October 24, 2017.
P.O. Box 384,
The Office of the Prime Minister,
50 Wellington Street,
Dear Mr. Trudeau
I am writing with respect to apparent changes being made in the interpretation of who and who is not eligible to access the Disability Tax Credit. Specifically, I understand from recent news reporting and commentary that there is a large and growing number of Canadians with type 1 diabetes (T1D) being denied relief through Canada’s Disability Tax Credit (DTC).
An incurable chronic medical condition affecting nearly 250,000 Canadians, T1D requires injections or infusions of insulin throughout the day in order to sustain life. To determine the dose of insulin required, individuals must test their blood (sugar) glucose six or more times a day. Canadians with T1D are at constant risk of dangerously high blood sugar, which can lead to complications, or dangerously low blood sugar, which can result in a coma or death. Diabetes is the leading cause of amputations, blindness, kidney and heart disease, and other debilitating conditions. Regardless of whether they are a child or an adult with T1D, patients should have the same rigorous standards of care.
The costs of managing this challenging and expensive disease are significant and increasing. Those using insulin pumps and continuous glucose monitoring may face out-of-pocket costs of more than $15,000 per year. Studies show that these costs adversely affect the ability of some with T1D to follow their prescribed treatment protocol, at significant negative impact to their long-term health and at significant cost to the Canadian health care system.
I was married for thirty-one years to a man who developed T1D at age 7. He died in 2006, a few months before his 54th birthday. The last ten years of his life were particularly difficult as, despite careful management of his illness, its destructive nature became more and more evident. During this time I was the sole provider for our family (we have two children), and he received a Canada Pension disability benefit. His disease was a ‘pre-existing condition’ that disqualified him from receiving any benefits from the private disability insurance he had through his former employer. (He left the work force in 1987 to better manage his disease’s progression.)
Although decades ago the Alberta government rescinded funding for insulin syringes for all who need them – choosing instead to give free syringes only to drug addicts -- I remain thankful for our public health care system, which covered the cost of kidney dialysis from 1996 through to his death, as well as the cost of many hospital visits, home nursing care and a thrice-weekly assistant for breakfast and morning care, not to mention the public health support we received for things like artificial limbs (he lost both legs below the knee) etc. The Disability Tax Credit was an important part of managing our household finances during these years.
Many Canadians living with T1D have long claimed the Disability Tax Credit (DTC) under the category of Life Sustaining Therapy, given that intensive insulin therapy is complex and time-consuming. For those Canadians with T1D that have accessed the DTC, the credit has helped defray some of the uninsurable costs of insulin therapy. It is also money well spent, as countless studies have shown that people with diabetes who manage their disease more rigorously have fewer complications and therefore cost the health care system far less over time.
Unfortunately, the DTC has always been inconsistently granted, and recently that inconsistency has grown markedly worse to the point where it has become very difficult, if not impossible, for adults with T1D to qualify for the DTC. Diabetes Canada is investigating this issue and informs me that more than 80 per cent of the applications being received from people with T1D are now being denied, whereas a year ago 80 per cent were being approved.
If the CRA has taken a policy change to arrive at the conclusion that adults independently administering insulin therapy (people with T1D) don’t need 14 hours to do so, they should be required to engage in consultation on that policy change and to communicate it broadly to all stakeholders. I see no evidence that this has been done in this case.
Despite physicians having duly certified, in accordance with the Income Tax Act, that their patients require more than 14 hours a week for their insulin therapy, applicants are now being denied on the basis that “the type of therapy indicated does not meet the 14 hour per week criteria.” These denials are in contradiction of the certifications provided by licensed medical practitioners and do not appear to be based on evidence. The medical practitioners who certify these applications for the DTC do so based upon their detailed understanding of this disease and its management, as well as based upon a personal knowledge of their patient’s self-management practices. In short, they are best positioned to opine on whether the patient is actually spending the minimum of 14 hours per week on applicable activities, as the clinician is certifying. To question the accuracy of a certification is to question the knowledge and/or integrity of the certifying clinician.
T1D – as do other so-called ‘chronic’ illnesses – takes a toll not only on the person who has the disease, but also on that person’s family – spouse, children, and parents. In 2013 I began a textile art project that became an installation exhibited in the gallery space at the Lacombe Memorial Centre last year. Included with this installation is my book, Mark on the Body: Honouring Those Who Live with Type 1 Diabetes. This book remains available for purchase; all proceeds are divided between JDRF Canada and Diabetes Canada, organizations which support research into the cause(s), better treatment modalities, and hopes for both prevention and cure of T1D, and which provide education for those who live with this disease. I enclose a copy and encourage you to read it so that you will have a first-hand account of the journey of a real family with a real person who lived with T1D and who died of it.
Given all of the above information, and the personal experience of our family, I would ask you to intercede with Minister Lebouthillier to ask the staff at the CRA to:
1) Follow the stated practice and guidelines required of the medical community, accept the certifications of medical professionals regarding their patient’s individual circumstances, and approve the applications for the DTC of Canadians with T1D who rightfully qualify. This includes those who, if they wear an insulin pump to manage their disease, have that form of treatment included in the “14 hours a day” touted by the Minister in her interpretation of the legislation.
2) If the CRA has taken a change in policy or standards affecting applications of adults with diabetes for the DTC, to engage in open and transparent stakeholder consultations and communications on the matter.
I thank you for taking the time to read and digest this information. I will be forwarding a copy of this letter and my book to my MP, Mr. Calkins for his information as well. I welcome the opportunity to have further communications on the issue of living with chronic illness, but particularly with T1D.
(Mrs.) Margaret Blank
Cc.: Mr. Blaine Calkins, MP, Red Deer-Lacombe