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.