Présentations
version
PDF
(Disponible
en anglais seulement)
Canadian Cystic
Fibrosis Foundation
Fondation canadienne de la fibrose kystique
2221 Yonge Street, Suite 601, Toronto, Ontario M4S 2B4
Tel: (416) 485-9149 / 1 (800)378-CCFF (2233)
Fax: (416) 485-0960 / (416) 485-570.7
Web: www.cysticfibrosis.ca
Le 31 juillet 2003
Charles Smyth
Technical Advisory Committee on Tax Measures
for Persons with Disabilities
140 O'Connor Street
Ottawa, ON KIA 0G5
Dear Mr. Smyth,
Thank you for the opportunity
to comment on the Disability Tax Credit (DTC) with respect to Canadians
affected by cystic fibrosis (CF), for the members of the new Technical
Advisory Committee on Tax Measures for Persons with Disabilities.
Cystic Fibrosis
As you may be aware, CF is an inherited disease which affects breathing
and digestion. In the lungs, CF causes severe breathing problems.
A build-up of thick mucus makes it
difficult to clear bacteria and leads to cycles of infection and
inflammation, which causes progressive damage to the delicate lung
tissues. From the time of diagnosis, usually in the first year of
life, individuals with CF must follow a demanding daily routine
of physical therapy to keep the lungs free of congestion and infection,
and to facilitate breathing. In the digestive tract, CF makes it
extremely difficult to digest and absorb adequate nutrients from
food. Thick mucus also blocks the ducts of the pancreas, preventing
enzymes from reaching the intestines to digest food. Therefore,
persons with CF must consume a large number of artificial enzymes
(up to 40 pills a day) with every meal and snack. Unfortunately,
CF is always fatal, and virtually all CF deaths are caused by chronic
and progressive lung disease.
Life-Sustaining
Therapy
A few years ago, following intensive consultations between representatives
of the Canadian Cystic Fibrosis Foundation (CCFF) and the Department
of Finance, the DTC eligibility criteria were changed to extend
access to the credit on a more equitable basis to young Canadians
with CF who were experiencing severe and prolonged disability, primarily
because they could not breathe. The change to include “life-sustaining
therapy” was made in respect of the 2000 and subsequent taxation
years. Prior to 2000, the families of at least two young Canadians
with CF who had died were pursued by government assessors for reimbursement
of the DTC, as the deceased individuals were deemed by the Revenue
Canada not to have suffered from disability. The principal rationale
seemed to be that there were no grounds for recognition of breathing
as a “basic activity of daily living”.
Our Foundation’s
members remain profoundly grateful that a positive solution was
identified for individuals with CF who require extensive therapy
to alleviate health problems which – as the disease progresses
– are severely disabling. They would be very concerned should
this eligibility be restricted. It is our understanding that the
Technical Advisory Committee is not revisiting the criteria for
“life-sustaining therapy”.
Breathing
While we are aware that “breathing” remains off the
list of basic activities of daily living used to determine eligibility
for the DTC, we would like to draw your attention to a recently
updated World Health Organization document, “International
Classification of Functioning, Disability and Health” which
now recognizes breathing as a basic daily function. It follows,
accordingly, that severe deficits in breathing, which are often
experienced by persons with CF, may have severely disabling consequences
with respect to carrying out normal routines of daily living.
If the Technical
Advisory Committee is considering, as recommended in the Report
of the Standing Committee on Human Resources Development and the
Status of Persons with Disabilities “Tax Fairness for Persons
with Disabilities” released December 2002, adding “breathing”
to the list of basic activities of daily living for the purpose
of assessing eligibility for the DTC, the CCFF would be pleased
to comment on or assist your committee in evaluating the merits
of this approach. Advisors to our Foundation, who are clinical specialists
in CF care, have done considerable research on the disabling effects
of deficits of breathing, and would be willing to share their research
and views with the Technical Advisory Committee.
“Qualified
Persons”
We agree with the finding of the Sub-Committee on the Status of
Persons with Disabilities in the March 2002 Report “Getting
it Right for Canadians: the Disability Tax Credit” that individuals
residing in remote areas may not have ready access to the practitioners
listed as persons qualified to complete Form T2201 as set out in
paragraph 118.3(1)(a.2) of the Income Tax Act. We support the Sub-Committee’s
recommendation that the Income Tax Act should be amended to included
“registered nurses” for these individuals. We would
also suggest that the Technical Advisory Committee give consideration
to adding “nurse practitioner” to the list, in their
review of persons qualified to complete Form T2201.
Redesigning Form T2201
and Public Awareness
The CCFF supports the initiative of the Canadian Customs and Revenue
Agency (CCRA) to revise and redesign Form T2201 with the primary
objective to clarify and increase the awareness of the DTC legislative
criteria for taxpayers and health professionals.
The Foundation is encouraged
that the CCRA recognizes the need to give better information to
persons with disabilities, and their families, regarding the criteria,
and eligibility for the DTC. We hope the CCRA and the Government
of Canada continue this positive initiative by mounting a program
to education and raise awareness of all tax measures available to
persons with disabilities and their families. We believe it is important
that the individuals concerned know about, and understand the tax
measures available to them.
To assist in this effort
the CCRA might find it useful to consult with the community of persons
with disabilities, including organizations that provide support
within this community, and seek their input in the development of
plain language information brochures and other resources on tax
measures. Assistance from organizations, such as the CCFF, could
be sought in helping to disseminate and raise awareness of the tax
measures available to persons with disabilities and their families.
For your information,
the Canadian Cystic Fibrosis Foundation is a non-profit, charitable
organization dedicated to improving life expectancy, and the quality
of life, of persons with CF. The Foundation pursues this goal principally
by providing incentive grants to enhance the availability and effectiveness
of specialized medical and transplantation services, and by seeking
a cure or effective control for CF, through research.
We appreciate this opportunity
to provide input. Should your committee members wish additional
information about CF and its impact on Canadians, we will be pleased
to
consult further. We look forward to receiving and reviewing the
recommendations of the
Technical Advisory Committee.
Yours sincerely,
Cathleen Morrison
Chief Executive Officer
cc. Dr. Carolyn Bennett,
MP
Dr. Elizabeth Tullis, CF Clinic Director, St. Michael's Hospital
|
