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Non-Earner Benefits (“NEBs”) have been available to injured claimants through the Statutory Accident Benefits Schedule2 since the overhaul of Ontario’s no-fault automobile insurance system in 1990. NEBs serve as a means to compensate individuals for their loss of enjoyment of daily life by providing monetary support for their inability to engage in activities ordinarily performed prior to a motor vehicle accident.3 In theory, the provision of this benefit was one of the trade offs for the reduction of the right to sue in tort caused by the introduction of a threshold for pain and suffering damages and to provide some form of weekly compensation to those not attached to the workforce akin to the income replacement benefit.