I think, generally speaking, words are important—I would definitely agree with you—and the obligation of the “shall” provides an obligation on the part of the minister to disregard circumstances that could arise where it would be warranted, for example, to provide an individual with an application form.
Now, I have to say that from a departmental perspective, as I said, the automatic renewal of GIS, the measures that are taken in Bill C-36, will I think go a long way to ensure that seniors will not be placed in a position where they have to apply through a paper application.
But let me give you a circumstance where the flexibility in the “may” may be warranted. For example, we rely on income information that is provided to us from the Canada Revenue Agency. If an individual has, for example, applied for the benefit in the past and could be in a situation where certain life events have changed—let's say their income information has changed—we're relying on the information that is provided by the Canada Revenue Agency. If that individual claims that the Canada Revenue Agency has not assessed their income appropriately, then what happens is we'd be obliged to accept the CRA income and potentially not have a senior be eligible for a GIS benefit because their income, as assessed by the Canada Revenue Agency, would be too high.
So you proactively go out and you initiate an application form for the individual. They provide us with the income. Ultimately, if the reassessment of CRA deems them to have income that's too high, there will have to be a reassessment of that situation. But I think the flexibility is something you want to ensure, with the proviso that you take every effort that is necessary to avoid an application process.