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Federal Advocacy

We call on the Federal Government to uphold their commitment to the Common Statement of Principles on Shared Health Priorities
by revising policies that limit Canadians’ access to counsellors/psychotherapists in federal health programs.

Federal Advocacy

CCPA calls on all parties to ensure the Federal Government encourages equitable access to ALL mental health service providers – including counsellors, counselling therapists and psychotherapists – for ALL Canadians!

Canadians face barriers accessing timely, effective, and qualified mental health care support provided by counsellors/counselling therapists/psychotherapists through federal health benefit programs and legislation. Without consistently recognizing qualified counsellors/counselling therapists/psychotherapists in all federal plans and provinces, this leads to preventable delays in obtaining mental health support, inequality in access to care based on province of residence, and lack of continuity of care as clients transition from one federal plan’s coverage to another or from one province to another. The Canadian Counselling and Psychotherapy Association (CCPA) recommends three legislative and easily actionable ways that the Federal Government can ensure consistency in federal recognition of counsellors/counselling therapists/psychotherapists and prevent avoidable gaps in the accessibility of federal mental health supports.

Learn more about each of our three recommendations below, and visit our Professional Practice Documents webpage to browse our submissions to the Federal Government.

1 – GST/HST exclusion for all mental health services, including those provided by counsellors and psychotherapists

Counsellors and psychotherapists are currently NOT exempt from charging GST/HST. CCPA encourages members to learn more about their tax obligations through the Canada Revenue Agency’s website.

Taxation is a federal matter, and as the largest national association for counsellors and psychotherapists, CCPA has been advocating for the removal of tax on counselling and psychotherapy services since 2004. The Excise Tax Act (ETA) lists professions and services that are exempt from charging GST/HST; in order for counsellors and psychotherapists to be listed as exempt medical professionals in the ETA, the profession must be regulated as a health profession in at least five provinces or territories.

As such, CCPA has taken a leadership position in supporting regulation of the profession of counselling and psychotherapy across Canada through our involvement in provincial federations and coalitions, as well as providing opportunities for said federations and provincial regulatory colleges to come together to collaborate on shared priorities.

In the last decade, CCPA has supported a number of provinces in regulating the profession of counselling and psychotherapy: Nova Scotia (2011, Registered Counselling Therapist), Quebec (2012, Psychotherapy Permit), Ontario (2015, Registered Psychotherapist), New Brunswick (2017, Licensed Counselling Therapist) and Prince Edward Island (2021, Counselling Therapist). Despite receiving royal assent in 2018 to regulate the profession, Alberta is still awaiting proclamation as the final step in the regulatory process.

Furthermore, in 2017, CCPA supported a private member’s bill by MP Pierre-Luc Dusseault to amend the ETA and exempt counselling and psychotherapy services from GST/HST. Listen to the press conference with MP Dusseault and CCPA and read Bill C-383:

Unfortunately, an election was called before MPs could vote on the bill. Dusseault’s interest in this issue did, however, lead to an invitation to appear before the House of Commons Finance Committee to speak to CCPA’s annual pre-budget submission which included a recommendation on GST/HST exemption:

At the time that Alberta received royal assent and would have been the fifth province to regulate the profession, CCPA applied for the counselling therapy/psychotherapy profession’s exemption in the ETA through the Department of Finance. The application was declined because the regulated provinces did not regulate the same professional title. Despite documentation and discussions that demonstrated how the professions share a common scope of practice even though different professional titles are used, the profession is not eligible for the exemption because the provincial legislation that regulates the professions does not use the same title and scope of practice language in describing the professions.

For a summary of the advocacy work on this issue, please consult our GSTHST Infographic. CCPA continues to advocate for tax exemption in our annual pre-budget submissions to the House of Commons Standing Committee on Finance and Department of Finance, as well as meetings with Federal Members of Parliament on this issue.

In Spring 2021, CCPA’s member advocacy survey provided valuable information about the GST/HST practices and barriers of members, and helped inform key advocacy messages on the GST/HST matter. Staff met once again with the Department of Finance in 2021 to explore alternatives to obtaining an exemption for the profession in the ETA. The meeting unfortunately did not result in a GST/HST exemption for the profession, but once again helped inform next steps in CCPA’s advocacy plan on this issue.

During the 2021 federal election, CCPA launched a successful letter-writing campaign to all candidates across Canada. The campaign included one letter devoted to the GST/HST exemption for the profession of counselling and psychotherapy.

Federal advocacy will continue to include meetings with Members of Parliament to raise awareness on the issue of unequal access to mental health care services provided by counsellors and psychotherapists, as well as submissions to relevant House of Commons Committees and meetings with policy makers at the Department of Finance and Canada Revenue Agency. Please see the our website for the most recent submissions to the House of Commons Standing Committee on Health, House of Commons Finance Committee, Department of Finance and more!

CCPA also continues to support regulation of the profession across Canada; we will re-apply for exemption once the fifth province regulates the counselling therapist or psychotherapist title with the aim of ensuring that practitioners of both titles obtain an exemption under the ETA. Stay up to date on the process of regulation through the summary and links on our Regulation page.

In the meantime, we continue to work on achieving recognition from the Department of Finance that the counselling therapy and psychotherapy professions in regulated provinces are the same profession in all but name.

For a one-pager on the issue, click here.

