Technical Advisory Committee on Tax Measures for Persons with Disabilities

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Submissions

September 25, 2003

Canadian Physiotherapy Association
Submission to the Technical Advisory Committee
on Tax Measures for Persons with Disabilities


The Canadian Physiotherapy Association (CPA) welcomes the opportunity to provide a submission to the Technical Advisory Committee on Tax Measures for Persons with Disabilities. CPA acknowledges the efforts of this Committee and the broad scope of this consultation. At this time our comments will focus on the access to ‘qualified persons’ aspect of the tax credit application process for individuals with prolonged and restrictive impairments.

CPA believes that it is in the public interest to provide individuals with disabilities increased access to qualified health professionals for verification of their status. After reviewing the criteria for ‘qualified persons’ CPA believes physiotherapists meet those criteria and is requesting the Technical Advisory Committee to consider including physiotherapists in the list of professionals with that designation.

CPA is the national voluntary professional association for physiotherapists in Canada and represents the majority of physiotherapists practicing in Canada today. CPA’s mandate is to promote excellence in education, practice and research.

Authorization for Disability Tax Credit

The disability tax credit is awarded to individuals with prolonged and severe disabilities that cause marked restriction to their performance of basic activities of daily living. Its intention is to offset, to some extent, the many expenses associated with living with severe impairment. In order to qualify for this tax credit, individuals must have their disability status verified by a ‘qualified person’, namely a medical doctor, optometrist, audiologist, occupational therapist, psychologist or speech-language pathologist, each of whom is authorized to certify specific impairments.

About Physiotherapy

Physiotherapy is a primary care, self-regulated health profession committed to client-centred services that respect the autonomy and dignity of the patient.

Physiotherapy is anchored in the movement sciences and concerned with the function of multiple body systems: it aims to enhance or restore function. Physiotherapists analyze the impact of injury, disease or disorders on movement and function. Their unique contribution to health care is to promote, restore and prolong physical independence by enhancing a client’s functional capacity. Physiotherapy services are covered under public (e.g., hospital) as well as private (e.g., insurance) funding mechanisms.

Physiotherapy Qualifications

Although many individuals with severe physical impairments receive regular and on-going treatment from physiotherapists, physiotherapists are not included in the listing of ‘qualified persons’ that certify walking/mobility impairments under the disability tax credit regulations. Individuals with severe physical disabilities applying for the credit are therefore required to consult other health care professionals to verify their walking or mobility impairment, frequently at additional effort and expense. Including physiotherapists in the list of ‘qualified persons’ would significantly reduce the difficulties individuals with disabilities face by allowing the health professional who often has the most in-depth knowledge of their impairment history and prognosis to verify their impairment.

CPA believes that a review of the following information will support our position that physiotherapists are appropriate candidates for the inclusion as a ‘qualified person’ for certification of individuals for disability tax credits.

• Canadians have direct, primary care access to physiotherapists in all provinces.

• There are more than 15,000 registered physiotherapists across Canada. Over half the physiotherapists practising in Canada work in community clinics, establishing relationships with their clients that last for many years.

• Physiotherapists are regulated health professionals, like the ‘qualified persons’ on the current list of eligible professionals, such as medical doctors, optometrists, audiologists, occupational therapists, psychologists and speech-language pathologists. They are accountable to the public through regulatory colleges in all Canadian provinces and are accustomed to a culture of professional responsibility and public accountability.

• Regulation assists in the confirmation of “guarantor checks”, as timely updating of contact information is a legal requirement for regulated health professionals.

• Regulation ensures consistency in use of title and education. The titles ‘physiotherapist’ and ‘physical therapist’ are protected titles under provincial health profession legislation. This ensures that only qualified individuals can describe themselves as physiotherapists.

• The thirteen university physiotherapy programs in Canada are all affiliated with medical and/or health sciences faculties. Entry-level educational curriculum includes, but is not limited to, the study of:


This educational curriculum ensures that all entry-level physiotherapists have the competencies to assess and treat physical dysfunction within their scope of practice. Physiotherapy education is in transition to a Professional Master’s degree, confirming the profession’s commitment to rigorous standards for education, research, and clinical reasoning.

• Physiotherapists already serve as guarantors for provincial disability issues such as the Assistive Devices Program under the Ontario Ministry of Health and Long-term Care, the Saskatchewan Aids to Independent Living (SAIL) program, and parking passes for persons with disabilities under Alberta and Ontario ministries of transportation.

All of the above factors support the appropriateness of physiotherapists’ candidacy for certification of individuals with walking impairments for the disability tax credits. CPA believes that their addition to the list of ‘qualified persons’ will provide Canadians with an alternate accessible and reliable resource for validation of their disability tax credit eligibility. Physiotherapists would welcome this opportunity to provide this service to their clients.

Recommendation:

The Canadian Physiotherapy Association urges the Committee to add physiotherapists to the list of other ‘qualified persons’ who are eligible to certify walking/mobility impairments for individuals applying for the disability tax credit. The Canadian Physiotherapy Association strongly believes that it is in the public interest to increase the access of individuals with disabilities to qualified health professional certifiers.

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