Category Archives: CRA

Great CRA Innovations: Annual Data on CVITP Results

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The CRA recently published a new feature on its CVITP website called “Free tax clinic statistics”.  This feature includes annual data on individuals assisted, returns filed, volunteers and host organizations as well as the value of the entitlements generated by filing returns.  It provides this data at the national level as well as by province and territory, something that was rarely seen before.  This is a very welcome development!

While the website only gives data for 2021 and 2022, we hope the CRA will update this feature in future years without losing the historical data.  Considering this new feature, we list four concerns below, in order of priority, from least to most important:

  1. A change in the timeframe for data collection, shifting from May 16 of the previous year to May 15 of the current year, over to January 1 to December 31 of the same year.  The data for 2021 (January 1 to December 31) are remarkably similar to the data reported for what was previously 2022 (May 16, 2021, to May 15, 2022).   The data for 2022 (January 1 to December 31) leads to only one change in our previous assessment of six trends revealed in CVITP data:  the numbers of individuals assisted and returns completed rose by 13% and 15% respectively in 2022 whereas the old data suggested stagnating performance.
  2. Reporting on the value of the refund, benefit and credit entitlements generated each year for CVITP clients.  The total is for the federal and provincial/territorial refund, credit, and benefits administered through the CRA.   A further breakdown of what is included would provide for greater transparency and understanding.  We give several reasons why we think the amount reported is a very conservative underestimation.
  3. While the subnational figures are of passing interest, host organizations are keen to get the information on the value of the refunds, credits and benefit entitlements for the clients they have served in their own CVITP clinics.  This demonstrates the relevance of their work to senior management within their host organizations and to their local communities.  It also helps to buttress their requests to donors for funding support.  The introduction of the CVITP Organization Identification Number or COIN in 2021 (for 2020 and subsequent year returns) now makes this possible.
  4. While the CRA data are useful, the results do not really get at the main purpose of the CVITP.  (We show why here.)  The CRA should track and report against more relevant results, which will help it to focus limited CVITP resources, especially its volunteers, on providing CVITP services to those who need these the most.

This article provides the numbers and more detail on the concerns listed above.

Assessing Year #2 of the CRA’s Three Year Pilot Project

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This article looks at the implementation in the second year (2022) of the Canada Revenue Agency’s (CRA) three-year pilot grant project in support of CVITP host organizations.  (We reviewed the first year of implementation in 2021 here.)

The first part of this article looks at the second year of funding.  Increases to the grant amounts on offer were announced late in the calendar year, after all the second-year implementation of this pilot project was finished.  These increases were probably a response to the very low grant payments for the first year of operation.  But while the CRA’s stated objectives for the program suggest the funding is intended to serve as incentive for host organizations to ramp up their services, the timing of the announcement was strange as it would have no effect on the results obtained in the second year.  According to the CRA, 1,067 host organizations had applied for grant funding in the second year and the CRA anticipated disbursing $2.4 million (up from just over $900,000 in the first year).

The second part of the article looks at the results obtained in the second year and compares these with results from the first year.  In doing this, use is made of the objectives and performance targets the CRA identified for this pilot grant program:

  1. While the first objective is to cover some of the participating (host) organizations’ administrative costs, no performance measure is given.  That said, it is strange for an element of the project design to be a stated objective of the pilot project.
  2. Whereas the number of participating organizations was expected to grow by 5% per year, between 2021 and 2022 the number grew by 692%.  However, as we observed when the grant program was launched over two years ago, the CRA will have difficulty disaggregating the rebound in the numbers due to the pilot project from a return to normal after the deleterious effects of COVID in 2020 and, to a lesser extent, in 2021 as well as the natural growth in the numbers that the program has previously known.
  3. Although increased retention of participating organizations is a stated objective and a performance measure is given, the CRA publishes no data which allow this to be assessed.
  4. Expansion in the reach of participating organizations is listed as another objective.  But no performance measure is given so this cannot be assessed.
  5. Expansion to vulnerable population segments is also listed as another objective.  But, again, no performance measure is given so this cannot be assessed.
  6. Even though it is not a stated objective, the CRA identifies an increase in the number of volunteers associated with grant recipient organizations as a performance measure.  As the CRA does not distinguish in its published data between host organizations which are grant recipients and those which are not, this cannot be assessed.
  7. The CRA also identifies an increase in the number of returns filed by grant recipient organizations as a performance measure.  However, this too cannot be assessed because the CRA does not distinguish in its published data between host organizations which are grant recipients and those which are not.  Surprisingly, the growth in returns filed is not a stated objective.  Yet a simple measure of success could be whether more individuals get served and, by extension, more returns get filed.

