Good morning, Mr. Chair and members of the committee.
Thank you for inviting us to appear before you on behalf of the Grouping of Professional Mental Health Orders of Québec.
My name is Félix-David Soucis and I am the president of the Ordre des psychoéducateurs et psychoéducatrices of Quebec. With me is Josée Landry, president of the Ordre des conseillers et conseillères d'orientation du Québec. We also represent our colleagues in the Ordre professionnel des sexologues du Québec, the Ordre professionnel des criminologues du Québec, and the Ordre des travailleurs sociaux et des thérapeutes conjugaux et familiaux du Québec.
The primary mission of Quebec's professional orders is to protect the public. They carry out that mission through a range of mechanisms that include professional inspection of their members, continuing education, and their respective syndics' handling of complaints from the public. In this way, the orders ensure the quality and rigour of their members' practice.
The orders represented by our grouping have a total membership of a little over 11,000 professionals who offer mental health services and care to the Quebec public and who are affected by this bill. Almost 2,500 of those professionals are in private practice. As is the case for other professionals in Quebec, they are currently required to charge their clients provincial and federal taxes. This interferes with access to services by people who are experiencing rising levels of need, particularly since the COVID-19 pandemic. During that period, in fact, the Quebec government formally designated professions in the field of mental health and human relations as essential because of the necessary help they provide the public in relation to psychosocial support and mental health care.
We are pleased with the measures announced in clause 137 of Bill C-59 that would eliminate the GST/HST for psychotherapy and counselling services. We believe that this measure will offer Canadians better access to mental health services and care. In Quebec, our professions have been included in the Professional Code of Quebec since 2012 as professions in the field of mental health and human relations. The legislature has thus reserved to our professions the practice of professional activities involving a high risk of harm to the public.
While some of these professionals hold permits as psychotherapists, the others hold permits issued to them by their professional order. They work in mental health and counselling in their respective field of practice, which is clearly defined in legislation, the Professional Code of Quebec. The care and services they provide, whether as psychoeducators, guidance counsellors, sexologists, criminologists or marriage and family therapists, undeniably fall within the field of mental health and apply to personal, professional and educational situations or to family- or couple-related situations.
If a person is facing difficulties relating to entry into the job market, a guidance counsellor will be able to mobilize the person's resources to enable them to achieve their career plans.
If an adolescent is having difficulties associated with going back home after time spent in a rehabilitation centre as a result of committing offences, a criminologist will be able to support them in rebuilding their social skills.
If a member of a family is in difficulty because of a mental health diagnosis, a psychoeducator will mobilize the adaptive capabilities of the entire family so the person is able to cope again.
If a person is questioning their gender identity, a sexologist will be able to support them in their personal journey.
If a couple is having relationship difficulties because of a conflict, a marriage and family therapist will offer them support to improve their methods of communication in order to foster a better relationship.
As you can see, the professionals who belong to these professions that are governed by the Professional Code of Quebec, and therefore by a professional order, are authorized to provide counselling therapy with the goal of supporting the public's mental health needs, in compliance with best practices in their field of practice.
However, the Canada Revenue Agency's notice 335 concerning the exemption for counselling therapy states that the professional services provided by a person could be exempted if the person "has the qualifications equivalent to those necessary to be so licensed or otherwise certified in another province."
Under this interpretation of the bill, it would be confusing and time-consuming, for all of the authorities that participate in such a process, for a professional to have to ask another Canadian authority to verify a qualification when it has already been attested to by the permit that authorizes the person to practise their profession. In its present form, the bill would require the members of Quebec's professional orders to verify with a regulatory agency that oversees the profession of counselling therapy in another province, as is the case in New Brunswick, Nova Scotia and Prince Edward Island, that they have qualifications equivalent to the qualifications of the professionals in the province in question.
We would point out that under the Professional Code, our professional orders have a mandate to be the regulatory and supervisory body for their profession in Quebec and that they are capable of doing that.
I would like to conclude by emphasizing that Quebec has a variety of professionals who are different from those in the other provinces. Quebeckers should not be penalized by having to pay taxes because of that difference. For this reason, we believe that this bill must take into account the unique features of Quebec's system of professions. It needs to be amended so that the services offered by members of Quebec's professional orders are exempted on the same basis as the services offered elsewhere in Canada without professionals having to prove their qualifications to authorities in another province.
Thank you for your attention and we are available to anything further having to do with this bill.
My colleague and I are now prepared to answer your questions.