Resemblance and Relief: National Clustering and Social Assistance Provision—A Subnational Comparison

Abstract

Social assistance--cash and in-kind benefits provided to those deemed to be without the means for an adequate level of subsistence--has been a point of constant comparison between the United States and Canada. These comparisons have generally tended to point to Canada's generosity in contrast to the meager levels of assistance provided in the United States.(1) Not only is Canada's social safety net widely accepted as more generous than that found in the U.S., but Canadians are also generally thought to be more favorable toward social welfare per se than Americans.(2) Without debating the accuracy of such generalizations qua generalizations, they overlook important variations both among states and among provinces. In doing so, they also overstate the differences between the American states as a group and the Canadian provinces as a group. Broadly stated, Canadian provinces are far stronger political actors than are the American states. However, both states and provinces exercise important responsibilities in the provision of social assistance. In policy areas where states and provinces are significant actors, it is logically necessary, prior to making generalizations about national differences, to examine whether there is in fact some significant level of national clustering--whether policies in the various states tend to look more like policy in other states than in the Canadian provinces and vice versa. In the absence of strong consistent national clustering among subnational jurisdictions, differences in public policies across provinces and states cannot be meaningfully explained by reference to national or system-level characteristics.(3) An examination of social assistance provision in the states and provinces reveals that rather than one country being consistently more generous than the other, an alternative characterization emphasizes the continuing lack of strong national clustering. This paper, therefore, illustrates the need for considerable caution in overemphasizing national-level differences between social assistance provision in the two countries. Central Government Programs for Social Assistance Provision of social assistance by states and provinces has taken place within each country's respective federal framework and the differences in these frameworks have been significant. However, distinctive federal arrangements do not constitute presumptive evidence of national clustering among states and provinces in terms of how social assistance is actually provided. Under both federal systems, states and provinces continue to retain considerable latitude to provide assistance in the manner they see fit. This flexibility contributes to making careful consideration of national clustering among states and provinces necessary. In both the United States and Canada, jurisdiction over the provision of last resort aid to the needy is granted to the states and provinces. Provinces have jurisdiction over social assistance by virtue of the constitutional provision granting them exclusive jurisdiction over hospitals, asylums, charities and eleemosynary institutions [S.97, 7] which was buttressed by powers over `all matters of a merely local or private nature' (S.92, 16).(4) In the U.S., social assistance falls under the range of activities not expressly assigned to the federal government by the constitution and thus remains the prerogative of the states. Despite these similarities, there are significant differences between the jurisdictional frameworks in the two countries as they have evolved. While the federal governments in both countries have asserted their constitutional capacity to provide income-tested benefits directly to individuals by virtue of the federal spending power, the two countries differ regarding means-tested (income and asset-tested) benefits. Direct federal provision of means-tested benefits existing in the U.S. (for example, Supplemental Security Income for the aged, blind, and disabled) would not be constitutionally legal in Canada. …