When the project was first launched, we wrote that the pilot grants needed to be targeted differently for the CVITP to better contribute to the poverty reduction objectives set out in the federal government’s 2018 Poverty Reduction Strategy.

In the intervening years, the federal government has further increased its use of the income tax and benefit return (for example, with the one-time top up to the Canada Housing Benefit, the Canada Dental Benefit and the grocery rebate) to achieve its income security and poverty reduction goals.  This has only reinforced our conviction that, upon completion of the pilot, the CRA needs to rethink the design of this program (and not just make the funding permanent and more generous) if it wants the CVITP to improve its contribution to reducing poverty in Canada.

Automatic Filing is No Magic Fix for Getting Benefits to More Low-income People

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The federal government’s Budget 2023 has announced plans to help more low-income Canadians who are not currently filing their returns to get the benefits to which they are entitled.  In this article, we explain why both of the proposed initiatives are unlikely to succeed.  What follows is a summary of the article.

One of the initiatives aims to increase the number of eligible Canadians using the File My Return (FMR) service to two million by 2025. This service, introduced in 2018, allows eligible Canadians to file their income tax and benefit returns over the phone by answering a series of short questions using an automated function.

However, the use of this service has been consistently low, with less than 10% of eligible users taking advantage of this service annually over the past five years.  Complicated instructions that require a high level of reading skills in one of the official languages and understanding of tax-related concepts, confusion over various automated options, and distrust in the government are some of the reasons which have contributed to the low take-up rates. Furthermore, usage depends on the Canada Revenue Agency (CRA) having the correct mailing address for the recipient, which it lacks for many current non-filers.

The other initiative proposes to pilot a new automatic filing service next year.  However, the attention given to automatic filing is misplaced.  Although the returns of some low-income residents could be automatically prepared by populating various parts, the CRA will still need to contact non-filers to obtain their approval of their returns.  The CRA’s track record in contacting low-income non-filers and getting them to respond is extremely poor and there is no reason to believe the response to this new initiative will be any different.

In the next few years, if the CRA wants to reach more low-income people who are not filing their returns, it should focus on strengthening the CVITP.  The CVITP is the main initiative the CRA relies on to help meet the objectives of the federal government’s 2018 Poverty Reduction Strategy.  With over 50 years of direct person-to-person contact and the trust this engenders, the CVITP remains the CRA’s best option for increasing vulnerable people’s access to the benefits they are entitled to.

CRA Scales Back Its Ambition For The CVITP

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In this series of five short articles, we show how the CRA has publicly scaled back its growth ambitions for the CVITP.  We cover four distinct periods in the evolution of the CVITP over the last 10 years:

  • During the 2013-2017 period, the CVITP saw steady growth but this does not appear to be because of any explicit strategy.
  • In the 2018-2019 period, aided by the quadrupling of the budget to support its administration of this program, the CRA established its first performance targets for the CVITP.  These targets would cover the 2018 to 2021 tax seasons.  The CRA planned to achieve these targets without providing the community-based organizations and their volunteers who delivered this service any financial support.
  • The 2020-2021 period saw a collapse in CVITP services followed by a modest rebound.  This was due to the introduction of COVID-related public health restrictions which restricted in-person clinics, the main delivery model which had been used up to that point in time.
  • Given that the CVITP’s performance was well short of the targets established by the CRA, the Agency eliminated any further targeting or performance reporting to Parliament on the CVITP for the 2022-2024 period.  It also introduced a pilot grant program to provide modest support to community-based organizations hosting the CVITP during the 2021, 2022 and 2023 tax seasons.  The intent of the program is to provide a financial incentive for existing host organizations to take on more clients and new community-based programs to host CVITP services.  However, this period also coincides with the return to normalcy in public life.  Thus, we should expect the CVITP to recover some of the ground it lost in 2020 even in the absence of financial incentives.

