Category Archives: Non-filers

How to Reduce the Number of Chronic Non-filers by Using the CVITP Better

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In the first article in this three-part series, we argued that while the number of current non-filers may not be as large as some popular estimates, the number is still very large and represents a serious drag on achieving the federal government’s poverty reduction objectives.   In the second article, we focused on recent non-filers, those who forget to file, file late, or skip one or two tax years.  Most importantly, these clients have a current mailing address on file with the CRA, enabling the CRA to communicate with them.  We looked at the non-filers benefits letter campaign and the forthcoming automatic filing pilot project to see how the CVITP could help to enhance the performance of these two initiatives.

In this third and final article, we look at the situation of chronic non-filers, those who have not filed for many years and make up the majority of estimated non-filers.  The CRA’s chief problem is that it does not have current mailing addresses for these clients.  Therefore, it has no way of communicating directly with them.  Yet this is the group the CRA should be trying to make progress in reaching if it is to substantially increase its coverage of poverty reducing benefits.

This article focuses on ways we think the CRA could also make use of the CVITP to target chronic non-filers.  To do so successfully, it will have to meet two pre-conditions.  First, it will have to become less reluctant to taking direct action in providing strategic direction and strong managerial support to the CVITP.  Second, it will have to change its vision for the CVITP from a free tax return preparation service to one that also includes helping low-income residents maintain their access to important poverty reducing benefits.

Assuming the CRA can meet these two conditions (and we acknowledge this is a big assumption), the article looks at ways it can better invest in its two partners to reach and effectively serve chronic non-filers.  With respect to community-based organizations that host CVITP clinics, we make suggestions to the CRA for changes to its funding formula, for providing data to improve client service and reporting on impact, and for assisting with coordination efforts.  We also have suggestions for the CRA regarding its other CVITP partner, volunteers; these cover their recruitment, training, supervision and support, and recognition and retention.

Finally, we close the article looking at how the CRA can better track its progress in contributing to the reduction of poverty through the CVITP by using more appropriate indicators than those it currently reports against.

How to Reduce the Number of Recent Non-filers by Using the CVITP Better

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In our first article in this series, we argued that while the number of current non-filers may not be as large as some popular estimates, the number is still very large and represents a serious drag on achieving the federal government’s poverty reduction objectives.  In this second and the next article, we show how the Canada Revenue Agency (CRA) could make better use of the CVITP to reduce the number of non-filers more effectively than its current efforts.

This second article deals with recent non-filers, those who forget to file, file late, or skip one or two tax years.  Most importantly, the CRA can still communicate with these clients as it has their current mailing addresses.

We focus on two initiatives.  The non-filers benefit letter campaign has been operating since 2016.  (We have previously reviewed this initiative here.)  We suggest providing letter recipients with the name, address and phone number of the closest CVITP host organization where they can get their returns done for free, and informing these organizations of the names and addresses of letter recipients who have been referred to them.  This may improve the rate at which letter recipients, most of whom are recent non-filers, respond.

The automatic filing of income tax and benefit returns will be experimented with starting next year.  (We recently reviewed this new initiative here.)  Some traditional CVITP clients may receive a pre-populated return from the CRA to review and send back, confirming the information contained in the return is complete and accurate.  Should they have any questions about their return or the process, some clients receiving such a return may not own a phone with which to call the CRA.  Others may not trust the CRA to provide clear answers to their questions.  Yet again others may not understand what is being asked of them.  To increase the success of this initiative, we recommend involving CVITP host organizations and their volunteers to help answer questions these clients may have.  While these clients are unlikely to be non-filers, if this initiative is successful, it will reduce the number of traditional CVITP clients thereby freeing up CVITP capacity to take on new clients, some of whom may not have filed a return in many years.

Neither of these initiatives is likely to substantially reduce the number of what we call chronic non-filers who make up the majority of non-filers.  The CRA’s chief problem is that it does not have current mailing addresses for these clients.  Therefore, it has no way of communicating directly with them.  Yet this is the group the CRA should be trying to make inroads with if it is to substantially increase its coverage of poverty reducing benefits. We believe the CRA could also make use of the CVITP to reduce the number of chronic non-filers.  This will be the subject of the third and final article in this series.

How Many People Failed to File a 2021 Return?

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This is the first article in a three-part series.  This article argues that, while the number of current non-filers may not be as large as some popular estimates, the number is still very large and represents a serious drag on the federal government’s poverty reduction objectives.

Robson and Schwartz estimate 10-12% of Canadian residents eligible to file a return failed to do so in 2015.  While this estimate continues to circulate in the media today, other estimates suggest the non-filer rate has fallen significantly since then.  Using one of the more intuitive methods employed by Robson and Schwarz, we estimate that the non-filer rate had dropped to around 4.8% by 2021.  However, this still means that approximately 1.5 million Canadian residents eligible to file a return failed to do so in 2021.  As most of these were low-income residents, many missed claiming federal and provincial or territorial income-tested benefits designed to reduce poverty.  Getting these residents to file a return will be key to meeting the federal government’s objectives laid out in its 2018 Poverty Reduction Strategy.

The next two articles will propose elements of a strategy whereby the CRA could make more effective use of the CVITP to reduce the number of non-filers, making an important contribution to poverty reduction.

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.

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.

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?”

The Issue of Non-filers

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Conservative estimates suggest there are over 1 million eligible people in Canada who do not file annually.  A significant number, perhaps the majority, are individuals living on very low incomes.  Because they do not file, they are missing out on important federal and provincial/territorial benefits.

The Canada Revenue Agency (CRA) recently introduced an initiative to encourage low-income non-filers to file their income tax and benefit returns.  However, the success rate for this initiative is pitifully low.

This article suggests why the CRA should and how it could work with CVITP host organizations to significantly increase the number of low-income non-filers who decide to file returns.