Benefits Unsheltered

An examination into the Canada Revenue Agency's communication and outreach efforts to shelters and other support organizations about benefits and credits administered by the Canada Revenue Agency.

Office of the Taxpayers’ Ombudsman
600 - 150 Slater Street
Ottawa, Ontario K1A 1K3
Telephone: 613-946-2310 | Toll-free: 1-866-586-3839
Fax: 613-941-6319 | Toll-free fax: 1-866-586-3855

© Minister of Public Services and Procurement Canada 2018
Cat. Rv10-16/2018E-PDF
978-0-660-24428-0
This publication is also available in electronic format at
https://www.canada.ca/en/taxpayers-ombudsman.html.

Taxpayer Bill of Rights

1. You have the right to receive entitlements and to pay no more and no less than what is required by law.
2. You have the right to service in both official languages.
3. You have the right to privacy and confidentiality.
4. You have the right to a formal review and a subsequent appeal.
5. You have the right to be treated professionally, courteously, and fairly.*
6. You have the right to complete, accurate, clear, and timely information.*
7. You have the right, unless otherwise provided by law, not to pay income tax amounts in dispute before you have had an impartial review.
8. You have the right to have the law applied consistently.
9. You have the right to lodge a service complaint and to be provided with an explanation of our findings.*
10. You have the right to have the costs of compliance taken into account when administering tax legislation.*
11. You have the right to expect us to be accountable.
12. You have the right to relief from penalties and interest under tax legislation because of extraordinary circumstances.
13. You have the right to expect us to publish our service standards and report annually.*
14. You have the right to expect us to warn you about the questionable tax schemes in a timely manner.*
15. You have the right to be represented by a person of your choice.*
16. You have the right to lodge a service complaint and request a formal review without fear of reprisal.

*Rights which the Taxpayers’ Ombudsman is responsible to uphold.

The Role of the Taxpayers’ Ombudsman

The position of Taxpayers’ Ombudsman (the Ombudsman) was created to support the government priorities of stronger democratic institutions, increased transparency within institutions, and the fair treatment of all Canadians. As an independent and impartial officer, the Ombudsman handles complaints about the services provided to taxpayers by the Canada Revenue Agency (CRA).

As outlined in the Order in Council P.C. 2007-0828, the Ombudsman’s mandate is to assist, advise, and inform the Minister of National Revenue (the Minister) about any matter relating to the service provided to taxpayers by the CRA.

As part of this mandate, the Ombudsman is responsible to address any request for a review of a service matter or matter arising from the application of the provisions of articles 5, 6, 9, 10, 11, 13, 14, and 15 of the Taxpayer Bill of Rights. These service matters are reviewed at the request of the Minister, on receipt of a complaint from a taxpayer or their representative, or on the Ombudsman’s own initiative.

The Ombudsman also examines systemic service issues that may negatively affect a large number of taxpayers or a segment of the population. The findings of systemic examinations are reported to the Minister, and where necessary, include recommendations for improvements to service. The Ombudsman facilitates access for taxpayers to the proper redress mechanisms within the CRA to address service matters, and provides information to taxpayers about the mandate of the Ombudsman.

Summary

The Minister of National Revenue (the Minister), the Honourable Diane Lebouthillier, was made aware women living in shelters with their children may be facing challenges in receiving their Canada child benefit (CCB) from the Canada Revenue Agency (CRA). In December 2016, the Minister requested the Ombudsman assist her in better understanding what, if any, service issues existed and to what extent.

Of the eight rights in the Taxpayer Bill of Rights the Ombudsman is responsible to uphold through her mandate, the most relevant rights to this systemic examination are: 

• the right to be treated professionally, courteously, and fairly (Article 5);
• the right to complete, accurate, clear, and timely information (Article 6); and
• the right to expect the CRA to be accountable (Article 11). 

During our research, the CRA informed us that: 

a) Promotional material on tax obligations, credits, and benefits is sent to organizations as part of its outreach activities;
b) The CRA has also produced a video series Preparing your income tax and benefit return as a reference tool to guide individuals through the filing process;^{Footnote 1}
c) The CRA does not have communication products or web content specific to persons using shelters, nor does it have specific procedures for its enquiries agents when speaking with support organizations or a person using a shelter;
d) Materials are being developed tailored to assist persons using shelters;
e) The CRA is exploring opportunities to enhance its outreach services by collaborating with other government departments (e.g., Employment and Social Development Canada/Service Canada);
f) The CRA is looking into whether it can simplify the T1 General income tax and benefit return for taxpayers with lower income and form RC66 – Canada Child Benefits Application; and
g) The CRA is conducting research on the barriers faced by persons using shelters when accessing CRA benefits and credits.

