Thank you very much, Madam Chair and honourable members of the committee, for the opportunity to appear before you today.
My name is Maureen Haan. I am the president and CEO of the Canadian Council on Rehabilitation and Work, or CCRW. We work with folks with disabilities to ensure inclusive, meaningful employment across Canada.
You're going to hear two things from me today that may at first seem contradictory.
First, I want to express genuine appreciation for the measures in the spring economic statement to improve the disability tax credit. Second, and more fundamentally, I will submit that the DTC has functionally evolved, out of necessity, into the entry point for disability-related programs and benefits. We believe that eligibility should take a different, modern, comprehensive approach to federal disability eligibility—outside the tax system.
The changes proposed in the spring economic statement are meaningful. Streamlining the application process, creating faster pathways for certain long-standing conditions and expanding the range of professionals who can certify eligibility will reduce administrative burden and improve access. These improvements reflect long-standing concerns raised by the disability community, and they will make a difference.
However, the DTC is not designed to be, and was never designed to be, a system for determining disability or eligibility for social programs. It is a tax measure, a non-refundable tax credit intended to provide modest tax relief. However, today it plays a much larger role: A valid DTC certificate is required to access multiple core federal programs, including the Canada disability benefit, the registered disability savings plan, the child disability benefit and the disability supplement to the Canada workers benefit.
In effect, the DTC has become the front door to the Government of Canada's disability support programs, and it is a barrier, because the DTC is administered through the Income Tax Act. The Canada Revenue Agency tax policy is now functioning as disability policy. Decisions about who can access income supports and essential benefits are being filtered through a tax-based instrument. Put plainly, tax-based criteria are deciding who is disabled enough.
This is not aligned with modern disability policy approaches. It is inconsistent with the legislated definition of “disability” in the Accessible Canada Act and with Canada's commitments under the UN Convention on the Rights of Persons with Disabilities.
The DTC relies on a narrow, highly structured concept of disability. This model does not reflect how disability is understood today. It does not adequately capture episodic disabilities, mental health conditions or cumulative limitations. As a result, people with real needs and legitimate disabilities are excluded, and when this narrow test becomes the gateway to multiple programs, the consequences are compounded. A denial of the DTC does not just restrict a tax credit: It can block access to income supports and other essential benefits.
This is why the national disability network has identified this issue as a key priority for engagement with the federal government. In its document titled “The Disability Agenda: National Advocacy Priorities for the Government of Canada”, released today during National AccessAbility Week, the NDN identifies this as priority number two: a new approach to federal disability program eligibility. Priority two points to a different path.
First, disability policy should not be anchored in the tax system. Eligibility for disability programs and benefits should be determined through a system designed for that purpose, not through a tax credit. The DTC should be an end, not a means. It should be a way of delivering tax relief, not the mechanism that determines who can access essential supports.
Second, the federal government should apply a consistent, modern definition of disability that is aligned with the Accessible Canada Act. I'm encouraged to report that Accessibility Standards Canada—of which I am proud to be a board member—is working with disability community partners to develop a standard with a common definition of “disability”, grounded in both the ACA and the CRPD, for use across the Government of Canada.
The DTC reflects an older, medicalized model, creating a clear disconnect across programs.
I see that my time is coming to an end, so I'll end there.
I'm open for any questions. Thank you.