2 – Inclusion of CCCs in the Interim Federal health Program (IFHP) for Immigrants and Refugees

The refugee population is growing rapidly in Canada. The Canadian government’s Immigration Levels Plan specifies that immigrants to Canada will increase from 7.5 million to more than 12 million by 2036 (Statistics Canada, 2017). Research indicates that refugees face unique challenges that impact their mental health and are mainly vulnerable to pre-and post-migration challenges, including higher rates of post-traumatic stress, mood disorders, psychotic illnesses, and depression (Porter & Haslam, 2005).

In response to these mental health trends, the need for timely, accessible, barrier-free and refugee-informed mental health policies is critical. Unfortunately, proactive and quickly actionable measures to increase appropriate mental health services or lack thereof have been ignored.

The Interim Federal Health Program (IFHP) is administered by Immigration, Refugee and Citizenship Canada (IRCC). Through this program, eligible refugees in Canada receive limited and temporary health coverage.

Because IFHP recognizes only regulated mental health professionals as service providers, refugees residing in the provinces and the territories who have yet to regulate the counselling/psychotherapy profession cannot access this critical resource. There are over 1,500 eligible providers in unregulated provinces who could be providing this critical support if allowed.

For better and more equitable mental health services provided to the refugee population, the Canadian Counselling and Psychotherapy Association (CCPA) recommends the IFHP recognizes CCCs as service providers in unregulated provinces and territories to address access to care issues and increase the availability of qualified and competent practitioners.

3 – Inclusion of all counsellors and psychotherapists nation-wide in the Non-Insured Health Benefits (NIHB) Plan for First Nations and Inuit

There is a significant need for improved access to qualified professional mental health support for the Indigenous Peoples of Canada. Attempts at assimilation have contributed to mental health challenges for First Nations, Inuit, and Métis peoples, which, in turn, have led to harm in Indigenous communities. The loss of their culture, identity and self-determination has had profound and lasting impacts on their mental well-being.

The Non-Insured Health Benefits Program (NIHB) and the Indian Residential Schools Resolution Health Support (IRS RHS) Program provide registered First Nations and recognized Inuit with coverage for a range of health benefits, including mental health counselling.

CCPA’s Canadian Certified Counsellors (CCCs) were eligible service providers under NIHB and IRS RHS programming until May 2015 when the designation was delisted in all provinces and territories where the profession of counselling/psychotherapy is not regulated. CCCs are only accepted in exceptional circumstances in rural and remote areas and on a limited basis.

This decision has significantly reduced appropriate, universal access to mental health counselling services for Indigenous Peoples and communities across the country, and disadvantages those requiring care in unregulated provinces and territories.

By restricting access to CCCs, who are eligible providers in various other Federal health benefit programs as well as though the First Nations Health Authority which is NIHB’s counterpart in BC, the Federal Government is not providing equitable access to mental health care for all Indigenous Peoples.

The current NIHB policy prevents Indigenous practitioners from working in their communities and traditional territories, and within the cultural areas in which they are experts. The mental health benefit is the fastest-growing benefits area in the plan. Indigenous People must have access to practitioners who are from their own community with lived experience and understanding of the socio-political influences that impact Indigenous lives and mental health every day.

In September 2015, in response to the delisting of CCCs in unregulated provinces, the Assembly of First Nations (AFN) – First Nations Inuit Health Branch (FNIHB) NIHB Joint Review Steering Committee recommended immediately reinstating CCCs as eligible providers in provinces and territories that have not regulated the profession.

As highlighted in rights instruments and national commissions on Indigenous people, like the Truth and Reconciliation Calls to Action, the United Nations Declaration on the Rights of Indigenous Peoples and the National Inquiry on Murdered and Missing Indigenous Women and Girls, each item demonstrates increasing access to mental health supports. However unilateral decisions are still being made by federal and provincial leadership on Indigenous communities and access to essential services.

In the interest of equitable accessibility to mental health services for Indigenous Peoples of Canada, it is recommended that Indigenous Services Canada implement the call to action from the AFN-FNIHB Joint Review Steering Committee and immediately reinstate CCCs in unregulated provinces as eligible providers under the NIHB program, adding over 1,500 eligible providers in the unregulated provinces.

In May 2022, Angela Grier, CCPA’s Lead, Indigenous Initiatives, appeared as a witness in front of INAN to talk about this issue. Listen to her testimony here: https://youtu.be/HKv-xSiW1Cs.

For a one-pager on the issue, click here.

Parliament Hill Campaign

During Counselling and Psychotherapy Month 2022, CCPA held a virtual Parliament Hill campaign. Trained spokespersons from CCPA’s Board of Directors, Chapter Presidents and staff will meet with key Members of Parliament to raise awareness around CCPA’s key federal advocacy messages. You can find our one-pager documents for these meetings below.

Members can support this campaign or CCPA’s broader federal advocacy work by sharing our updates as we post them on social media, or by using CCPA’s Advocacy Toolkit to reach out to their MP and request a virtual meeting. Elected officials want to hear from their constituents, so your efforts securing a meeting to discuss the profession of counselling/psychotherapy will help raise awareness about the profession and our recommendations! CCPA’s Director of Public Affairs is also available to attend the meeting with you.

GST/HST Exemption for Counselling Therapists/Psychotherapists

Read our one-pager summary for MPs, Senators and Staffers

Open

Reinstatement of CCCs in the NIHB Program

Read our one-pager summary for MPs, Senators and Staffers

Open