Thank you, Mr. Chair and members of the committee. On behalf of JDRF Canada, the leading global charity focused on research to cure, prevent, and treat type 1 diabetes, I want to thank you for inviting us here today to present to the pre-budget consultations.
Type 1 diabetes or T1D is a chronic, potentially fatal, autoimmune disease in which a person’s pancreas stops producing insulin, a hormone that transforms food into energy, causing a lifetime dependence on daily injections or infusions of insulin to maintain glucose control.
Those living with type 1 diabetes must carefully balance food intake, physical activity, and insulin to maintain their blood glucose levels within a target range. Failing to appropriately manage this disease may lead to costly and devastating complications such as kidney failure, blindness, nerve damage, amputation, heart attack, or stroke. There's a constant risk of dangerously low or dangerously high blood glucose levels which are life-threatening. We really can't overestimate what is involved in managing this disease. It's incredibly time-consuming and meticulous.
As I'm sure you know, the Government of Canada has long offered relief to Canadians through the disability tax credit, the DTC. According to the Government of Canada's website, the purpose of the DTC is to provide for greater tax equity by allowing some relief for disability costs since these are unavoidable additional expenses that other taxpayers don't have to face. The out-of-pocket costs of managing type 1 diabetes are significant. Depending on individual income and insurance coverage, the costs range from $1,000 to $15,000 annually.
New technologies, such as insulin pumps and continuous glucose monitors, certainly help people with type 1 diabetes better manage their disease. They benefit the patients and taxpayers, because better glucose control means fewer emergency room visits and longer-term complications, which are obviously very costly to the health care system. However, these devices are expensive and not fully covered by provincial or private insurance plans.
There's no question that Canadians living with type 1 diabetes have additional expenses that other taxpayers don't have to face. For nearly a dozen years, Canadians with type 1 diabetes have been able to rely on the disability tax credit for at least some financial relief. The notion of a life-sustaining therapy with respect to the DTC was expanded in 2006 to allow people with diabetes to qualify. There's no denying that insulin therapy is life-sustaining. If you're a type 1 diabetic and you don't take your insulin, you'll die.
The CRA's interpretation of the rules around life-sustaining therapy seem to have changed as of May 1 this year. According to the Association of Canadian Disability Benefit Professionals, at least 80% and possibly more than 90% of the claims are now being denied. This is happening despite their doctors having certified that they spend more than the requisite 14 hours a week administering insulin therapy and the associated requirements such as blood glucose testing.
As the costs of type 1 diabetes grow, making it more difficult to access the disability tax credit, the result will be greater inequality in Canada and a greater burden to people living with this disease.
We believe everybody with type 1 diabetes should qualify for the disability tax credit. In our pre-budget submission to this committee, JDRF recommended two small changes to the Income Tax Act that would make this possible.
The first change would ensure that the function of calculating carbohydrates or the food on your plate is included when determining the time spent administering a life-sustaining therapy for the purposes of claiming the DTC. Insulin is not like getting a regimen of antibiotics from your doctor. It's not like “take at every meal”. You actually have to calculate exactly what you take, because if you don't, it can be very dangerous. Calculating the carbohydrates is an inseparable function of calculating the appropriate insulin dosage.
The other amendment would be to reduce the threshold from 14 hours to 10 hours to remove any uncertainty in determining the DTC eligibility for Canadians with type 1 diabetes.
We believe these proposed changes would ensure that every Canadian with type 1 diabetes would be eligible for this vital relief mechanism.
We want to thank the members of this committee for inviting us here today. We look forward to answering any questions to help these patients in Canada.