ARCHIVED - Review of the impact of the administration of the Canada Child Benefit

August 7, 2019

The Office of the Taxpayers’ Ombudsman (OTO) is commencing a review of service issues arising from the administration of the Canada child benefit (CCB), namely difficulties proving entitlement, validation, and information available. This review is the result of complaints to my Office and comments received through outreach activities.

Background

Over the course of my mandate, I regularly heard and received complaints about the Canada Revenue Agency’s (CRA) requirements for proving eligibility for the CCB. In particular are issues with proving entitlement, validation, and information available. I have heard the requirements are often not clear and, in the cases of vulnerable individuals, difficult to fulfill. When CCB recipients cannot satisfy the CRA’s requirements for proof, cancellation and recovery of benefits already paid can result. This can occur even if a recipient is actually entitled to benefits but is unable to provide the documents requested by the CRA, or the CRA has deemed the documentation provided insufficient. This can lead to a re-victimization of those already vulnerable populations for whom the CCB is intended to benefit. 

CRA reviews of eligibility status can stem from a change to a benefit recipient’s situation, generally major life events such as a divorce, adjustments to child custody arrangements, or immigration from another country. These are life events that are fraught with emotion, stress, and financial challenges. During such times, situations of child custody and living arrangements are often unclear, not finalized in the courts, or acrimonious, and providing the proof the CRA has determined it requires can therefore be difficult, if not impossible. 

When benefits are cancelled and/or clawed back, personal and financial hardship increases, as the CCB is a major source of income for some individuals in vulnerable situations, and its loss can result in other severe or significant personal consequences.

The CRA has been making changes to the administration of the CCB, which we have been monitoring instead of opening a systemic examination. I have been providing feedback, input, and recommendations on ways to improve the administration of the CCB, through various means, since becoming the Taxpayers’ Ombudsman. However, the CCB remains an issue for many people and continues to be a source of complaints. I therefore feel it is necessary to consolidate this information in a report.

Issue

The question we intend to answer through our review is:

• How can the CRA improve service and reduce the compliance burden on benefit recipients and applicants, particularly those in vulnerable situations?

Next Steps

My Office is currently conducting extensive research, including a review of all information provided and received from the CRA regarding the CCB over the last four years. Additionally, we are reviewing individual complaints and comments received through outreach. The review will focus on the administration of the CCB, not the benefit itself. I aim to deliver my findings and recommendations to your Office by the end of this fiscal year.

This memorandum will be published on the website of the Office of the Taxpayers’ Ombudsman 30 days following its receipt by your Office.

Should you require additional information, please do not hesitate to contact me.

Original signed

Sherra Profit
Taxpayers’ Ombudsman