Given the history of CRA’s changing ambitions for the CVITP, we draw three conclusions:

  1. The CRA’s track record in performance targeting with the CVITP illustrates how meaningless it is for federal departments and agencies to set, monitor and report on their own results.  When performance falls short of targets, these can be changed or dropped entirely to avoid the inconvenience of having to explain awkward results.  The elimination of any further performance indicator for the CVITP suggests the CRA no longer considers that the CVITP is part of its key responsibilities.
  2. CRA data for the 2022 tax season, the most recent available, show the CVITP’s numbers of returns completed and of individuals assisted represent about three quarters of the results achieved in the 2019 tax season.  Worse still, the number of returns completed is only a 13% increase over the number produced for the 2013 tax season (the earliest figure reported by the CRA).  And the number of individuals assisted is only about 80% of the number for the 2016 tax season (the earliest figure reported by the CRA).  Yet, over the same period, the Canadian population has grown and the federal government has increasingly resorted to using the return filing process as its principal tool for allocating a growing number of income-tested benefits.  It is unclear how, despite a quadrupling of its CVITP budget, the CRA has managed to produce such poor results.
  3. The fact that the CRA has quietly abandoned its growth ambitions for the CVITP calls into question the federal government’s statement in its 2018 Poverty Reduction Strategy (PRS) that the CVITP is a key program for helping to deliver on the PRS objectives.  If the PRS is genuinely a strategy and not just a communications tool, the federal government needs to follow up and ensure that the relevant departments and agencies it depends on to achieve the PRS objectives are implementing their initiatives effectively.  Someone senior inside the federal government needs to be calling the CRA to account for its poor implementation of the CVITP.

Helping Non-filers Access the CVITP to Increase Benefits Coverage

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In the first article in this series, we argued that the CRA’s existing non-filer benefits letter campaign was not effective.  In the second article, we reviewed a recent Auditor General (AG) of Canada report on the efforts of Employment and Social Development Canada (ESDC) and the CRA to help those in hard-to-reach populations who are non-filers to access benefits.  We concluded that the CRA does not know the size of the non-filer problem and, worse still, has done little to better inform itself.

The focus of our third article is on outlining some solutions to this problem.

The CRA believes that a lack of awareness about the benefits of filing is a key obstacle and has a number of outreach activities designed to address this problem.  Ironically, research commissioned by the CRA itself contradicts this; it identifies the main obstacles to be ones that the CVITP has already been designed to address.

In the AG’s report referred to above, the AG noted that the CRA and ESDC both have extensive outreach activities employing thousands of volunteer organizations across the country to target these same populations, but that the CRA and ESDC needed to adopt an integrated approach for people requiring extra help.  Closer collaboration by the CRA with ESDC could prove beneficial as ESDC’s competencies in working with community-based organizations could help the CRA to introduce better practices within the CVITP.

But even in the absence of strong collaboration, the CRA could still be doing more to help hard-to-reach populations to file their returns, in particular by making better use of the CVITP.  At present, the CRA seems to be counting principally on its three-year pilot grant program to build CVITP capacity by recruiting and retaining host organizations.  We remain sceptical that this program will genuinely increase the number of host organizations providing CVITP services.

The CRA cannot simply bet on strengthening CVITP capacity by increasing the number of host organizations and volunteers.  It also needs to make more efficient use of its existing CVITP host organizations and volunteers, ensuring that this infrastructure provides services to those who need it the most.  In particular, we have highlighted the importance of undertaking data analysis to inform the CRA’s strategic choices and have given specific examples to illustrate how this could be done.

