Accessibility consultation report

Context and Background

In 2019, the Accessible Canada Act (the Act) was passed to create a barrier-free Canada by 2040. The Act requires all organizations under the federal government to prepare and publish accessibility plans to identify, remove, and prevent accessibility barriers. The development of these accessibility plans requires consultations with persons with disabilities. The importance of consultation and engagement cannot be understated, as the accessibility plans must address the accessibility barriers that persons with disabilities across Canada face every day.

Accessibility barriers prevent persons with disabilities and their caregivers from accessing information and completing tasks. According to Statistics Canada, 22% of Canadians have one or more disabilities, whether they are related to mobility, hearing, vision, cognition, mental health or others (2017 Canadian Survey on Disability).

The Canada Revenue Agency (CRA) is committed to eliminating accessibility barriers and meeting the requirements of the Act. Between April and May 2022, the CRA held a six week-long public consultation process to learn about accessibility barriers that persons with disabilities have encountered with the CRA’s external programs and services, and how those barriers affected their experiences. The consultation process was designed and facilitated by Delaney, the engagement people, a neutral third party who worked with the CRA project team on the consultation planning, implementation, and the analysis of findings. A total of 627 people participated in the process through a number of consultation and engagement methods including: virtual group discussions, virtual and phone interviews, an online questionnaire, and phone and email submissions.

Input received through this process is summarized in this report and will be used to develop the CRA’s first Accessibility Plan, to be completed and released publicly by December 31, 2022.

While participants shared a number of barriers and solutions to barriers, three key themes emerged through this process. These will be discussed further in this report:

• 1) Awareness & Respect
• 2) Accessing Information
• 3) Options for Interaction

The Consultation Process

Throughout the consultation process, participants were asked to share:

• How they interact with the CRA;
• The accessibility barriers they face;
• How accessibility barriers impact their experience;
• Solutions they suggest to eliminate or prevent accessibility barriers; and
• How they would like to provide feedback on accessibility to the CRA.

Through participants’ responses, the CRA sought to understand how it can improve the accessibility of external services for persons with disabilities in Canada.

Promotion

The CRA promoted this consultation process in a number of ways:

• Social media posts on the CRA’s French and English LinkedIn pages, Facebook, and Twitter accounts;
• Informational and outreach emails and calls to partner and community organizations that provide services to persons with disabilities; and
• Website with information in English and French, as well as American Sign Language (ASL) and langue des signes québécoise (LSQ).

Consultation

Persons with disabilities and their caregivers could share input about accessibility barriers they face when interacting with the CRA using various methods:

• A questionnaire that could be taken online or could be filled out with the support of a Delaney representative;
• Virtual group discussions;
• Phone and virtual interviews;
• Email submissions, and;
• Phone calls to a toll-free line.

In order to ensure the consultation process was fully accessible to persons with disabilities, Delaney (on behalf of CRA) put several accommodation measures in place:

• Offering multiple methods of providing input;
• Designing the project website to align with Web Content Accessibility Guidelines (WCAG) 2.1;
• Organizing group discussions at a variety of dates and times to work for different schedules, time zones, and availabilities;
• Scheduling interviews according to participant preference;
• Offered interviews over the phone or video conferencing, according to participant preference;
• Held group discussions in English and French;
• Provided Communication Access Realtime Translation (CART) captioning for all group discussion sessions;
• Provided American Sign Language (ASL) and langue des signes québécoise (LSQ) upon request; and
• Provided honoraria (payment) to people who took part in group discussions and interviews.

