Thank you.
I'll begin with a list of recommendations up front. I always like to lead with those first, in case we run out of time.
People with disabilities should have rightful entitlement protection from unfair fees charged by financial promoters. The disability tax credit has become the gate for determining eligibility for a variety of benefits. Thus, we must ensure unencumbered and fair access. The disability credit becomes more commonly used as a determinant of eligibility for other federal benefits, and there's a need to review the forms and the process of establishing eligibility.
Removing barriers for people living with mental health disability in the section entitled, “mental functions necessary for everyday life” has changed markedly from previous years. There is a need to address issues posed by people with episodic disabilities, as the criteria do not help account for the waxing and waning of symptoms within an overall picture of disability.
The Council of Canadians with Disabilities and DisAbled Women's Network Canada believe disability organizations should be supported as part of Minister Finley's interest in social financing to assist people to complete applications for disability tax credit, CPPD, and other relevant government programs. The disability tax credit should be made refundable for those who do not have a taxable income but experience additional costs related to their disability. Now that the disability tax credit has multiple purposes, eligibility must be considered in relation to those who should be eligible for other benefits, such as the RDSP.
The Government of Canada needs to do a broader review of tax measures for people with disabilities to create greater access and fairness. Streamlined process and strategy should allow people to have greater access to programs, clear policies, and forms available online to create savings that can be directed to increased benefits and programs for disabled people. Make the CPPD, disability tax credit, and other federal government forms ones you can save as you work through them. Review the “other qualified professionals” list of who can sign a disability tax credit application. Prohibit billing above a set amount for forms for any provincial, federal, or municipal government program by either professionals or for-profit companies. Protect people from exploitation and outright financial abuse by ensuring some standards for industry promoters and financial advisors of people with disabilities.
I'll now begin the body of my text. I simply like to lead with the recommendations for fear of being cut off.
Good morning. We thank you very much for consulting with us today. We wish to acknowledge the Algonquin peoples as we meet on the traditional lands we share.
It's my privilege and responsibility to speak on behalf of both the Council of Canadians with Disabilities, on which I serve as a member-at-large of the executive committee, and as president of the DisAbled Women's Network Canada.
CCD and DAWN support the intent of Bill C-462 and agree that people with disabilities should have their rightful entitlement protected from unfair fees charged by financial promoters. Disability tax credit eligibility is a critical issue for people with disabilities, as it has become the gate for determining eligibility for a variety of benefits. Thus, we must ensure unencumbered and fair access. In addition, we also recognize that determining eligibility for the disability tax credit can be complex. An inequity exists because it's much easier to provide evidence of a physical or sensory disability than it is to provide evidence of a cognitive learning, intellectual, or mental health disability. In some cases, the cost of diagnosis is considerable, and in other instances access to professionals able to make this determination is limited. The disability tax credit, in its current iteration, has created barriers for people living with mental health disability in the section entitled, “mental functions necessary for everyday life”, which has changed markedly from previous years.
The reality is that the definition and understanding of disability is always changing. Medical conditions are also changing and emerging as new discoveries are made. It is recognized that some disabilities are episodic in nature. As the disability tax credit becomes more commonly used as a determinant of eligibility for other federal benefits, there's a need to once again review the forms and the process of establishing eligibility.
The disability tax credit was initially designed as a tax fairness measure, recognizing that people with disabilities have additional disability-related expenses. Disability tax credit eligibility is now the determinant for accessing other benefits and programs, such as the registered disability savings plan, the child disability tax benefit, the working income tax benefit for persons with disabilities, and the disability accommodation benefit in the Tax Act.