In our review of the three-year pilot grant program when it was first introduced, we also illustrated how data analysis could be used specifically to inform choices about funding, including offering a larger financial incentive for returns filed by clients who had previously not filed for a number of years.  After the 2023 tax season, the CRA will be reviewing the implementation of its three-year pilot grant program.  Assuming it retains a modified grant program thereafter, it could include more generous grant payments for each return a host organization files for the 2020, 2021 and 2022 tax years with the highest payments for the oldest returns.

We close our third article in this series admitting that CRA money alone will not solve the problem of non-filers.  However, ESDC could play a larger role.  We will return to this in a future article, examining some of the ways in which ESDC could collaborate with the CRA in supporting the CVITP.

Auditor General Critical of Another CRA Effort to Identify Non-filers

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In our first article in this three-part series, we argued that the Canada Revenue Agency’s (CRA) Non-filer Benefits Letter Campaign was, at best, seriously underperforming on its intent, to get non-filers to file their outstanding returns.

In our second article, we look at what else the CRA may be doing to identify non-filers.  A February 2022 report from the Auditor General of Canada to Parliament (AG) entitled “Access to Benefits for Hard-to-Reach Populations” sheds further light on this question.  The report looks at the work of Employment and Social Development Canada (ESDC) in administering the Guaranteed Income Supplement (GIS) and the Canada Learning Bond (CLB), and the work of the CRA in administering the Canada Child Benefit (CCB) and the Canada Workers Benefit (CWB).

The AG focused on how well ESDC and the CRA are doing in getting these benefits to all residents who are eligible to receive them, what it calls the coverage rate.  Since the filing of a return is a condition for obtaining (CWB) or maintaining (GIS and CCB) the benefit, or again for establishing eligibility for the benefit (CLB), the CRA’s and ESDC’s work on the take-up gap, or the percentage of eligible residents who are not benefit recipients can inform the discussion about non-filers.

The AG found that “[ESDC and CRA] estimates overstated the take-up of benefits because they did not always account for people who had not filed tax returns, which are required to access most benefits.”  The AG also found that the CRA and ESDC “did not have a complete estimate of the overall take-up rates of the selected benefits.  Nor did they know the take-up rates of specific hard-to-reach populations known to experience barriers to accessing benefits.”  What was the CRA doing to improve its understanding of the size of the gap between eligible and actual benefit coverage?  The AG found that “[n]o tangible progress had yet been achieved in data collection, measurement, or analysis of benefit take-up.”

Finally, this article examines the relevance of the AG’s report to the CVITP.  CVITP host organizations know that one of the key barriers to filing a return is the lack of free return preparation services.  This is why these organizations offer CVITP services: they understand that, for the clients they serve (many of whom fall squarely within the hard-to-reach populations identified by the AG), providing this free service is critical to obtaining federal and provincial or territorial benefits which contribute toward reducing income-based poverty.

The first two articles in this series set the stage for what more the CRA could be doing to reach non-filers, the subject of the third and final article.

Disappointing Distraction: The CRA’s Non-filers Benefits Letter Campaign

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Two years ago, we posted an article on the issue of non-filers.  We are now updating this with a series of three articles.

The first article in this series looks at the Canada Revenue Agency’s (CRA) non-filer benefit letter campaign which has been running for six years.  This campaign entails the CRA sending letters to people who have not filed a return in the most recent tax season.  These letters outline the benefits of filing a return.  Then the CRA tracks whether or not the letter recipients file a return in the next tax season.

We argue that the performance of this campaign has been, at best, insufficient at dealing with the size of the non-filer problem.  Less charitably, we argue that it represents a minimalist effort on the part of the CRA.  Worse still, we believe the success of this effort, such as it is, is based on the faulty assumption that these letters actually motivate recipients.  Research commissioned by the CRA and others shows that a lack of knowledge about the benefits of filing is not identified as one of the main barriers to filing a return.  The CRA makes very little data available on this initiative but we strongly suspect that, even in the absence of this letter campaign, a similar number of non-filers from one tax season would likely file in the next.

