private sectors. Initially, HUD referred developers to the ANSI standards for accessibility, then HEW guidelines and then the Uniform Federal Accessibility Standards. However, it took HUD 15 years to finalize and publish its own requirements for Section 504 which requires that at least 5% of all federally-funded housing be accessible for people with mobility limitations and that 2% of housing be accessible for people with visual and hearing impairments. In addition to these overall regulations which HUD adopted to respond to civil rights legislation, regulations have been formulated for specific programs such as the Section 202 program.

Since the early 1980s, HUD has placed increasing emphasis upon housing subsidies and vouchers for elderly people, rather than constructing new housing for the elderly. The Section 8 Existing Housing program includes a certificate program which pays the difference between 30 percent of a tenant's income and the fair market rent. Older people can use the Section 8 certificate program to seek an affordable barrier-free housing unit. In 1983, a housing voucher program was created which is similar to the certificate program; however, the actual rent is negotiated by the tenant and landlord and the amount of subsidies are more limited. The tenant receives 30% of their income for rent regardless of the actual cost of the rent. In 1990, approximately 945,000 units were reserved for the certificate program and 250,000 for the voucher program. Roughly 46% of the certificate program funds were for elderly or handicapped individuals. Advocates of the certificate and voucher systems feel that these programs will avoid segregation and warehousing of poor people and allow individuals choices; however, others argue that there is already a critical shortage of housing for elderly people; landlords just increase rents because they know that tenants have additional funds available and very few new barrier-free housing units will be created through these demand-sided programs (Special Committee on Aging, 1990).

In addition, government and non-profit agencies adapt homes of disabled people. However, these approaches are piecemeal at best. Many of these community services have been geared primarily to assist younger adults to live more independently, to get out of their homes and to be employed. These programs are often not based upon individual need, but upon the category of service for which an individual qualifies. For example, individuals who qualify for the Veteran's Administration program might obtain renovations up to $35,000, while someone with similar needs on Medicaid might have few or no adaptations covered under this program (Dunn, 1986). In addition, some agencies provide small repairs and modifications using funds from the Older Americans Act for home supports (Hyde, 1989).

Grant, loan and reimbursement programs are even more sporadic and piecemeal in the United States. The U.S. does not have a comprehensive national grant and loan program which provides money for people to adapt their homes, even for individuals with low or moderate incomes. One exception is the Farmers Home Administration program which may provide low interest loans to rural homeowners aged 65 and over (up to $80,000) and grants (up to $5,000) for needed home adaptations. Some states such as Massachusetts have provided low-interest deferred loans to low-income homeowners through state bonding agencies for home repairs and adaptations. In addition, municipalities such as New York City and Oakland, California have used federal Community Development Block Grants for this purpose. Nevertheless, most elderly people are not covered by these programs (Dunn, 1986). Health care reimbursements such as Medicare do not fund home adaptations, although they will cover the expenses of durable medical equipment such as wheelchairs and walkers. Medicaid provides a broader response of reimbursements than Medicare. Several states have used the Medicaid waiver provisions to cover some housing adaptations although these programs vary considerably between the states. These adaptations must be cost-effective and reduce the need for a more restrictive, or costly setting. Private insurance companies with a few exceptions typically do not pay for adaptations and only if "its use is consistent with the insurer's obligations of maintaining/restoring a beneficiary's health and is perceived to be cost-effective" (Hyde, 1989, p. 4).

States may enact building codes to regulate the standards of new housing. States have gradually adopted barrier-free housing standards for new multiple unit construction or renovation projects. Usually building plans are approved for accessibility before construction. However, a 1979 survey found that state standards were very different and specific administrative and enforcement methodologies were often ineffective. Some architects might technically comply with state regulations, but because many architects are not committed to accessibility, these modifications are often inadequate (American Bar Association, 1979).

