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Experiences with disability legislation are different between Canada and the United States, but both countries have experiences to share regarding trends and best practices, as well as challenges addressing the accessibility of public facilities, housing, and transportation for persons with disabilities. Based on this distinction, a literature review was conducted focusing on the similarities and differences between Canadian and American disability legislation, primarily for trends and best practices that have resulted in positive outcomes for people with disabilities. Three times as much literature exists on U.S. experiences based on disabilities legislation over the past two decades. One major reason is that the United States has federal legislation specific to disabilities (dating back to 1990) and Canada has none. The impact of federal legislation is seen across each American state. Without federal legislation in Canada, the provinces are left to implement their own, often different, practices. This country comparison includes gaps in practices and considerations for improvements.
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Burns et al. (2009) studied this question.
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