March 14, 2023

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Although not common, there comes a time in every volunteer’s work where you need to get on the phone with the client and call the Canada Revenue Agency (CRA) CVITP Helpline.  It may be because there’s information you need to complete the client’s return which only the CRA has.  Or it may be because neither the client nor you understand correspondence the client has received from the CRA.  Then again, it may simply be because the client is asking a question about their file with the CRA, and you want to assist them.  Whatever the case, you will be calling the CVITP Helpline, together with the client, to speak with a CRA agent.

Before going further, we should stress that we really, really like the CVITP Helpline.  We think it is a great innovation.  And we usually end up speaking with very dedicated CRA agents who really do want to help.  But more frequently than we would like, we have an experience which reminds us just how incredibly difficult it can be for some clients in communicating with the CRA.  The barriers to client identification can be onerous, even for a client who is very well prepared going into the call.

The context

At present, there are two ways for the volunteer to help the client to get in touch with the CRA.

One way is for the client to sign the form AUT-01, “Authorize a Representative for Offline Access”. This form must be mailed or faxed.  The CRA’s service standard is to process it within four weeks. Then the volunteer phones the CRA without the client needing to be present on the call to seek account information on behalf of the client.

The other way is to have the client on the call when the volunteer phones the CVITP Helpline. The volunteer describes the issue briefly, and then passes the call to the client.  The CRA agent then asks the client several questions to satisfy themselves that the person on the call really is the client.  During this process, the volunteer must remain completely silent.  Once the CRA agent is satisfied of the client’s identity, they will ask the client if the volunteer can rejoin the call.  When the client agrees, the volunteer can then enter a discussion with the CRA agent, seeking answers to questions that involve the client’s account information.

The problem

Neither way works well.

Our one experience using the AUT-01 form was pointless.  The CRA agent started asking questions about the client including the address the client had used three to four years ago.  When we indicated we did not know because our client could not remember this information and therefore had not provided it in advance, the agent terminated the call.

Since the start of the COVID pandemic, almost all our calls have been with the client in a separate location (using a three-way call).  These calls are sometimes successful, but too often their success or failure depends on the CRA agent who takes the call.  Some CRA agents appear to detect from the way they answer that the client is likely to have problems with some of these questions.  So the CRA agent goes out of their way to permit the call to proceed.  But this is not always the case.

There are various reasons this approach often fails:

• a client will become very nervous and unable to answer even a simple question;
• questions about prior addresses can be very difficult, because the client may be unable to remember things like the number of the house on the street where they had lived, the exact unit number of an apartment, or the postal code;
• equally, questions about income amounts on various lines of prior Notices of Assessments (NoAs) are very difficult as the clients we deal with typically do not keep good paper records nor have they set up a MyAccount with the CRA and thus have no access to their prior NoAs;
• in preparing a client for a call, the client might have assembled all the documents they have kept but then, during the call the client does not understand a question posed by the CRA agent nor know where to look in their pile of documents yet any suggestion from the volunteer to the client (e.g., “look on the page headed 2019 Notice of Assessment”) may cause the agent to terminate the call.

The client ends up being frustrated and scared away from calling the CRA again.  They may also lose faith in the competence of the volunteer, thereby damaging the reputation of the host organization.

Absent further assistance from the volunteer, the problem will remain unresolved.

Too often the result is that the volunteer resorts to preparing a letter from the client to the CRA requesting the specific account information.  This adds a burden to the CRA which must now prepare a written reply.  And the reply may take up to two months.  Of course, it goes to the address of the client who may forget to contact the volunteer again.

This alternative is very unsatisfactory because, to get the more useful answer, a dialogue is usually required.

Our proposal

We suggest that the CRA develop a procedure for the CVITP helpline whereby a volunteer can identify themselves to an agent and proceed to obtain information about a client without the client being on the call. The agent would ask questions of the volunteer to satisfy themselves that the caller is a fully approved CVITP volunteer authorized to speak on behalf of the client.  We believe that such a procedure would be consistent with the policies and procedures the CRA currently has in place to protect client confidentiality.

Here is what it would look like.

1. Prior to the call but on the same day, the CVITP volunteer submits a successful Federal Authorization request for the client in question.
2. Then the volunteer calls the CVITP Helpline (remember: the client is not present for the call).
3. The CRA agent on the CVITP Helpline asks questions of the volunteer to convince themselves that the caller is a bona fide CVITP volunteer approved by the CRA:
   • First, the caller would be asked for their name as well as their unique EFile and RepID identifiers.
   • Then the caller would be asked for their Social Insurance Number (SIN), date of birth, and home address.
   • Finally, the caller would be asked for the name, SIN and date of birth of the client they are calling about.
4. The CRA agent could confirm in their system that the Federal Authorization has been filed for the client in question by a RepID identifier which corresponds with the information provided by the CVITP volunteer.
5. Where there are problems with the spelling of a client’s name in the CRA’s database (a frequent challenge) which means the Federal Authorization request cannot be filed, the CRA could still consider using the three elements in paragraph 3 above to establish that the caller is a bona fide CVITP volunteer.

Once the CRA agent is satisfied as to the volunteer’s identity, the volunteer could ask questions on behalf of the client.

Managing concerns about the confidentiality and security of client information

The current procedure in which the CRA agent confirms the identity of the client through questioning has been put in place to safeguard client information from its release under fraudulent circumstances.  Given this concern, we believe the following considerations with respect to our proposal are relevant.

First, a CVITP volunteer only receives their unique EFile and RepID identifiers when they have satisfied several conditions established by the CRA:

• The EFile identifier is issued or renewed after the CRA has satisfied itself that the volunteer has not previously abused the trust placed in them by the CRA and meets other conditions, such as being current in filing their own income tax and benefit returns. (The EFile identifier is renewed annually and can be disabled at any time by the CRA.)
• To use the Autofill My Return function, the volunteer must also have a RepID identifier. (The RepID identifier can also be disabled at any time by the CRA.)
• Before being fully approved by the CRA, the volunteer must be formally affiliated with a host organization which has itself been accredited by the CRA.  In addition, the host organization must confirm with the CRA that it has on file a current Police Records Check for the volunteer.

Second, the CRA already permits a CVITP volunteer to access a large amount of confidential personal information about a client, and to do so without requiring the volunteer to work under the close supervision of other authorities.  Among other things, this information includes the client’s:

• SIN and date of birth and, where relevant, their spouse’s name and those of any children;
• Current address and, where relevant, previous addresses;
• Phone number;
• Marital status, and where the marital status has changed within the tax year, details on the nature of the change;
• If a Disability Tax Credit is on file, knowledge of the type of disability;
• Income information;
• Status with respect to outstanding returns; and
• Banking information should the client wish to set up direct deposit when their return is efiled.

Given the foregoing, we believe there is little to no additional risk to the security and confidentiality of client information in adopting the procedure we propose above.

Conclusion

The CRA needs to place more trust in the rigorous security and confidentiality procedures it already has in place for the CVITP.  Adopting the aforementioned procedure, or something very much like it, would go some way toward reducing client stress and increasing the efficient use of CRA and CVITP volunteer resources.