The policy approach which has recently had a major impact upon making present and future housing accessible in the United States is disability rights legislation. The 1973 Vocational Rehabilitation Act and its amendments established the framework for disability rights in the U.S. The Fair Housing Amendments Act (FHAA) of 1988 focused specifically upon housing discrimination and accessibility. It amended Title VIII of the Civil Rights Act of 1968 to add people with disabilities and families with children, so that they will not be discriminated against in terms of housing. From 1991, all new buildings with four or more units including public, private and non-profit housing have been required to be accessible according to new design criteria. This Act sets out specific design criteria including several adaptable housing features. Although this legislation is based upon individual complaints, it will also help bring state accessibility codes up to a national standard. States that wish to enforce these regulations and receive HUD funding for this purpose must legislate accessible state housing building codes which are at least substantially equal to FHAA's codes and regulations. The law also states that landlords must allow a person with a disability to make architectural modifications to an apartment (Disability Law Center, 1989). In 1990, the Americans with Disability Act (ADA) extended civil rights protection for people with disabilities in areas other than housing.

THE CANADIAN RESPONSE

In Canada, under the 1867 British North America Act, the responsibility for housing was delegated to the provinces. Because of this constitutional arrangement, it has been difficult for the federal government in Canada to initiate comprehensive barrier-free housing policies across the country. The federal government initiatives are embodied in the National Housing Act (NHA) and implemented by Canada Mortgage and Housing Corporation (CMHC). CMHC has chosen to influence housing through financial mechanisms such as grants, loans and insurance arrangements. CMHC has increasingly delegated these financial initiatives to the provinces in recent years (Gross, 1985).

From the inception, specific housing programs for the elderly were not singled out. In 1949 under the federal-provincial partnership agreement (Section 40), the federal government provided 75% of the capital and operating costs for public housing including housing for older persons, while the provincial and some municipal governments paid 25% of the costs. In 1964, the public housing program expanded rapidly when the federal government agreed to pay up to 90% of the capital costs (Section 43) and cost-shared operating expenses at 50-50 (Section 44) with the provinces and municipalities. However, the public housing program was discontinued in 1979 after constructing over 200,000 units, one-half of which were designated for the elderly. Partially because of the negative image of public housing, CMHC replaced this program with the Section 56.1 Social Housing Program. Under this program, CMHC provides insurance and subsidies to provinces and municipalities and non-profit organizations such as churches or co-operatives to construct non-profit units and co-operative houses including units for elderly people. The Social Housing program has been modified in recent years. Under the existing federal-provincial agreement the provinces can elect to administer any of these programs except the federal co-operative housing program which has been administered and financed by the federal government (Goldblatt, 1989).

Many of the earlier public housing units designated for elderly people were not fully adapted. Decisions regarding accessibility were primarily left to the provinces and local housing authorities. However, in 1981 in response to the International Year of the Disabled, CMHC began to require that at least 5% of all new federally financed units be accessible. CMHC has not yet adopted a policy of adaptable design for all units; however, CMHC is presently undertaking research in this field. There are approximately 250,000 federally funded elderly housing units. Roughly half are non-profit and co-op units and the balance are public housing stock. In the five years between 1986 and 1990, the Social Housing Program produced 46,524 units of which 19,573 units were for the elderly including 5,669 units which were modified for their needs (CMHC, 1991).

CMHC has instituted a rent supplement program which is cost-shared on a 75-25 basis with the provinces. The provincial governments subsidize specific units for lower-income recipients in non-profit, co-operatives, limited-dividend projects and in some private buildings. Individuals who receive rent supplements pay the same rents as they would in public housing. However, the Canadian government has not adopted a housing voucher or certificate system similar to the United States in which individuals seek out their individual housing unit (Gross, 1985).

Some provincial departments and non-profit organizations in Canada undertake minor housing modifications for their clients. However, this service approach is less emphasized in Canada than in the United States because of the fairly extensive federal and provincial programs which provide grants and loans for modifications to existing housing.

The real strength of the Canadian model is found in the federal and provincial grant and loan programs for disabled people to modify their existing housing. The federal Residential Rehabilitation Assistance Program (RRAP) was developed in 1973 as a general home improvement program for people with low to moderate incomes whose homes needed repairs and who lived in designated neighbourhood improvement areas. In 1981 this program evolved to include grants and loans for housing adaptations. In 1986, CMHC developed RRAP-D for disabled people with low to moderate incomes. This program provides individuals in need with a total of $10,000 in loans, including up to $5,000 in grants depending upon their income, to modify their homes. Individuals can also apply for RRAP funds for general renovations to their homes. From 1974 to 1990 the RRAP program helped renovate approximately 220,060 units, of which approximately 86,200 were homes of elderly people. Between 1986 and 1990, approximately 24% of 14,700 individuals who received loans and grants under the RRAP-D program were elderly people. CMHC also provided grants to landlords to make adaptations up to $5,000 for self-contained units and $2,500 per bedsitting unit, if the landlord brought the building up to standards and agreed to rent ceilings for 15 years. However, this program was discontinued in 1989 (CMHC, 1991).

