CRA Data and Analysis Suggestions for a More Effective CVITP Strategy

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As mentioned in a previous article, one priority in her Supplementary Mandate Letter from the Prime Minister (dated January 2021) instructs the Minister of National Revenue to “enhance and expand the Community Volunteer Income Tax Program”.  One thing the Canada Revenue Agency (CRA) can do to help achieve this is through placing greater emphasis on another priority mentioned in the same letter, instructing Minister Lebouthillier to “improve the collection and analysis of disaggregated data related to supports and services offered by the CRA.”

Data needs to be collected and analyzed for at least two reasons.  First, to confirm whether or not the CVITP is meeting its intended objective.  And second, where the CVITP is falling short of its intended objective, to help devise strategies to ensure the program can better meet its intended objective.

We think the Canada Revenue Agency (CRA) currently has two related problems with respect to CVITP data.  First, it collects the wrong data and publishes too little of what it does collect.  Second, this means the CRA focuses on doing the wrong things.

In this two-part series of articles, we look at data and its use in formulating strategy.

In the first article, entitled “First, the CRA Needs to Collect and Analyze the CORRECT Data”, we examine the data that is collected and analyzed on clients and their returns.  We begin with the uncontroversial observation that data needs to be collected and analysed to confirm whether or not the CVITP is meeting its intended objective.  We then refer to a previous article in which we argued that the CRA presently collects and reports CVITP results data which are not aligned with the purpose and in which we offered alternative performance indicators which we believe do a better job of this.  We also look at the data the CRA currently collects on CVITP host organizations and volunteers – what we call the delivery infrastructure – and make some modest suggestions for additional data to be collected through the annual registration process just prior to the tax season.

In the second article, entitled “Then, the CRA Needs to Build a Strategy With a Focus on Improving EFFICIENCY”, we look at how all this data can be used to devise strategies to ensure the CVITP can better meet its intended objective.  The combination of analyses of data on CVITP results and delivery infrastructure can help to inform the choice of actions to be taken.  The strategic priority we focus on is increasing the number of CVITP clients.  We argue that the CRA should place greater emphasis on increasing efficiencies within the existing delivery infrastructure over increasing the size of the delivery infrastructure.  A few examples are offered to illustrate how data on results and delivery infrastructure could be used to do this.

CRA’s Newly Minted COIN: A Welcome Innovation

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This year, the Canada Revenue Agency (CRA) introduced an innovation into the CVITP.  Every host organization will be issued with a unique CVITP Organization Identification Number or COIN for the duration of its participation in the CVITP (i.e. it will remain the same from year to year).  In this article, we explain briefly why the CRA introduced the COIN and how it works.  We also identify a function for the COIN which the CRA has not yet stated but which we believe will be really important for helping to make strategic decisions about the future shape of the CVITP.

Post Tax Season Review: Initial Impressions from the CVITP Frontlines

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With the close of the tax filing season, we did an informal survey of some of our fellow CVITP volunteers, to get their first impressions of how the tax season went.  This included both new as well as returning volunteers.  This article contains a summary of their impressions as well as a few of our own.  We welcome hearing more about some of the lessons you have drawn from your own experience of the tax filing season.

Missing in Action: No Future CRA Reporting on CVITP Results

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The Canada Revenue Agency (CRA) recently released its Departmental Plan for the forthcoming fiscal year.  Since 2012, the CRA has reported to Parliament on the results obtained by the CVITP.  With the introduction of results-based performance reporting across all federal departments and agencies in 2017, the CRA has included the CVITP results within its performance indicators.

However, the new Departmental Plan has dropped any formal reporting on the CVITP; this means no data will be included on CVITP performance targets or results achieved.  Therefore, no information will be systematically made available to Parliamentarians, the public or even the CVITP host organizations and their volunteers.

In this article, we give four reasons why this is a problem:

  1. any evidence on the linkage between the CVITP and the federal government’s Poverty Reduction Strategy will be lost;
  2. Parliament will be unable to exercise any oversight over the CVITP budget increases it approved;
  3. it calls into doubt the Minister of National Revenue’s commitment to a priority identified only three months earlier by the Prime Minister; and
  4. CVITP host organizations and their volunteers who do the bulk of the CVITP work for the CRA using their own resources will now be kept in the dark as to the results of their efforts.