This article lays the groundwork for a discussion in the next two articles of more effective approaches to addressing the issue.  As we hope will become readily apparent to the reader, the CVITP has an important, but as of yet vastly underexploited, role to play in helping to tackle this issue.

The Evolution of the CVITP – 2022 Update

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Canada Revenue Agency’s (CRA) recently released Departmental Results Report for fiscal year 21/22 allows us to complete the 2022 update for the evolution of the CVITP.  We have divided this subject into three short articles.  The first focuses on the results from delivering CVITP service to clients.  It includes all the data with accompanying commentary on individuals assisted, returns filed and value generated.  The second focuses on the CVITP infrastructure needed to provide this service.  It also provides all the data with accompanying commentary on host organizations and volunteers.  The third is a new feature which provides some simple measures of CVITP productivity.

Short on time?  Here are the key developments:

NO INCREASE IN CVITP SERVICE IN 2022

  • While the CRA calls the number for individuals assisted in the 2022 tax season an approximation, it is roughly the same as in the 2021 tax season; in other words, there has been no increase in service.  The 2021 tax season saw a partial rebound in numbers after the sharp decline in 2020 but it was still well below the numbers reached in 2016 and far from the peak in 2019. 
  • The trend for returns filed largely mirrors that of individuals assisted.
  • While the CVITP was making progress in filing more of its clients’ prior year returns up until and including the 2020 tax season, its performance in this area declined in 2022.
  • For the first time, the CRA has reported in its Departmental Result Report on value of the refund and benefits generated through the CVITP.  This is a very welcome development, and we hope that the CRA continues this practice in the future.  As the main rationale for offering a CVITP clinic is not to help individuals pay income tax but to help them maintain access to many poverty-reducing benefits, this figure provides tangible evidence of the real value generated for CVITP clients.

NUMBER OF HOST ORGANIZATIONS REBOUNDS BUT NUMBER OF VOLUNTEERS CONTINUES TO DECLINE

  • The number of host organizations offering CVITP service has largely rebounded in the 2022 tax season following the precipitous decline due to COVID health restrictions.
  • The trend in volunteers has been in decline since it peaked in the 2019 tax season.  The small rebound in the CRA count for 2022 is, we believe, misleading.  This is due to an unusual interpretation which the CRA makes in whom it classifies as a volunteer.  In partially correcting for this with an adjusted estimate, we show that the small rebound in 2022 is illusory and that the number of volunteers continues to decline.

PRODUCTIVITY REBOUNDS FOR VOLUNTEERS BUT NOT FOR HOST ORGANIZATIONS

  • Averages of individuals assisted and returns filed per volunteer fully rebound to the peaks achieved in the 2017 tax season.
  • Averages of individuals assisted and returns filed per host organization are only 70% and 71% respectively of the peaks achieved in the 2017 tax season.

For further analysis, charts with trends, tables with data and their sources, see:

How to Get Experienced Volunteers Back Next Year

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Once a CVITP volunteer has been recruited, trained and gained some experience, the CVITP stands to gain if the volunteer comes back again next year.  Given that the Canada Revenue Agency (CRA) does not publish information about its volunteers, we do not know if the root of the problem behind its stagnating volunteer numbers is principally one of poor recruitment of new volunteers or of poor retention of existing volunteers.

Just as with the recruitment of new volunteers, the CRA currently relies primarily on its host organizations’ efforts to retain their existing volunteers for the next tax season.  Yet the evidence suggests this indirect approach, mediated via its host organizations, is not working.  In this article, we propose ways for the CRA to get directly involved in efforts to retain its existing CVITP volunteers.

Volunteers need to be recognized for their efforts.  This is a fundamental aspect of any organization’s work on retaining its volunteer.  However, at present the CRA does remarkably little to recognize its CVITP volunteers’ contributions.