Our examination revealed that, although the CRA has mechanisms in place to reach out and inform persons using shelters and the organizations serving them about benefits and credits, the CRA is not utilizing these mechanisms consistently across the country. Collaboration between the CRA and the organizations that serve persons using shelters is necessary to ensure those in need have access to the benefits and credits needed to assist them in gaining or regaining self-sufficiency.

Based on the findings and conclusions of this examination, the Taxpayers’ Ombudsman makes the following recommendations to the Minister of National Revenue: 

1. The Taxpayers’ Ombudsman recommends the Canada Revenue Agency continue to find new ways to effectively inform, educate, and collaborate with organizations, to provide information on benefits and credits to persons using shelters.
2. The Taxpayers’ Ombudsman recommends the Canada Revenue Agency actively promote and increase awareness of outreach services and information available to organizations with respect to benefits and credits available to persons using shelters.
3. The Taxpayers’ Ombudsman recommends the CRA ensure consistency across all provinces and territories in:
       a. the promotion of outreach services available; and
       b. the delivery of information to organizations with respect to benefits and credits available to persons using shelters.

    

Introduction

A Brief History

The Taxpayers’ Ombudsman (the Ombudsman) may open a systemic examination following an analysis of trends which identifies a service issue impacting a large number of taxpayers or a segment of the population, on her own initiative, or by request of the Minister of National Revenue (the Minister). The Honourable Diane Lebouthillier became aware some women who live in shelters with their children may be facing challenges in receiving their Canada child benefit (CCB). In December 2016, she requested the Ombudsman assist her in better understanding what, if any, service issues exist and to what extent.

Historically, persons using shelters were older, single men. Today, more and more women, families, and youth are finding themselves displaced from their homes. Youth and adults typically spend an average of 10 days in shelters, while seniors (50+) and families stay, on average, for more than 20 days.^{Footnote 3} There are three types of shelters supporting these groups of Canadians: 

• Emergency shelters provide temporary, short-term accommodation for individuals and families.
• Transitional housing can be differentiated from emergency shelters by the longer length of stay and greater intensity of support services offered to its clients. They are an intermediate step between emergency shelter and permanent housing. Stays are typically between three months and three years.^{Footnote 4}
• Violence against women shelters provide temporary shelter to single women or women with children who are fleeing domestic abuse.

 

All the shelters contacted were aware of the CCB, but mostly through general knowledge, such as obtaining information on the CCB by looking on the CRA website, and from their own experience with the CCB as parents.^{Footnote 7} 

Scope of our Examination

Based on the information obtained through our research and provided by the CRA, the Ombudsman opened an examination into the CRA’s communication and outreach efforts to shelters with respect to persons in shelters accessing benefits and credits. Through the course of the examination it became apparent that we needed to expand this to include organizations that provide services to persons using shelters including, but not limited to, any organization that runs a shelter.

Of the eight rights relating to the service provided to taxpayers by the CRA and outlined in the Taxpayer Bill of Rights, the most relevant rights to this systemic examination are: 

• the right to be treated professionally, courteously, and fairly (Article 5);
• the right to complete, accurate, clear, and timely information (Article 6); and
• the right to expect the CRA to be accountable (Article 11).

 

Analysis

A 2016 study conducted by the Canadian Alliance to End Homelessness found approximately 35,000 Canadians are homeless on a given night and at least 235,000 Canadians experience homelessness in a year. Among those individuals, 27.3% are women, 18.7% are youth, 24.4% are older adults and seniors, and 28-34% are Indigenous Peoples.^{Footnote 8} The study found families stay in shelters twice as long as individuals.^{Footnote 9} A second independent study states there has been a 50% increase in the number of families with children using organizations in the past decade.^{Footnote 10}

The CRA states its commitment to taxpayers is to contribute "to the well-being of Canadians and the efficiency of government by delivering world-class tax and benefit administration that is responsive, effective, and trusted."^{Footnote 11}  It is our view that this should include ensuring all Canadians have access to tax and benefit information, whether it be electronically, through social media, call centres, or in print.

