Thank you for the invitation to present today.
The Canadian Psychological Association is the national association for psychology in Canada. There are about 18,000 psychologists in Canada, making us the country's largest group of regulated specialized mental health care providers.
I'm here today to highlight how the current language in the budget concerning the GST could lead to unintended consequences for Canadians seeking mental health treatment. If passed without clarification or amendment, Canadians will now have to pay taxes on certain psychological services that were once exempt.
Budget 2013 makes changes to the GST so that reports and services provided solely for non-health care purposes, even if supplied by health care professionals, are not considered basic health care and will not be eligible for exemption. It goes on to explain that taxable supplies would include reports, examinations, and other services performed solely for the purpose of determining liability in a court proceeding or under an insurance policy.
It is CPA's view that psychological assessments, even those that determine liability in a court proceeding or under an insurance policy, must be considered a basic health service. Let me explain why.
When it comes to the treatment of mental illness in Canada, privately insured services are the norm and not the exception. Psychological services are not covered by our provincial and territorial health insurance plans, and are paid out-of-pocket by taxpayers or through private insurance. Unfortunately, limits on private insurance coverage are frequently too little to allow for meaningful service.
Medical legal assessments and insurance assessments are used to determine the nature of a health problem and to recommend the type and length of the treatment required. These assessments are necessary to demonstrate that the person has met the eligibility criteria to access the service and to receive the funds to pay for it.
Determining liability in a court proceeding or under an insurance policy is therefore essential for many Canadians to gain access to the mental health treatment they need.
Here are a few examples. A child with a developmental disorder might need a complex psychological assessment to determine the nature of the disorder and identify his or her specific cognitive and behavioural needs. This identification may be necessary to establish eligibility for specialized care through insurance or other programs that might offer financial relief for this care.
In another instance, a Canadian may suffer health effects as a result of having been a victim of crime. They may have a brain injury or post-traumatic stress disorder for which they must seek the services of a psychologist to establish a claim for treatment in a civil suit. While the need for an assessment might be identified immediately after the incident, it is not unusual for it to be identified later on. Someone with a brain injury may present symptoms such as lack of initiative, problems with concentration, or trouble problem-solving, that can take some time to accurately identify and distinguish from other conditions. Recovery can take months or years, and symptoms may never fully resolve. With the proposed changes, not only would this person have to cover the costs for the assessment and any necessary treatment, they would now also have to pay GST.
Finally, when someone is hurt in a motor vehicle accident, they require approval from an insurer for a needed psychological assessment to be covered. If the request for the assessment is denied by the insurer—and this can happen even with a physician referral—an independent examination is then triggered. With the changes outlined in the budget, any psychological assessment that is ordered or delivered after an examination is triggered will no longer be considered basic health care and will be subject to GST. We strongly believe it should not be up to the insurer to decide whether or not an assessment has a health care purpose.
It's important to note that this isn't a pocketbook issue for psychologists. It's not the psychologists who will have to pay this tax. It's going to be hard-working Canadians who have a health need that is not met by Canada's publicly funded health care system.
It's CPA's position that an assessment or intervention, when delivered even in a medical/legal context, or when privately insured, is a necessary basic health service. There's some urgency for clarity, given that changes outlined in the budget are retroactive to March, 2013, and many psychologists are also small-business owners.
We have brought forward the following recommendations for the consideration of the committee: that the budget be amended to note that psychological assessments and treatments are a necessary health service, and that psychological assessments used to determine liability in a court proceeding or under an insurance policy are basic health services and should therefore remain GST-exempt.
Thank you.