This article offers ideas for the CRA to better acknowledge their volunteers’ contributions both to the volunteers themselves and to the wider community.  It also includes some other measures the CRA could take to help retain experienced volunteers.

These suggestions are informed by Volunteer Canada’s Canadian Code for Volunteer Involvement (CCVI) and, in particular, its checklists for putting the Code into action (including the checklist on recruitment on page 9).  While it has not adopted the Code, we believe the CRA should heed its advice as the Code represents the industry standard for Canadian organizations, whether non profit or government, in working with volunteers.

Stagnating Volunteer Numbers: Will CRA Succeed In Recruiting Better?

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The federal government has frequently indicated it wants the CVITP to grow.  In recent years, the CVITP budget has quadrupled to expedite this growth.  As volunteers lie at the heart of the CVITP’s service delivery, the Canada Revenue Agency (CRA) needs to ramp up recruitment.  How’s that going?

In the first article of this three-part series, we explore the current trends for volunteering in Canada and in the CVITP.  We present evidence suggesting that the CVITP faces an existential threat with stagnant or declining volunteer numbers.

In the second article of this series, we review what the CRA has recently said about its plans for volunteer recruitment.  It appears to rely primarily on the volunteer recruitment efforts of its host organizations to grow its volunteer base.  Yet the evidence suggests this indirect approach, mediated via its host organizations, is not working.

Gambling further on using just this approach poses a great risk to the future success of the CVITP.  The third and final article proposes that the CRA also get directly involved in more actively recruiting volunteers.  The article offers ideas in three areas:  developing appropriate promotional materials, launching an annual recruitment campaign, and using diverse media.  These are used to illustrate what this more direct approach might look like.   The article also suggests how the CRA could manage this direct approach. 

These suggestions are informed by Volunteer Canada’s Canadian Code for Volunteer Involvement (CCVI) and, in particular, its checklists for putting the Code into action (including the checklist on recruitment on page 9).  While it has not adopted the Code, we believe the CRA should heed its advice as the Code represents the industry standard for Canadian organizations, whether non profit or government, in working with volunteers.

Once the CRA has recruited new volunteers, what can it do to keep them?  Watch for our forthcoming article on CVITP volunteer retention.

Messaging Confusion: The CRA Has More Than Just A Marketing Challenge

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The CRA markets the CVITP clinics as a place for low-income residents to get their taxes prepared.  Yet this is increasingly at odds with the experience of most of the CVITP’s clients.  They do not come to CVITP clinics to get a year-end reconciliation of the income tax they owe as their incomes are too low to pay tax.  They come because they know, from prior experience, that they can only continue to get important federal and provincial/territorial benefits if they file a return.

In this article, we explore why it matters that the CRA misrepresents the CVITP clinics in its marketing.  We recommend an alternate way of marketing the CVITP which better aligns with the reality lived by its current and potential clients.

Changing the way the CRA markets the CVITP makes it sound like it’s an isolated problem with an easy fix.  But we believe the mismatch between the CRA’s current marketing messages and the reality on the ground is indicative of a larger challenge: the CRA needs to update its vision of the CVITP.

It is no longer just a free tax preparation service.  It has also become – and arguably more importantly – a community-based service which helps low-income residents maintain their access to important poverty reducing benefits.  The evolution of the income tax and benefit system and the return preparation process it employs have driven this change.

A realistic appreciation of the two functions currently carried out by the CVITP suggests the CRA needs to embrace a different approach to its administration of the CVITP.  This new approach should emphasize the dual function throughout four stages (i.e., recruitment, training, supervision and support, recognition and retention) in the administration of the CVITP’s service delivery.  We give two examples in our article to illustrate the kind of changes this might entail.  Future articles will offer many more examples.

Collecting and Analyzing Data to Improve Service and Demonstrate Impact

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When personal information is stripped from client returns and the remaining information is aggregated, a host organization can make at least two uses of the ensuing data.  It can use the demographic and economic data to learn more about the population currently served and to improve targeting efforts in the design of future tax clinics.  The host organization can also use data on the benefits and credits generated for clients to demonstrate to its various stakeholders the impact of the current CVITP service on their clients’ financial situations.