Many of the provinces also provide grants and loans for home adaptations. Some of these programs were initiated to cover geographic areas which did not qualify for the earlier federal RRAP program. Some target certain groups in need such as elderly people who are frail. These programs provide a diversity of benefits from $350 to $15,000 to help people with home repairs and often with home modifications. For example, the Ontario Home Renewal Program for Disabled People (OHRP-D) was developed for people with disabilities regardless of income. Loans are provided up to $15,000 for home adaptations and all or a portion of this loan may be forgiven, dependent upon income (Ontario Ministry of Housing, 1986). It is important to note that despite Canada's extensive government health care system, most provincial health insurance programs do not cover housing adaptations, but they may cover assisted devices such as hearing aids, glasses, canes, walkers and wheelchairs.

Every five years the National Research Council (NRC) updates the National Building Code which acts as a guideline for the provinces as they revise their building codes for new construction and renovation of apartment buildings. In 1975 the National Building Code included accessibility requirements (Ontario March of Dimes, 1990). Nevertheless, according to the powers of the British North America Act, the provinces develop their own housing codes. The provinces of Newfoundland and Prince Edward Island do not have provincial building codes. Yet, the provinces have increasingly ensured that new apartment buildings are accessible. However, the extent of accessibility and adaptability varies between provinces. Generally, the provinces have established standards which ensure that private apartment buildings are accessible and that a certain percentage of units, usually 5%, are barrier-free.

The Canadian government has not developed extensive civil rights legislation for people with disabilities as in the United States. However, when Canada repatriated its Constitution from Britain in 1982, it established the Charter of Rights and Freedoms. Section 15 of this bill of rights prohibits discrimination on the basis of mental or physical handicap. As a result, Canada is the first nation to have in their constitution a section prohibiting discrimination based upon handicap. Since this legislation was implemented, several far-reaching cases have been brought before the Supreme Court. These cases have expanded the protection of individuals with disabilities including older Canadians. Nevertheless, this Act has not been implemented into specific enforceable legislation such as the FHAA and ADA in the United States. Some disability advocates have prepared a federal omnibus bill which could amend existing pieces of federal legislation to incorporate anti-discriminatory provisions (Standing Committee on Human Rights, 1990). In addition, some of the provinces have revised their human rights codes to incorporate clauses prohibiting discrimination against disabled people in order to conform with the Charter of Rights and Freedoms. In 1989, Ontario led the provinces in establishing "Guidelines for Assessing Accommodation Requirements for Persons with Physical Disabilities," which allow individuals with disabilities to complain to the Ontario Human Rights Commission, if they do not feel that their environment adequately accommodates their disability, including their housing. Although these guidelines established major rights, these provisions primarily depend upon individuals to initiate complaints (Ontario Human Rights Commission, 1989).

DISCUSSION

The policy responses in the United States and Canada are similar in some respects, but also represent very different models which reflect different ideologies and jurisdictional arrangements in these countries. Both countries have emphasized the importance of housing options for seniors with different needs and the increasing role of state and provincial governments. Barrier-free requirements have been instituted in both countries for new publicly-financed housing including accommodation for elderly people. However, the U.S. has increasingly moved into a demand-sided voucher system and out of financing new construction even for elderly people. In addition, HUD's budget was dramatically reduced by 57% from 1980 to 1987, including basic programs for rental assistance for elderly and handicapped persons (Schwartz, Ferlanto & Hoffman, 1988). Therefore, despite progress in implementing barrier-free requirements for new public housing, there are far fewer new barrier-free units being constructed in the United States for elderly people. In contrast, CMHC continued to fund the children, so that they will not be discriminated against in terms of housing. From 1991, all new buildings with four or more units including public, private and non-profit housing have been required to be accessible according to new design criteria. This Act sets out specific design criteria including several adaptable housing features. Although this legislation is based upon individual complaints, it will also help bring state accessibility codes up to a national standard. States that wish to enforce these regulations and receive HUD funding for this purpose must legislate accessible state housing building codes which are at least substantially equal to FHANs codes and regulations. The law also states that landlords must allow a person with a disability to make architectural modifications to an apartment (Disability Law Center, 1989). In 1990, the Americans with Disability Act (ADA) extended civil rights protection for people with disabilities in areas other than housing.

