Service improvement request - Information for Victims of Domestic Abuse

In 2016, the Minister of National Revenue asked the Taxpayers’ Ombudsperson for assistance. The Minister wanted to understand what, if any, service issues exist, and to what extent, women residing in temporary shelters face in receiving their CCB.

To determine the service issues, our Office contacted women’s shelters to discuss their awareness of the CCB. Based on their responses, the Taxpayers’ Ombudsperson decided to launch a systemic examination into the CRA’s communication and outreach efforts to shelters, with respect to benefits. From this examination we published our findings in the report Benefits Unsheltered, which had 3 recommendations to the Minister.

We continued to hear issues related to the CRA’s administration of the CCB; therefore, in August 2019, the Taxpayers’ Ombudsperson notified the Minister we were opening a systemic examination. The examination focused on what, if any, service issues exists in the CRA’s administration of the CCB, namely difficulties proving entitlement, validation, and information available.

When carrying out our CCB examination, we remained cognisant of the Minister’s previous request for assistance regarding women in shelters. In addition, when identifying opportunities for service improvement we try to focus our attention on helping Canadians who are the most vulnerable. This led us to identifying an issue that could affect vulnerable Canadians, including those residing in temporary shelters.

The CRA has provided targeted factsheets and presentations to women’s shelters, hosted a webinar in the winter of 2021, and uses How to get your benefit payments while staying in a shelter to provide information to Canadians on how to get benefits and credits when staying in shelters. However, it does not actively inform all Canadians, nor comprehensively explain what is required, or what to do, if they are facing abuse, or are at-risk of abuse, whether they are in a shelter or residing somewhere else.

For example, the CRA provides a list of alternative documents that can used as a substitute for other documents, but it does not provide them all on the webpage. Specifically, the webpage does not indicate that the CRA accepts a letter from a trusted third party, for example the Band Council, a resettlement agency, or a church.

In addition, the CRA does not explain that it has different requirements for Canadians facing abuse. For example, if a taxpayers spouse is abusive, the spouse’s signature is not required on the Form RC66, Canada Child Benefits Application includes federal, provincial, and territorial programs.

Further, Canadians may question the reliability of the information on the webpage, as it has a yellow banner (shown below) that indicates it has archived the page and will not be updating it.

 

 

We also find the following statement, and its placement on the webpage insufficient:

“Under no circumstance will the CRA ask you to contact an abusive spouse.”

Although, the CRA is not directing taxpayers to contact an abusive spouse, it’s not clearly indicating to taxpayers that contact is not required. Not being explicit could lead to some taxpayers contacting an abusive spouse, as they may feel that it’s their only option to get the documents the CRA is requesting.

First, the CRA should stress to Canadians do not contact a spouse who could put them at-risk of abuse. Then, the CRA should inform them on what to do instead. For example, the CRA could indicate:

• If you need documents or a signature from an abusive spouse, do not contact them, and do not put yourself in danger trying to retrieve documents.
• If you call us at 1-800-387-1193 and let us know your spouse is abusive, we will be flexible in what kind of documents we need from you.
• If an agent asks for a document or a signature that may put you in danger, ask to speak to their supervisor.

Based on the above, to improve the clarity and completeness of information available to Canadians who are at-risk of abuse, or victims of abuse, as well as the service the CRA provides to Canadians, the Taxpayers’ Ombudsperson requests that the CRA make the following service improvement:

• Create an active webpage on what a taxpayer should do when the CRA requires, or requests, information, or documents, that may put the taxpayer in danger.
  • For example, this webpage would inform taxpayers who are at-risk that:
    • A spouse’s signature is not required on the Form RC66, Canada Child Benefits Application includes federal, provincial, and territorial programs
    • A letter from a trusted third party, for example the Band Council, a resettlement agency, or a religious entity that can be provided instead of what the CRA requested

This webpage should be gender neutral and relevant to Canada’s population that is diverse in faiths and ethnicities. It should contain information not limited to Canadians in shelters. It should detail what is expected by the CRA, and what the taxpayer is required to do. Further, the CRA should ensure the webpage does not become archived, and that it also creates an update schedule, or process, to ensure that the most current information is available to Canadians.

In addition, the webpage should be designed in a way that it can be used as a resource for not only Canadians and organizations, but also to victim support people. This will help to ensure that all victims, or at-risk Canadians, have a resource that details what to do when the CRA requests information that could put them in danger.