The CRA informed our Office it does not have communication products or web content specific to persons using shelters, nor does it have specific procedures for its enquiries agents when speaking with organizations or a person using a shelter. When taxpayers call to discuss benefits and credits, regardless of their situation, they are advised changes in their personal situation may affect their benefit payments (e.g., change in marital status, change of address, etc.). The CRA informed our Office it is currently developing materials specifically tailored to assist persons using shelters.

The CRA does, however, have promotional material on benefits and credits available to all Canadians including persons using shelters, such as fact sheets, posters, presentations, promo cards, as well as videos and webinars. These promotional materials are handed out during in-person outreach visits, fairs, conferences, expos, and symposiums. The CRA stated all of the products use plain language to ensure persons with literacy issues using shelters are able to understand the information. In fact, the CRA informed our Office it is currently looking into the possibility of having a simplified T1 General income tax and benefit return and form RC66 – Canada Child Benefits Application for individuals with lower income. The review of these forms is based on feedback the CRA received from individuals stating the form was cumbersome to fill out.

The CRA also makes its products and services known through emails to stakeholders (including organizations that provide services to persons using shelters), television, radio, various social media platforms such as Twitter, the CRA website,^{Footnote 12} the CRA YouTube channel,^{Footnote 13} as well as through the volunteers of the Community Volunteer Income Tax Program (CVITP).^{Footnote 14}

The CVITP is a collaboration between community organizations and the CRA. Under this program, community organizations host tax preparation clinics each year from mid-February to the end of April. A few organizations, although not many, offer services during a longer period of time or year-round. Volunteers prepare income tax and benefit returns for eligible individuals who have modest incomes up to an income threshold established by the CRA, and simple tax situations. The CRA assigns coordinators to the program who support the organizations, provide guidance, offer training, and make computers and tax software available to the clinics. In Quebec, community organizations work in collaboration with both the CRA and Revenu Québec.

The CRA is currently developing a handout for CVITP volunteers, meant to be a resource so they can share with taxpayers more information on benefits, credits, and other information about CRA services. The handout will contain pertinent CRA website links and telephone numbers for enquiries should a taxpayer or a person using a shelter need to follow up on the status of their income tax and benefit return.

Regional Outreach Efforts

The CRA conducts in-person outreach with organizations. The CRA informed us its regional outreach officers proactively contact organizations to offer services and information. This includes sharing information related to filing income tax and benefit returns to receive benefits and credits, and offering CRA promotional materials. Outreach services are provided to organizations upon initial contact.

The CRA has indicated that its outreach efforts will remain focused on contacting the organizations and providing their staff with tax and benefit information to respect concerns over anonymity and security of persons using shelters. The organizations’ staff, in turn, can ensure their residents are informed of the benefits and credits they can access through filing an income tax and benefit return. Given that some organizations do not advertise their location, the CRA may not be able reach them all through its outreach efforts.

The CRA advised us if an organization declines the initial offer for a visit, the regional outreach officer will leave their name and phone number and the organization then has the option of contacting the outreach officer directly to request an in-person visit. Although the CRA provides guidelines, each region is responsible for managing its outreach efforts, including when and how the outreach is conducted. Each region then reports its activities to the CRA’s headquarters.

The CRA indicated it proactively sends organizations new or updated CRA products (e.g., benefit amounts, phone numbers, and website links) and offers outreach services to organizations to ensure their needs are being met. Employees and volunteers of these organizations can sign up to receive emails from the CRA about changes to the tax and benefit system.

Organizations may also call the CRA’s regional outreach officer in their respective region(s) to request the CRA provide an information session to a specific group. The CRA states these information sessions are tailored to be flexible and responsive to the needs and demands of the audience requesting the presentation. The CRA’s regional outreach officers conducting these visits use CRA promotional material relevant to the nature of the visit. These visits may consist of a full benefits and credits presentation, answering questions, and handing out materials. The visits may also include a very high-level and brief overview of one or two benefits or credits, followed by a question and answer period, depending on the audience’s needs.

