(8,990). Although an amendment ratified in 2018 enabled government employees and teachers with disabilities to voluntarily retire in accordance with the conditions stipulated by the law, the MOL has failed to ensure equal access by persons with disabilities to retirement benefits and programmes in accordance with Article 28, Point 2(e) of the CRPD. Instead, the MOL maintains that it is unnecessary to amend the existing Labor Insurance Act because the Act already includes disability benefits, the Labor Pension Act allows for early payout of individual labor pension accounts, and retirees are able to voluntarily subscribe to the National Pension Insurance. This clearly does not comply with Points 70 b) and 71 b) of the Concluding Observations of the ROC's Initial CRPD Report. Pursuant to the committee meeting resolutions of February 8. 2021, the NHRC submitted a letter to the MOL on February 23, 2021 requesting the establishment of a reasonable retirement system for laborers with disabilities in accordance with Article 28 of the CRPD and Article 47 of the PDRPA. 126. Point 70 c) of the Concluding Observations of the ROC's Initial CRPD Report states persons with disabilities without a work history are eligible for only a disability pension under the national pension scheme which by itself is inadequate to cover basic food costs. The CRPD Second Report emphasized that the social security system in Taiwan comprises both social insurance and social welfare and assistance services and that social security is not measured solely by national pension payments. However, the NHRC found that between 2016 and 2019, the per-capita mental/physical disability pension payments and the guaranteed basic pension payments for mental/physical disabilities amounted to NT $4,872 per month, far lower than the minimum cost of living in 2019 for the various regions stipulated in the Public Assistance Act. 113 Therefore, the mental/physical disability pension payments and guaranteed basic pension payments for mental/physical disabilities stipulated in the National Pension Act are inadequate to cover the basic needs of persons with disabilities. 127. Point 251 of the CRPD Second Report only presented the proportion of households with persons with disabilities in public housing. This is inconsistent 113 The lowest was NT $11,135 for Fujian Province. The highest was NT $16,580 for Taipei City. The average for Taiwan Province was NT $12,388. 89