Annually, the Canada Revenue Agency (CRA) strips the personal information from returns and provides the demographic and economic data to Statistics Canada for publication.  Infrequently, the CRA has also aggregated the data from returns on benefits and credits at the national and provincial levels and shared the figures publicly.  Given the advent of the CVITP Organization Identification Number or COIN in 2021, it is now technically feasible for the CRA to do all this for each individual host organization as well.

There are two reasons why we believe it is in the CRA’s own interest to do this.  First, by providing data to individual host organizations on the benefits and credits generated by their CVITP clinics for their clients, the CRA would be helping them to make the case to donors.  Increased donor funding would alleviate a serious resource constraint for many host organizations.  In turn, this could reduce some of the pressure on the CRA to provide funding while, at the same time, increase client access to CVITP services.

Second, by obtaining demographic and economic data on the clients served by its CVITP service, the host organization can learn more about the population currently benefiting from its CVITP service.  Where there is a mismatch between this data and the population the host organization wishes to serve, this information can be used to help better target CVITP services in the next tax season.  In turn, this could increase access to CVITP services by clients who need these the most.

In both instances, the provision of data to host organizations could help the CRA to better contribute to meeting the objectives of the federal government’s Poverty Reduction Strategy (PRS).

Quite apart from doing this to fulfill its obligation to support the government’s PRS, we believe the CRA has an obligation, as a good partner, to provide its host organizations with their data.  Currently, most host organizations offer CVITP clinics with little or no support from the CRA.  Providing this data would be one of the most important contributions the CRA could make to help its host organizations.

Although the CRA does not presently do this, some host organizations are collecting and analyzing client data from their CVITP clinics.   However, most are not.  This article explores five challenges host organizations face in doing this:

  • A lack of interest or understanding within the host organization about the importance of this data
  • Addressing client consent considerations
  • Handling client privacy issues
  • Finding staff or volunteer time to collect the data
  • Finding the expertise to analyze the data

Our experience is that host organizations mandated to promote their clients’ financial empowerment are the most successful at present in addressing these challenges.  As they already receive donor funding in support of this mandate, they are well positioned to tackle these challenges.

On the other hand, most host organizations providing CVITP services do not have clients’ financial empowerment as part of their core mandate.  Thus, they probably do not receive donor funding specifically to support their CVITP services.

One final reflection: our article addresses the use of anonymized data found in client returns.  To improve on the delivery of their CVITP services, host organizations also need to find ways to get data on non-filers within their potential client base.

Implementation of CRA’s Pilot Grant Program in Year 1 of 3 – A Slow Start to Missing the Mark

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In 2021, the Canada Revenue Agency (CRA) introduced a new pilot grant program that provides financial support to some CVITP host organizations.  When it was introduced, we had a lot to say about it here.

The pilot program has completed the first of its three years.  As is unfortunately typical of the CRA in its reporting on the CVITP, there is a dearth of information on the first year of this pilot.  However, there is one important piece of information cited in the CRA’s Departmental Plan for the 2022-23 fiscal year: “In the first year alone, the CRA sent just under one million dollars to qualifying organizations across Canada to support their efforts to ensure that vulnerable people have the ability to file tax returns and access the benefits and credits designed to support them.”

Remember: the budget for this three-year pilot grant program is $10 million; this amounts to an average of $3.3 million being available each year to support host organizations.  Disbursing less than $1 million in the first of the three years raises serious question about the ability of the pilot grant program to meet its stated objectives: defraying organizations’ costs of hosting CVITP clinics and encouraging more organizations to host CVITP clinics.

In the following article, we show that it has budgeted too much for this pilot or, on the basis of the current budget, it is simply too stingy with the current payments to meet its goals.  We predict that the pilot program will complete its three years well under budget.  There are two design elements we stated when the pilot program was first launched which are likely to contribute to this outcome: administrative arrangements that are burdensome, deterring some host organizations from applying for the grant, combined with grant amount limits that are too low to serve as an incentive for host organizations.