THE CANADIAN RESPONSE

In Canada, under the 1867 British North America Act, the responsibility for housing was delegated to the provinces. Because of this constitutional arrangement, it has been difficult for the federal government in Canada to initiate comprehensive barrier-free housing policies across the country. The federal government initiatives are embodied in the National Housing Act (NHA) and implemented by Canada Mortgage and Housing Corporation (CMHC). CMHC has chosen to influence housing through financial mechanisms such as grants, loans and insurance arrangements. CMHC has increasingly delegated these financial initiatives to the provinces in recent years (Gross, 1985).

From the inception, specific housing programs for the elderly were not singled out. In 1949 under the federal-provincial partnership agreement (Section 40), the federal government provided 75% of the capital and operating costs for public housing including housing for older persons, while the provincial and some municipal governments paid 25% of the costs. In 1964, the public housing program expanded rapidly when the federal government agreed to pay up to 90% of the capital costs (Section 43) and cost-shared operating expenses at 50-50 (Section 44) with the provinces and municipalities. However, the public housing program was discontinued in 1979 after constructing over 200,000 units, one-half of which were designated for the elderly. Partially because of the negative image of public housing, CMHC replaced this program with the Section 56.1 Social Housing Program. Under this program, CMHC provides insurance and subsidies to provinces and municipalities and non-profit organizations such as churches or co-operatives to construct non-profit units and co-operative houses including units for elderly people. The Social Housing program has been modified in recent years. Under the existing federal-provincial agreement the provinces can elect to administer any of these programs except the federal co-operative housing program which has been administered and financed by the federal government (Goldblatt, 1989).

Many of the earlier public housing units designated for elderly people were not fully adapted. Decisions regarding accessibility were primarily left to the provinces and local housing authorities. However, in 1981 in response to the International Year of the Disabled, CMHC began to require that at least 5% of all new federally financed units be accessible. CMHC has not yet adopted a policy of adaptable design for all units; however, CMHC is presently undertaking research in this field. There are approximately 250,000 federally funded elderly housing units. Roughly half are non-profit and co-op units and the balance are public housing stock. In the five years between 1986 and 1990, the Social Housing Program produced 46,524 units of which 19,573 units were for the elderly including 5,669 units which were modified for their needs (CMHC, 1991).

CMHC has instituted a rent supplement program which is cost-shared on a 75-25 basis with the provinces. The provincial governments subsidize specific units for lower-income recipients in non-profit, co-operatives, limited-dividend projects and in some private buildings. Individuals who receive rent supplements pay the same rents as they would in public housing. However, the Canadian government has not adopted a housing voucher or certificate system similar to the United States in which individuals seek out their individual housing unit (Gross, 1985).

Some provincial departments and non-profit organizations in Canada undertake minor housing modifications for their clients. However, this service approach is less emphasized in Canada than in the United States because of the fairly extensive federal and provincial programs which provide grants and loans for modifications to existing housing.

The real strength of the Canadian model is found in the federal and provincial grant and loan programs for disabled people to modify their existing housing. The federal Residential Rehabilitation Assistance Program (RRAP) was developed in 1973 as a general home improvement program for people with low to moderate incomes whose homes needed repairs and who lived in designated neighbourhood improvement areas. In 1981 this program evolved to include grants and loans for housing adaptations. In 1986, CMHC developed RRAP-D for disabled people with low to moderate incomes. This program provides individuals in need with a total construction of a considerable number of new units of elderly social housing through the 1980s.

