News
Submission on the Government’s Consultation on Draft Legislation for Various Tax Measures
2026-09-15
Introduction
The College of Family Physicians of Canada (CFPC) welcomes the opportunity to respond to the draft legislative proposals released for consultation on July 23, 2026, specifically the proposed amendments to sections 118.3 and 118.4 of the Income Tax Act concerning the Disability Tax Credit (DTC).Administrative burden consistently ranks as a top concern for family physicians. It has been linked with family physicians leaving practice, cutting back working hours, and discouraging medical students from going into the specialty. This is particularly concerning when millions of people living in Canada do not have access to a regular family physician.
One of the significant sources of administrative burden for family physicians is federal forms, with the DTC ranking highest as the most burdensome federal form family physicians must complete. Among health professionals, family physicians are primarily relied on to fill out the current DTC form, completing approximately 80 per cent of DTC applications.* In 2024, 330,000 DTC applications consumed time equivalent to nearly one million patient visits seen by family physicians. The Canada Disability Benefit, which uses the DTC for eligibility, is expected to increase applications by over 50 per cent in coming years, growing the paperwork burden.
The CFPC welcomes the measures announced in the Spring Economic Update 2026 (SEU) regarding the DTC. Simplifying the certification process for individuals with certain long-lasting medical conditions and expanding the range of health professionals authorized to certify eligibility are positive steps. They have the potential to improve access for people with disabilities while reducing paperwork for family physicians. However, these incremental changes will not fully address the fundamental source of the burden: the DTC continues to rely predominantly on family physicians to act as gatekeepers to a federal tax benefit.
We encourage the federal government to consider the following recommendations in addition to the SEU, to achieve measurable improvements for family doctors and the patients they serve.
Recommendations
To start, the CFPC calls on eliminating the legislative requirement for family doctors to complete the DTC form. Amend section 118.3 of the Income Tax Act to eliminate the requirement for family physicians to complete the DTC form and move toward an honour-and-audit model similar to the one used for Canada-wide income tax submission. Applicants should be able to provide the information necessary to establish eligibility, with the Canada Revenue Agency (CRA) verifying applications through targeted review or audit where appropriate.Such an approach would maintain program integrity while reducing unnecessary demands on the health system and improving access for people who do not have a family physician. It would also be consistent with Budget 2025’s plan for automatic tax filing for low-income people in Canada, which signals a shift toward a simpler, citizen-focused process to access tax benefits.
In the short term, the federal government should also:
- Further simplify the DTC application form by reducing its length, eliminating repetitive questions, and limiting requests for clinical information to what is necessary to determine eligibility.
- Enable pre-eligibility through other established disability programs, including appropriate provincial and territorial disability benefits and parallel federal programs. People living in Canada should not have to repeatedly establish the same disability to different government programs.
- Compensate family physicians for required DTC certification work, ensuring that the administrative costs associated with accessing a federal benefit are not transferred to patients or absorbed by family practices.
- Ensure the qualifying condition list for streamlined DTC access in the SEU is kept evergreen, transparent, and clinically sound. The federal government should have a mechanism in place, such as regulations, to regularly review and add missing conditions under this pathway. Collaboration with family physicians and people with disabilities must guide this approach.
Lastly, we call on the federal government to measure the impact of DTC reforms announced in the SEU. The CRA must publicly report on whether these reforms are decreasing barriers for people with disabilities and reducing administrative burden on family physicians. In addition to ensuring accountability around these outcomes, this evaluation will help inform where further reforms may be needed.
Conclusion
The proposed amendments, in the SEU, to sections 118.3 and 118.4 of the Income Tax Act are welcome and should be implemented quickly. However, they should be viewed as a step toward a necessary fundamental reform rather than an end point. The core certification requirement remains a major driver of the DTC’s burden on family physicians and a barrier to obtaining the benefit by people with disabilities.The federal government’s 2025 campaign platform earmarked $100 million per year to reduce administrative burden, in its Fiscal and Costing Plan. They also committed to reduce red tape and “streamline inefficient or complicated processes, including excessive paperwork or forms.” The DTC is a clear opportunity to deliver on these commitments. We encourage the federal government to leverage this promised funding to provide the CRA with necessary resources to move on the recommendations highlighted above, for the benefit of people with disabilities, family physicians, and everyone living in Canada.
*Information disclosed during private meeting with Canada Revenue Agency officials (March 19, 2024).
