How Canada is harming its most vulnerable citizens

The tangled web of disability governance and policy in Canada bodes poorly for Canadians with severe disabilities.

National Revenue Minister Diane Lebouthillier, standing during question period in the House of Commons on Parliament Hill in March, has tremendous powers in supervising the disability tax credit. Sean Kilpatrick, The Canadian Press

By Jennifer Zwicker, Stephanie Dunn, Toronto Star May 3, 2018

At a recent Senate committee hearing on the Disability Tax Credit (DTC) and the Registered Disability Savings Plan (RDSP), the father of a child with autism made a heartfelt plea and a chilling statement: “We are impacted by the inability to secure our son’s future. We are his sole social circle, we are his financial backers, we are his transportation — we are his life. My fears keep me awake at night.

If we don’t have something in place — a plan, a program, a support network — what will happen to my son when I’m gone? Institutionalized, neglected, or worse, homeless, with no love or supports — I need peace of mind and he needs a future.”

Who do you think this father should turn to in Canada to raise these important issues?
Minister of Revenue Diane Lebouthillier and the Canada Revenue Agency (CRA)? Probably not your first guess. Yet through their administration of the DTC our national tax agency is the unlikely gatekeeper of a number of important disability supports in Canada.

In February, Lebouthillier and CRA representatives appeared before the Standing Senate Committee on Social Affairs, Science and Technology to defend their highly criticized supervision of the DTC — a program that currently fails to reach most Canadians with qualifying disabilities, with take-up estimated to be only around 40 per cent of eligible working-aged adults.

Over the course of the hearings, disability advocates and Senators reiterated a broad range of concerns including poorly-defined and interpreted eligibility criteria, a complex application process, opaque appeals channels and the absence of adequate data to monitor the program.

While some of these issues can be addressed with more effective administration – for example, the CRA has yet to enforce the bill limiting third-party fees despite the bill being introduced four years ago – others are beyond the scope of the CRA.

Yet it is unclear which ministry is willing to address them. At the heart of this issue is the fragmentation of the governance of disability policy in Canada, leaving no single ministry with appropriate authority, decision-making ability and, importantly, accountability.

The CRA is responsible for administering federal disability tax measures, including the DTC and aspects of the RDSP. Finance has purview over the legislation underlying these tax measures (including the eligibility criteria for the DTC) via the Income Tax Act. The Minister for Sports and Persons with Disability is responsible for administrating the grants and bonds associated with RDSPs (for which the DTC is a prerequisite), in addition to its mandate around accessibility and overseeing the Office for Disability Issues.

This fractured governance and limited accountability bodes poorly for Canadians with severe disabilities, a group that faces high levels of unmet needs and significant barriers to accessing education, employment and achieving equal participation in society.

What needs to change?
If we are serious about wanting to improve outcomes for individuals with disabilities — and the federal government should make this a priority — accountability in governance of disability policy in Canada is needed.

A strong and empowered ministry that is directly responsible and accountable for the broad portfolio of disability policy, including both supports and rights-based legislation, is essential. This includes shifting the important task of disability assessment out of the CRA’s purview (and the Income Tax Act) and into a department under the disability ministry’s authority.

In the short term though, the CRA will continue to administrate key disability supports. To do this effectively it needs to recognize they are currently, de facto, one of the most powerful institutions involved in federal disability policy as the decision-maker for access to life-changing disability supports. This will involve both the will to address concerns around barriers to accessing the DTC, and engagement in meaningful collaboration with other ministries.

How Canada governs disability policy says a lot about who we are as a nation and what we value. Our current federal system suggests that we consider disability somewhat as an afterthought, scattered around and tacked on to other programs.

But if we value a society that encourages equality and full participation for people with disabilities — as we have agreed to when ratifying the United Nations Convention on the Rights of Persons with Disabilities — we need to do much better.

Dr. Jennifer Zwicker is an expert adviser with, a director of Health Policy at The School of Public Policy and Assistant Professor in the Department of Kinesiology at the University of Calgary.

Stephanie Dunn is a research associate in the Health Policy division at The School of Public Policy at the University of Calgary and an expert adviser with

Source Toronto Star

Also see
Disabled Canadians could be waiting months for money owed by Canada Revenue Agency in CBC News
Providing benefits not burdens in
It’s time for Canada to measure up on kids with disabilities in The Toronto Star
Why is the Canada Revenue Agency denying the Disability Tax Credit to those who need it most? in The Vancouver Province
Ottawa accused of new tax grab after disability tax credit clawback hits those with mental illness The Financial Post
Ottawa Carleton MP Poilievre Fights “Disability Tax” in Ottawa Life Magazine
Options for a Refundable Disability Tax Credit for ‘working age’ persons in Maytree
The disability tax credit: Why it fails and how to fix it in The School of Public Policy, University of Calgary
Additional living costs and barriers faced by families with children with disabilities: Evidence from the Participation and Activity Limitation Survey (PALS – 2006) in Government of Canada
Disability Tax Credit Public Consultations in Government of Canada
Disability Tax Fairness Campaign in
Bill C-462 (Historical) Disability Tax Credit Promoters Restrictions Act in
Disability Advisory Committee in Government of Canada

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