Another major difference in the policy approaches in the United States and Canada is that the U.S. has depended upon a patchwork of uncoordinated government and voluntary agencies to adapt existing homes. This model is consistent with the emphasis in the United States upon voluntary charitable services. In contrast, Canada has developed a national grant and loan model in which disabled people with low to moderate incomes are given funds to adapt their homes. This model is reflective of a British universal social welfare tradition. However, neither country has significantly expanded their health care systems to cover home modifications. Medicaid perhaps has been the most responsive program. Nevertheless, home adaptations continue to be considered primarily as a housing service and not as a mechanism to promote health and to reduce accidents and eventual hospitalization of elderly people with disabilities.

Both countries have increasingly had their building codes modified to include barrier-free design for new private multi-unit construction and renovations. These codes are primarily formulated at the state and provincial levels. There are considerable variations in the codes within both countries; however, the evolution has been towards a more unified national response. The United States has dramatically moved in this direction with the Fair Housing Act Amendment which requires that all new multiunit buildings adhere to basic barrier-free guidelines, while Canada still depends upon national codes which provinces may adopt on a voluntary basis.

The strength of the U.S. model is the expansion of disability rights. The FHAA has significantly expanded the role of the federal government to not only ensure that federally-funded housing be barrier-free, but also to cover private and non-profit apartment buildings and to prohibit any form of housing discrimination against disabled people. It builds upon a system of civil rights in the United States. Although the law operates upon a complaint basis, many states are also ensuring that their building codes comply with this legislation. Canada's civil rights legislation is not as comprehensive or prescriptive. Although the guidelines adopted by the Ontario Human Rights Commission are closer to the U.S. rights-based legislation, these guidelines are just for Ontario and they do not prescribe specific housing standards for accessibility which must be adopted in building codes. Other provinces may follow Ontario's lead, but very divergent regulations and coverage may be created across Canada. One of the major problems of creating national accessibility legislation in Canada is that its Constitution clearly delegates the responsibility for housing to the provinces.

The barrier-free housing policies which have been developed in the United States and Canada reflect the ideologies of these countries and jurisdictional arrangements. Despite specific actions of individuals and pressure groups, these housing policies have evolved to reflect prevalent national ideologies. The present federal policies in the U.S. are consistent with the anti-collectivist U.S. ideologies outlined by George and Wilding (1985) which emphasize a limited government role in providing services, the use of vouchers and voluntary services for the very needy and the promotion of individual rights. The Canadian policies reflect more of a reluctant collectivist ideology with a substantial role for government in providing services, including a safety-net in the form of housing adaption loans and grants to ensure homes are barrier-free.

CONCLUSIONS

There does not appear to be one policy option which can ensure a barrier-free housing environment for all disabled elderly people in need because policies must respond to several different types of housing. For example, civil rights legislation such as FHAA can dramatically affect new construction; however, this legislation cannot help poor individuals to renovate their own homes. Grant and loan programs or voluntary services have a greater potential for helping these individuals. Policy options for each housing sector must be carefully considered in relation to effectiveness, costs and the empowerment of consumers. These policies must effectively address existing housing, new construction, and rehabilitation in the private, public and non-profit sectors.

One overall approach that the author feels has considerable potential is to combine the strengths of both rights-based legislation and comprehensive social welfare programs with the concepts of universal adaptable design (see Figure 2). Strong rights-based legislation and regulations could be adopted at the federal and/or regional levels such as the FHAA. Such legislation could ensure a social right for disabled individuals to have barrier-free housing and to provide a framework for other policy responses. This legislation could require that all new accommodation be barrier-free with very specific enforceable universal design standards, ensure that tenants could modify their own units and that disabled people would not be discriminated against in terms of any housing issues. In addition, it is important that housing codes be established which emphasize adaptable/universal housing design for all new construction and rehabilitation. Such adaptable housing codes can ensure that housing can be easily adapted to people's changing needs. It is also important to consider ways in which adaptable design can be incorporated into the construction of new family homes. More publically funded barrier-free housing must also be constructed for seniors, especially because of the limited supply of housing and the dramatically increasing elderly population. A national universal program could be established to modify existing housing of tenants as well as homeowners in public, private and non-profit housing. Consumer control and involvement should also be encouraged. Elderly people can play an important role along with architects and designers in developing the plans for any new housing construction or renovations of existing buildings. Finally, consumers need to be informed about existing programs and their rights. One of the major reasons why many older people do not take advantage of housing adaptation programs is that they do not know about these programs and cannot obtain contractors to modify their homes (Dunn, 1985).

