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CCPA advocates for improved access to counselling/psychotherapy services with the Federal Government through three specific recommendations. Read more about each recommendation below, and browse through our submissions to the Federal Government found on our Professional Practice Documents webpage.

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.

At the time that Alberta received royal assent and would have been the fifth province to regulate the profession, CCPA applied for the counselling and 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.

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-393:

Audio Player

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:

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, and Department of Finance.

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 Across Canada 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.

2 – Permanent inclusion of counsellors and psychotherapists in the Public Service Health Care Plan (PSHCP)

The Public Services Health Care Plan (PSHCP) is the largest health insurance plan in Canada that covers over 750,000 federal public servants, members of Parliament, federal judges, employees of certain designated agencies, veterans, members of the Canadian Forces and RCMP, pensioners and eligible dependents. The plan is currently administered through Sunlife Insurance.

The Government of Canada has awarded the contract to administer the PSHCP to the Canada Life Assurance Company (Canada Life). The new contract will come into effect July 1, 2023, following a transition period. Plan members (your clients) will continue to send all claims and requests to Sun Life until June 30, 2023. Please note that this change will have no impact on PSHCP negotiated benefits.

Following years of advocacy on the issue, in the spring of 2020, temporary changes to the Public Service Health Care Plan (PSHCP) were implemented which accepted counsellors and psychotherapists as eligible mental health practitioners. These changes continue to remain in effect until indicated otherwise.

Negotiations to renew the plan began last spring, and remain ongoing. CCPA has actively advocated for the temporary inclusion of counsellors/psychotherapists to become permanent in the plan. Unions taking part in the negotiations have confirmed their support for this permanent inclusion and are representing our interests at the bargaining table. CCPA is also advocating to ensure the new plan allows counsellors/counselling therapists/psychotherapists to register for the direct billing platform alongside other allied medical professions:

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

More information to come – stay tuned!