By the Numbers

• 627 people participated in the process
• 522 completed the online questionnaire
• 83 attended a group discussion
• 19 participated in an interview
• 34 emails sent to the project email address
• 13 phone calls received through the project toll-free line
• 62,990 social media impressions were made
• 1,873 visited the project website

Key Themes

Participants shared many insights about the accessibility barriers they face and how the barriers affect their experience. Suggestions from participants included how they would like to provide feedback, solutions to barriers, and their ideal experience. Three key themes were recurring throughout the consultation process:

Theme 1: Awareness and Respect

Respect was raised as a key theme in relation to interactions clients had with the CRA over the phone, typically through a contact centre. Participants expressed the desire to be respected, understood, and included when interacting with CRA agents. In describing their experiences, including challenges and accessibility barriers, some participants described interactions that had emotional, physical, (mental) health, inter-personal, and financial implications. While in many cases, their contact with CRA was successful and they resolved the issue that prompted the phone call, there were also instances where the issue was only partially or not resolved, adding to the negative experience.

When interacting with the CRA by telephone, participants noted a lack of respect and compassion, and noted that CRA staff had limited or no awareness of their disabilities, needs, and supports or accommodations that should be in place. There was an overall sense among participants that ableism is at play and impacts participants’ ability to access information or complete tasks with the CRA.

Barriers

Barriers to access services experienced when interacting with CRA staff included:

• Feeling rushed to complete a task;
• CRA agents speaking and describing processes too quickly, not speaking clearly or loudly, or using inaccessible language;
• Being ignored or asked to complete tasks they are unable to do;
• Not having requested accommodations provided;
• CRA agents not accepting a caregiver, interpreter, or intervener (“Interveners provide the visual and auditory information necessary to enable people with Deafblindness to interact successfully with other people and their environment”, “Deafblind Services”, Canadian Hearing Services, March 15, 2021, https://www.chs.ca/service/deafblind-services) as a representative who is supporting communication on behalf of a client;
• Being mocked by CRA staff;
• Feeling like a bother;
• Being passed around from agent to agent;
• CRA agents not listening or understanding; and
• CRA agents speaking to a caregiver rather than the client.

Solutions

When talking about an ideal experience, participants described a desire for a customer service approach that incorporates empathy, respect, compassion, and recognition of the barriers they experience daily, along with appropriate accommodations.

Quotes from Participants

“If they could educate me instead of me educating them, that would be great.”

“It’s demeaning to ask a Deaf person to vocalize.”

“It’s not the disability – it’s the ableism – that’s the problem.”

“It’s very evident that able-bodied people make these decisions.”

“I want someone to be compassionate to me, but at the same time, I want to be treated like there’s nothing wrong with me”

Theme 2: Accessing Information

Individuals who participated in this consultation and engagement raised concerns about barriers to accessing information from the CRA; this theme was consistently referenced across all CRA communication options (website, phone, mail).

Barriers

Accessing information independently is important and participants identified that if they could easily find information, they could then easily complete a task without additional support from the CRA. Participants described attempting to access information on the CRA website first, only to then seek further clarification through the phone. When looking for information online participants were met with a number of barriers, including:

• Information not being shared in American Sign Language (ASL) or langue des signes québécoise (LSQ) either on the website or when communicating with the contact centre;
• Text being too lengthy or shared in long lists which is inaccessible to persons experiencing cognitive disabilities or who use ASL or LSQ as their primary language;
• Not using icons or infographics to share information, which is inaccessible to those who experience cognitive disabilities; and
• Inaccessible language used (such as use of terms they did not understand) and too many steps to access information.

Many participants would call the CRA contact center when they were unable to find information online. Participants described long wait times when calling into the contact centre, which can present additional barriers to those who experience disabilities, including cognitive disabilities, mental health disabilities or chronic pain. They felt that the agents that they interacted with were not equipped with the resources or knowledge to properly support persons with disabilities. This often results in clients being transferred from agent to agent, without being provided an explanation. Several participants described multiple calls with various agents and managers, all including a lengthy wait and often with the need to re-explain the issue or question multiple times, before the accurate information is provided.

Solutions

Suggestions for improving access to information included: increasing the number of contact centre agents; providing training to staff on the supports and benefits available to persons with disabilities; ensuring resources are available to facilitate communication in ASL and LSQ; and improving accessibility and performing audits on the CRA website.

Quotes from Participants

“Understand the disabilities and barriers of people they are communicating with and meet them where they are instead of trying to have disabled people meeting abled people where they are.”