This is a strange way to mark the 50th anniversary of the CVITP.

PM’s Mandate Letters for Minister of National Revenue: Does the CRA “Walk the Talk” on the CVITP?

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We already know that the federal government identified the CVITP as an initiative contributing to achieving the objectives of its 2018 Poverty Reduction Strategy.  But how can one tell just how important the CVITP is currently to the government?  One way is to consult the Mandate Letter that the Prime Minister sends to the Honourable Diane Lebouthillier, the Minister for National Revenue responsible for the Canada Revenue Agency.  This letter gets issued following the Speech from the Throne and highlights the current government’s priorities.  This article highlights a few of the priorities in the Minister’s December 2019 Mandate Letter and her January 2021 Supplementary Mandate Letter which are relevant to the CVITP.  And it briefly looks at how well the Canada Revenue Agency is doing at delivering on these priorities.  The results are not promising.

Coming soon…

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With the regular tax season drawing to a close, we are planning to return to producing articles on a range of CVITP related topics that we hope will be of interest to you.  For example, in the coming weeks, look for the following articles:

  • Tax Season Post Mortem: initial impressions from the CVITP frontlines
  • CRA Minister’s Mandate Letters and the CVITP
  • CRA Ombudsman’s Report and Recommendations for Improving the CVITP
  • Case Study: lessons from filing for refugee claimants
  • CRA’s newly minted COIN (CVITP Organization Identification Number)
  • Missing in Action: CVITP and the CRA’s Departmental Plan for the 2021-22 fiscal year
  • A CRA Data Wish List for Improving the CVITP

Furthermore, we have many other article ideas planned, including:

  • Case Study: lessons from filing for workers in the gig economy
  • Implications of the Federal Government’s Budget 2021 for CVITP Clients
  • CRA’s Partnership With Host Organizations: shortcomings & opportunities
  • CRA’s Partnership With Volunteers: shortcomings & opportunities
  • Alternative Income Ceilings for CVITP Tax Clinics
  • CVITP Volunteers as Freelancers?
  • Lost in Translation: CRA Communications With CVITP Clients

If you have an article idea you would like to suggest, we’d love to hear from you.  And if you have an article you would like us to publish on a topic you think would be of interest to our readers, please do let us know.

So make sure to visit this site regularly in the coming weeks for informative analysis and ideas on the CVITP and its link to poverty reduction.

CVITP Volunteers At Work

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Like many of our readers, we are CVITP volunteers.  During the months of March and April, we turn our attention to helping clients with the preparation of their income tax and benefit returns.  Consequently, we will be posting fewer articles during the tax season.  We expect to be back posting more articles starting in May.

Observations From Helping Chronic Non-filers to File

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One host organization we work with as CVITP volunteers has good connections with other social services in the local community and, through those connections, identifies chronic non-filers who are now seeking to file. A number of these cases have been forwarded to us to work on.  This article covers some issues we have identified when filing for these chronic non-filers.  It also highlights issues raised that the CVITP is not designed to handle but which can impact on the client’s situation.  This article does not cover the mechanics of how to file for these individuals; information on this can be found in our article “How do I file a client’s returns for prior years?”

What’s New for the 2020 Tax Year?

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A number of important new measures were introduced in 2020.  These included the CVITP Organization Identification Number and the Canada Revenue Agency (CRA) grant program for host organizations participating in the CVITP, as well as five COVID-related benefit programs and a refundable tax credit for clients.  This article provides summaries of each of these with useful links where additional information can be found.  It also forewarns volunteers and their host organizations of problems that clients might raise stemming from the unusual measures taken in 2020.

16 Lessons From Dealing With COVID

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As we reported here, in the 2020 tax season the CVITP served only 55% of the clients it had served in the previous year.  The Canada Revenue Agency (CRA) attributes the dramatic decline to the public health restrictions introduced in 2020 to deal with COVID.

