A version of this commentary appeared in Policy Options, Ottawa Life and Hamilton Spectator

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It’s time to look beyond the CRA

Breaking Down Barriers is the galvanising theme of a recent report from the Senate Standing Committee on Social Affairs, Science and Technology that outlines urgently-needed recommendations to improve access to underutilised federal disability supports: the Disability Tax Credit (DTC) and Registered Disability Savings Plan (RDSP).

Some of our most vulnerable members of society face multiple hurdles trying to get access to the DTC and the RDSP. This includes eligibility criteria that do not reflect the realities of living with a disability and are more strict for people with impairments in mental function compared to those with physical disabilities. It also means a burdensome application processes that can include hidden costs, arbitrary eligibility decisions and opaque claims and appeals processes.

For Canadians with disability, who are almost twice as likely to live in poverty compared to other Canadians, programs like the RDSP are critical. The RDSP helps people with severe disabilities and their families to save for the future and the idea of the program was hailed as one of the most progressive savings plans in the world. Yet the reality is less favourable: fewer than 15 per cent of Canadians with qualifying disabilities are accessing this program.

Bureaucracy is the greatest barrier that needs to be “broken down.” Accountability and measurable action by Minister Lebouthillier and Revenue Canada is long overdue.

Yet, it does not make sense that we are tasking staff at Revenue Canada with determining complex eligibility for much needed disability savings and income support programs in the first place. The Minister of Families, Children and Social Development and the Minister of Finance need to take accountability for the Senate recommendations.

The lived experience of the extreme fragmentation of programs and supports is significant.

If you are a Canadian living in low income with a severe disability, you have to prove your disability status to your provincial government to claim disability supports, and then “re-prove” your status to the federal government to gain eligibility to the DTC to set up an RDSP. Completing these applications is not without cost; people can pay hundreds of dollars to their physicians to complete an application form certifying their disability (in some cases every year) – a certification that is out of touch with global standards of disability determination.  As well, many bank branches simply do not support in-person set up of the RDSP.

It is unclear why anyone who meets the strict criteria for provincial disability supports would not be entitled to the DTC and RDSP. One of the recommendations in the Senate report is that everyone in a provincial program for people with disabilities be enrolled automatically in the RDSP.

For this to happen, collaboration between ministries and across different levels of government is needed. Yet, recommendations of this nature are not new in Canada. In the 1998 In Unison: A Canadian Approach to Disability Issues report, ministers agreed that “More effective and coordinated programs would better serve Canadians with disabilities and the country as a whole.”

That this statement holds as true today — two decades later — demonstrates that effective action has failed to follow this intergovernmental vision.

How can we turn this dismal lack of action around?  Can this current federal Liberal government make it happen?  Let’s hope so.

In the short-term, the federal government needs to mandate that the Ministry of Finance, Canada Revenue Agency and Employment and Social Development Canada enact the recommendations outlined in the Senate report, ensuring collaboration where required.

In the longer term, Canada desperately needs 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. This ministry should engage with provinces to determine how to best streamline federal and provincial disability supports.

Finally, all parties need to realise that the current system is working against Canadians with disabilities. Denying this already disadvantaged group access to the supports that they need — and are entitled to — works against our vision of an inclusive Canada.


Dr. Jennifer Zwicker is 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.  They are both Contributors with EvidenceNetwork.ca based at the University of Winnipeg. 

This work is licensed under a Creative Commons Attribution 4.0 International License.