FIGURE 2. A Comprehensive Policy Approach

(COMPREHENSIVE HOUSING POLICIES)

1. NATIONAL RIGHTS TO ACCESSIBLE HOUSING
(For Individual Issues and to Guide Policy)

2.UNIVERSAL ADAPTABLE HOUSING CODES AND PROGRAMS
(For New Construction and Renovations)

3. A NATIONAL COMPREHENSIVE HOUSING ADAPTATION PROGRAM
(For Existing Housing and to Act as a Safety Net)

(COMMUNITY INVOLVEMENT AND CONTROL)

4. COMMUNITY INFORMATION ON HOUSING RIGHTS
(Information on Seniors' Rights and Programs)

5. CONSUMER INVOLVEMENT IN SERVICES
(Involve Seniors in Policies, Housing Adaptation Services and Management)

One of the next steps for the United States is to place priority on developing a more comprehensive grant and loan program for disabled people to modify their accommodation. Perhaps the next practical step in the United States would be to expand the Medicaid and Medicare systems to cover the costs of housing adaptations. A more comprehensive approach would be to initiate a national grant and loan program funded by HUD. The recent U.S. National Affordability Act of 1990 could be amended to include a provision for home modifications. In Canada, housing rights legislation needs to be expanded for people with disabilities. Any new Canadian disabilities rights bill should address the development of a national barrier-free housing standard. National legislation or consistent provincial legislation which is negotiated between the provinces and the federal government must ensure universal adaptable housing design in all newly constructed housing units similar to the FHAA legislation.

Nevertheless, every country has its own unique issues, jurisdictional arrangements and ideological approaches to social policy development. Each country will have to build upon their strengths in order to develop effective and comprehensive barrier-free housing policies.

POSTSCRIPT

The information for this paper was gathered in 1990. Since that time there have been considerable changes in housing policies for the elderly, especially in Canada. Not only has Canada been dramatically affected by a worldwide recession, but the free-trade agreement with the United States has severely increased unemployment as many manufacturers have moved to the United States where minimum wages are lower and labour laws less strict. At the same time the federal and provincial governments have been cutting public spending in order to reduce corporate taxes and transferring taxes from corporations to personal and sales taxes, so that corporations can be more competitive with businesses in the United States (Hurtig, 1991).

Over the last few years, the federal Conservative government in Canada has been slowly reducing its commitment to social housing. However, in 1992 the Canadian federal government radically changed its policies by instituting a cap on the growth of all new social housing expenditures, including for the elderly. This policy has meant a reduction of approximately 20% in 1992 and 30% in 1993 for new housing commitments including RRAP-D, the national program of home modifications. In 1994 the federal government plans to freeze the social housing budget which will mean the end of the national housing modification program, and curtail funding for any new social housing in Canada, unless additional internal savings can be generated by CMHC. One positive development is that CMHC has implemented Home Adaptations for Seniors' Independence (HASI) across Canada. This two-year demonstration program provides low income elderly people 65 years and older with up to a $2,500 grant to pay for minor housing adaptations. CMHC allocated grants to adapt 3,800 housing units of elderly people over these two years across Canada. However, this program may not be continued past March 31 st, 1994, depending upon the outcome of an evaluation and whether or not CMHC can generate any internal savings to pay for this program (CMHC, 1993).

In terms of barrier-free housing, there have been less changes in the United States than Canada in the last two years. Dramatic cutbacks in federal housing expenditures in the United States occurred ten years before those in Canada. Very little new federal housing for the elderly is being constructed in the United States. However, more states are using Medicaid waivers to cover housing modifications for the elderly. Plus, reverse mortgages are becoming more widespread for the elderly, so that they can take out some of the equity in their homes to modify their premises.

With the present ideology of cutting back government expenditures in both countries, a housing rights model may become increasingly useful in Canada as well as in the United States. Housing rights legislation can require that existing as well as new housing be barrier-free. Nevertheless, both countries need to construct more new barrier-free housing units for the elderly and provide a national housing adaptation program for existing homes in order to create an effective national barrier-free policy response.

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