The CRA provides training sessions for interested members of an organization who wish to undertake outreach activities in their communities. The aim is to positively influence persons using shelters in their communities to file their income tax and benefit returns in order to receive benefits and credits.

The CRA advised it is currently developing its outreach strategy for the next three years. As part of this strategy, the CRA is exploring opportunities to expand its outreach services by collaborating with and leveraging the experience and reach of other government departments such as Employment and Social Development Canada and Service Canada, to target vulnerable segments of the population, including persons using shelters.

During our examination, the CRA provided us with a list of over 200 organizations it had contacted or visited from 2014 to early 2017. From this list, we were pleased to note the amount of outreach conducted in Newfoundland, New Brunswick, Nova Scotia, and British Columbia. However, we noted the amount of outreach conducted was less significant among the remaining provinces and territories and uneven overall. While the CRA indicated this list does not cover all outreach activities to shelters across all regions, there remains an issue with outreach activities to such organizations being uneven among the provinces and territories. The CRA needs to ensure there is consistency across the country in its regional outreach efforts to ensure organizations, regardless of where they are located, are aware of available CRA resources.

The CRA advised that the current database (from which the list of organizations visited was created) lacks certain capabilities, including not having the ability to specifically identify organizations as shelters. The CRA has implemented a new requirement for regions to report to CRA headquarters all outreach activities related to shelters. The CRA has developed a new database for outreach to enhance its ability to collect data to measure the success of its outreach activities and identify the various needs of its partnering organizations. The database is expected to be launched in December 2017.

In addition to its efforts to raise taxpayers’ awareness of possible eligibility to certain benefits or credits, the CRA informed our Office that in the fall of 2016 it began working towards the launch of a community-based research project on persons using shelters, regarding the barriers they face when accessing CRA benefits and credits. The research began in March　2017 and took place in social service agencies in the National Capital Region. We were advised researchers aimed to interview persons using shelters, and CVITP volunteers and organizers.

Results of the research were unavailable at the time of the writing of this report. In a statement provided to our Office, the CRA stated it is hoping the results will bring insights into the challenges faced by persons using shelters in filing income tax and benefit returns, and accessing benefits and credits. It was agreed the CRA will share the results of the research with our Office when finalized at which time we will review the results.

Findings

Our findings are as follows:

The CRA does not have communication products or web content specific to persons using shelters, nor does it have specific procedures for its enquiries agents when speaking with organizations or a person using a shelter. We are satisfied that in an effort to address this issue, the CRA has confirmed it is developing materials tailored to assist persons using shelters.

The CRA uses a wide variety of promotional products that are shared with organizations and geared to educate both the organizations, and the persons using shelters, about their tax obligations and the benefits and credits to which these persons may be entitled. Our Office reviewed a sample of the promotional material and was satisfied with the products, and their use of plain language.^{Footnote 15}

The CRA’s proactive contact and in-person outreach with organizations is important to ensure persons using shelters will have the information they need regarding benefits and credits available to them. We agree with the CRA’s approach to focus on contacting the organizations to provide benefit and credit information for persons using shelters. However, we note that there are inconsistencies in the outreach that is done across the provinces and territories. We find that the development of an outreach strategy exploring additional opportunities to expand outreach to persons using shelters, as well as the development of the new database to track outreach, should assist in levelling some of these inconsistencies, but it is also our view that more could be done. It is important for the CRA to be consistent in the outreach services provided across the country to ensure equal access to benefits and credits.

The community-based research into barriers faced by persons using shelters in accessing benefits and credits should provide useful information to the CRA to assist in finding ways to improve the effectiveness of the delivery of information on benefits and credits to those persons.

Recommendations

Based on the findings and conclusions of this examination, the following recommendations are made to the Minister of National Revenue: 

1. The Taxpayers’ Ombudsman recommends the Canada Revenue Agency continue to find new ways to effectively inform, educate, and collaborate with organizations, to provide information on benefits and credits to persons using shelters.
2. The Taxpayers’ Ombudsman recommends the Canada Revenue Agency actively promote and increase awareness of outreach services and information available to organizations with respect to benefits and credits available to persons using shelters.
3. The Taxpayers’ Ombudsman recommends the CRA ensure consistency across all provinces and territories in:
           a. the promotion of outreach services available; and
           b. the delivery of information to organizations with respect to benefits and credits available to persons using shelters.