In preparing for the forthcoming tax season, the CVITP tax clinics will be subject to similar COVID related public health restrictions.  Furthermore, as of now, the CRA has given no indication that it will change the traditional filing deadline of April 30th to ensure the continuity beyond June 2021 of the many benefits which are conditional upon filing an up-to-date return.  Significant changes in practices and procedures are needed to avoid an outcome similar to last year’s.

What can be learned from the experience last year which can be applied to this year’s tax season and to future years when the public health restrictions are no longer an issue?

This article identifies 16 lessons.  We also invite our readers to share additional lessons drawing on their own experiences.

Notice of Assessment: Canada Revenue Agency’s New Grant Program

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The Canada Revenue Agency (CRA) recently announced that it will, for the first time, be providing financial support to host organizations that run CVITP clinics.  As the CRA has previously denied that it could provide such support, this is an important change.  And in principle, it is one that we support.

However, the current pilot project, which offers $3.3 million a year over the next three years, is poorly designed, with no targeting (not in line with the purpose of the program), insufficient financing (unlikely to provide the intended incentive effects), and an administrative process that is burdensome (not exploiting the flexibilities available with the use of grant funding).

Recognizing that this three-year pilot project has yet to begin its first year of implementation, we make some suggested changes that we believe will significantly improve its impact.  We propose that the CRA:

  • Target its grant funding to ensure host organizations are providing support to those who need it the most;
  • Make the client income level a criterion, using the poverty line as the threshold;
  • Set a minimum percentage for a host organization’s client returns that must meet or fall below the poverty line to qualify for any grant funding;
  • Offer a larger financial incentive for returns filed by clients who had previously not filed for a number of years;
  • Establish and publicize the minimum percentage and the size of the financial incentive at the outset of the grant funding period;
  • Significantly increase the funding level per eligible return to provide for something approaching a real incentive;
  • Use the annual registration process for the approval of host organizations to collect all of the information required to assess the host organization’s eligibility for grant funding; and
  • Use the annual registration process for the approval of host organizations to notify eligible host organizations of the funding formula it will use to determine the amount of grant funding they could receive at the end of the eligible activity period.

We conclude this four-part series of short articles offering some thoughts on the challenges the CRA will face in assessing the impact of this pilot project.  Given the difficulty in surmounting these challenges, there is a risk that any growth in the numbers will be claimed as demonstrating the success of the pilot and used to justify maintaining this project with poor targeting, insufficient financial resources and cumbersome administrative arrangements.

2021 Tax Season – A Letter to the Minister

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The Minister of National Revenue, the Honorable Diane Lebouthillier, is responsible for the Canada Revenue Agency (CRA).  We recently wrote to her to express our concern about the forthcoming tax season.  Without significant changes from the procedures and practices adopted in 2020 for the 2019 tax year, we worry that the CVITP experience this year will not be materially different from that of last year when CVITP operations were severely disrupted by COVID and many fewer clients were served than in recent years.

CVITP clinics will be operating under the same COVID related public health restrictions as in 2020.  Furthermore, as of now the CRA has given no indication that it will change the traditional filing deadline of April 30th to ensure the continuity beyond June 2021 of the many benefits which are conditional upon filing an up-to-date return.

In light of this, we make a number of suggestions.  Read our letter to the Minister here.

The Evolution of the CVITP – 2020 Update

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We find two sources of 2020 data from Canada Revenue Agency (CRA) publications that allow us to update CVITP trends on the numbers of individuals assisted, returns filed, volunteers employed and host organizations offering free tax clinics.

In this article, we show and briefly discuss: (1) the dramatic decline in individuals assisted; (2) the continuing modest upward trend in the average number of returns filed per client; (3) a modest decline in the number of volunteers registered, which may mask a collapse in the number of volunteers who were actually employed in providing services in virtual clinics; (4) a modest increase in the number of host organizations registered which may similarly mask a collapse in the number of host organizations which actually offered services through virtual clinics; and (5) a continued decline in the average number of volunteers employed per host organization.  This last trend may be an early sign of future capacity constraints within the CVITP.