Thank you for the opportunity to speak about our recommendation that mental health counselling services be classed as zero-rated for HST and GST.
There are two issues here. One is around access to care. The second has to do with fairness in the labour market. I'll speak to the access to care issue first.
Typically an individual has to pay out of pocket to see a counsellor or psychotherapist. This is because counselling and psychotherapy are not publicly funded. Very rarely are they covered by third-party insurance programs. As a result, when an individual goes to a counsellor or psychotherapist, they have to pay out of pocket, which is a significant financial burden. On top of that, they have to pay the relevant taxes. In our opinion, that creates a significant barrier to accessing counselling and psychotherapy.
The second issue is around fairness. As you mentioned, in terms of mental health professions, all regulated professions are exempt from HST/GST. As a result, counsellors and psychotherapists, even though they are providing a very similar service—there are overlapping scopes of practices—are subjected to this tax that their colleagues, who are providing very comparable services but in different professions, are not having to pay.
From that perspective, our challenge is that counselling and psychotherapy are regulated in only four provinces in Canada—Nova Scotia, New Brunswick, Ontario, and Quebec. Our understanding is that we must have five provinces in order to be eligible for the HST/GST exemption. Most provinces are working towards regulation right now. We have a couple that are getting quite close, so we're optimistic that we'll reach that five mark in the very near future, but it does take a lot of time to get a profession regulated.