We note that the indicators the CRA has said it will use to determine the success of the pilot are likely to yield misleading conclusions.  This is because the implementation of the pilot program coincides with the period immediately following COVID, when the numbers for the CVITP had plummeted and thus could be expected to rebound anyways.

We also believe that the indicators the CRA is using are the wrong ones as none of them gets at the real purpose of the CVITP.  As noted in one of our articles assessing the pilot program when it was first launched, at its core the CVITP is about the income levels of the clients it serves.  Therefore, the pilot program should aim to increase the number of returns filed by a host organization for clients whose incomes fall at or below the poverty line, not simply the number of returns filed nor, for that matter, host organizations and volunteers enlisted in the CVITP.  Until the CRA draws a closer link between its CVITP and the objectives contained in the federal government’s Poverty Reduction Strategy, it will continue to miss the mark with opportunities like its pilot grant program.

Ambivalent Administrator: a Contradiction in the CRA’s Relationship with the CVITP

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Contradiction

Canadian residents with taxable income have a legal obligation to file a return.  But Canadian residents with no taxable income have no legal obligation to file a return.  What does the CRA do in the latter case, when a resident with no taxable income does not file a return and thus loses access to benefits that are contingent upon filing a return?

We believe the federal government has an expectation that the CRA will not be passive but will actively encourage residents to file.  This is because the federal government has identified so many of the benefits contingent upon filing a return as key to achieving the objectives identified in its Poverty Reduction Strategy.  And, as the federal government’s administrator of its system for filing returns, the CRA is the gatekeeper for gaining and retaining access to so many of these benefits.

The CRA’s current actions with respect to the CVITP suggest it has a highly ambivalent attitude toward the CVITP, its main program for assisting low-income residents to file their returns.  Why do we say this?

For two reasons.  First, we believe the CRA has adopted two approaches which, taken together, are contradictory.

On the one hand, the CRA has repeatedly stated the importance of maintain what it calls an arms-length relationship with CVITP host organizations (see 4 in diagram above) and their volunteers (see 5 in diagram).  For example, on page 41 of the 2020 report on the CVITP by the Taxpayers’ Ombudsman, the CRA states that it: “…strives to provide as much support as possible to the volunteers and partner organizations, while maintaining the arms-length relationship required to mitigate the liability risks that would be associated with any prescribed involvement in tax return preparation by the CRA.” 

Yet it is unclear what exactly the CRA means by an “arms-length relationship” in the CVITP context.  The CRA says it needs to maintain some distance from – or, to word it another way, not work too closely with – host organizations and their volunteers to mitigate any risks the CRA might run as a result of the returns these partners prepare for clients.

On the other hand, the CRA clearly states on its website that it is prepared to do the returns of those residents with a modest income and a simple tax situation who have used a free tax clinic before or are eligible to use one (see 1 in diagram). 

The CRA’s willingness to do the returns of low-income people and accept the risks this entails is puzzling.  It seems to contradict the CRA’s own argument about the need to mitigate for the liability risks associated with its involvement in the CVITP return preparation process by maintaining some distance from its partners.

Second, the main rationale for the CVITP is to help low-income people access benefits and credits to which they are entitled, not to pay income tax as most CVITP clients do not owe income tax.  Nevertheless, in the four years since the federal government’s publication of its Poverty Reduction Strategy (PRS), the CRA has never once publicly acknowledged the link the federal government has established between the CVITP and the PRS’s goals.

Events over the last three years should shake the CRA of its ambivalence.  Just as the CRA has seen its budget for the CVITP quadrupled with the aim of doubling its client numbers, it saw those numbers dip by a third from their peak.  If the CVITP is to be turned around, the CRA must get off the fence and take more initiative.

In the following article, we provide more details on all of this and options for the administration of the CVITP.