October
24, 2017.
P.O.
Box 384,
Mirror,
Alberta
T0B
3C0
The
Office of the Prime Minister,
50
Wellington Street,
Ottawa,
Ontario
K1A
0A2
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decades ago the Alberta government rescinded funding for insulin syringes for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.
Yours
truly,
(Mrs.) Margaret Blank
Cc.: Mr. Blaine Calkins, MP, Red
Deer-Lacombe
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