“Ableism is a huge issue, especially during the pandemic. If we had other disabled people, or people familiar with disabled people, that answered our calls, they would automatically have more compassion and more patience.”

“When you feel left out, it creates a bigger divide between able-bodied people and people with disabilities, and it doesn’t make us feel valued.”

Theme 3: Options for Interaction

Participants in this process were asked about how they would like to provide feedback to the CRA about accessibility barriers, as well as solutions for many of the accessibility barriers they and others have faced. Participants shared their preferences on how they would like to interact with the CRA. For many people with disabilities, their communication needs and preferred channels often change from day to day based on their health situation. Above all, participants expressed that their individual needs and situations require an individualized approach.

Barriers

Participants shared a number of barriers based on the channel through which they interacted with the CRA.

In-Person Barriers

• Chemicals and scents 
• Electro-sensitivities 
• Lack of mobility accessibility  

Telephone Barriers

• Access to a telephone or affordable phone coverage  
• Wait times  
• Complex phone menu options 
• Requires you to push buttons without option to verbalize choice 
• No direct line for persons with disabilities 
• Full voicemail inboxes 
• Phone disconnections  
• Poor sound quality 
• Passed from agent to agent 
• Lack of awareness or functionality of the call back option
  • Support person might not be available when the call back is placed to the client.
  • If unavailable, the client must start the process of contacting the CRA again 
• No video relay service (VRS) 
• No texting option  
• No language options beyond English or French (including ASL and LSQ) 
• Staff with strong accents 
• Proof of identity questions are not accessible  
• Support persons being challenged or silenced by CRA staff  
• Requiring clients to vocalize their support/intent 

Mail or Fax Barriers

• Security passcodes sent via mail 
• Assume you have an address  
• Assume you are sighted  

Barriers to Online Interactions 

• Access to technology 
  • Lack of access to internet, phones, printers, computers, Wi-Fi, fax 
  • Needing to travel to access technology 
• Lack of offline options  
• Online login to My Account  
• Website accessibility and design  
  • Not always compliant with WCAG 
  • Not easily or quickly scanned with screen readers 
  • Dense text with large amounts of information 
  • Using only written English or French  
  • Getting lost in redundant loops 
  • Text-to-background contrast  
  • Text and icon size 

Forms 

• PDF forms not always accessible to screen reader users 
• Option to request forms in alternative formats is not well communicated to clients  
• Not accessible on smartphones 

Disability Tax Credit (DTC) application 

• Amount and complexity of paperwork 
• Screen readers not able to read or complete paper forms 
• PDF version of forms is inaccessible  
• Lack of clarity concerning the eligibility criteria for the DTC 
• Similar information is needed to be submitted to other federal agencies 

Solutions

Suggestions included improving current options for interaction by phone, website, and online portal such as My Account; however, it also includes adding a multi-option platform for interaction such as online chat with a live agent, email, direct phone numbers to an individual agent or specialized team, video relay services, and texting.

Quotes from Participants

“[Calling the] CRA is never going to be an in and out call.”

“The ability to ask for help is roadblocked by our technology options.”

“What’s accessible to me may not be accessible to someone else.”

“[I] thought of sending an email but was not sure it would be read, that it would get through, that it would matter, that it would make a difference.”

What’s Next

The feedback provided by participants in this consultation exercise will be used to shape the CRA’s first Accessibility Plan, which will set out the concrete actions that the CRA will undertake to address accessibility barriers over the next three years. The CRA’s Accessibility Plan will be published in December 2022, and represents the first step in realizing the Government of Canada’s vision of becoming barrier-free by 2040.

The CRA will continue to consult persons with disabilities as part of the preparation for future Accessibility Plans and Progress Reports, as required by the Accessible Canada Act. This will ensure that the Agency’s efforts are consistently focused on the issues that have been identified by persons with lived experience.

The CRA would like to recognize the contribution and time participants shared throughout this process. Thank you for sharing your experiences and for working with us to improve accessibility and remove barriers at the CRA.