Inside CFPC’s advocacy to reduce DTC form and other admin time

The College of Family Physicians of Canada (CFPC) is pushing to get doctors out of having to do Disability Tax Credit (DTC) forms—or at least minimize the doctor input to only that needed be done by physicians.It is part of a wider campaign by the CFPC to reduce admin burden on FPs and was an issue the group brought up with MPs, the Canada Revenue Agency (CRA) and other government officials during the group’s visit to Parliament Hill early last week. The overall visit was over a range of FP issues. On the DTC form, the CFPC is calling for a “citizen-focused process for completing the paperwork,” as it was described in a press release. So, in Ottawa, members of the group suggested that the CRA explore alternative methods to get doctors less involved in the form, such as enabling patients to self-report their functional limitations through online tools or phone services. Dr. Mike Allan, CEO and executive director of the CFPC, argues that some of the DTC form is “functional assessments. We really think a lot of it can be filled out by the patient.”Dr. Allan said technology offers options: artificial intelligence could guide patients through the form completion. He said he believes if something comes up that needs medical verification, there could be a process for involving a family physician but that shouldn’t be the default.The options for change are wide. Dr. Adam Chen, in an online comment to an earlier article, suggested we advocate for “Disability Assessment Units” across the country. “This way you can throw as many forms at the family doctor as you like, but we will only write, ’refer to assessment by Disability Assessment Unit,’” he wrote. Read: Canada’s worst forms, anecdotally (2018)However, while the CFPC’s primary goal is to remove or minimize the time doctors spend on the DTC form, Dr. Allan argued that until that happens physicians should be compensated. Historically, many physicians have provided this service without charging patients, particularly as many of those needing the form are financially vulnerable. However, this unpaid work contributes to the overall strain on doctors’ time and resources.He noted that the Canadian Medical Association has been advocating for physicians to be compensated for this work. Dr. Allan said he thinks it makes sense that the organization requiring the form—whether it’s CRA, Veterans Affairs or insurance companies—should be responsible for the cost.Overall, Dr. Allan said the CRA and other government officials were receptive to the idea of rethinking how the DTC form is handled and he’d like to see this be the beginning of a move to wider efficiency. Dr. Allan mused: “Wouldn’t it be wonderful if these disability forms were maybe a little more comprehensive in some ways, but they allowed us to cover the provincial disability forms? There’s many out there and what if we could kind of get it down to one form?” It would be great if “we could improve the the way that the different departments in the federal and provincial governments work together—and I know this is a huge ask, but I did see more interest in that than I thought—and (we had a situation where) once the provincial form is done for disability, then it's also valid for the federal one.” He added: “You're seeing us focus on the Disability Tax Credit. But it's actually opening other doors to look at the bigger picture of forms in general.”The CFPC’s efforts are still in the early stages, but Dr. Allan is optimistic. He said the group was encouraged by the willingness of MPs and the CRA to engage in this conversation. It’s clear, he said, that they understand the urgency of reducing the administrative burden on family doctors, especially when it comes to forms like the DTC.Q&ADr. Allan spoke, from his hotel room in Ottawa, with Medical Post editor-in-chief Colin Leslie by Zoom in detail about the CFPC proposal and the organization’s lobbying efforts generally. Q: How did the time in Ottawa go?I would say it went really well. There was a whole team of us here. Staff. Members of the board. We had a good time at the reception the evening before. To kind of set a tone. We certainly weren’t lobbying or anything at that time. We were more just getting to know each other.Q: So that’s a reception or what would that be like?So the reception is like, it’s an event where you’re sponsored by a Member of Parliament generally. And then, you know, very brief little speeches from us, saying how happy we are to be there and then some some speaking from the minister and the shadow minister—that kind of thing, and then really just kind of chatting and getting to know each other. And in that case we have a really broad range of people in the room. Sometimes our partners, like the Society of Rural Physicians of Canada, Disabilities Without Poverty, a group that we’re working with about the disability tax credit, family doc, family doc leaders in the Ottawa area: and sometimes from a little further afield—just getting a chance to meet politicians, for them, getting to meet doctors.Q: That was Sunday?That was Monday, and then the Tuesday was the day that was really the members of the staff with myself: as the CEO, and then three of our board members going in and meeting—kind of breaking up into teams and meeting with, I think, we had . . . 18 meetings spread over the day with three to four teams working. The feedback was really really positive.Q: So these were meetings with MPs or staff or . . . ?(And that meeting) with CRA, related to the disability tax credit. (We had a wide range of people from CRA) including the people running the show, the operational element. (So that) and all the way up to the MPs and ministers they were all, and their staff were all—no one reported anything negative—it was all very positive. And I think the crisis in family medicine, and the situation in healthcare, has really kind of energized and aligned people into enthusiasm to find solutions. And so I think I do feel we were heard.And when I say that, I don’t mean that tomorrow we’re going to see a massive change in a lot of different things. But these are steps forward. These take time and discussion, and processes have to be in place, and I think yesterday was a big step in that direction.Q: OK, let’s just sort of jump into what the proposals are about the DTC.Lets. But first, I want (to note), we didn’t come just (come) about the Disability Tax Credit. We were talking about compensation for family doctors, talking about the way—not just the amount—but at least as importantly, the manner in which they’re compensated, their fee structures, how they’re paid. We talked about things like team-based care. How do we get better teams to support family medicine and collaborate with other allied providers? And then also, how do we address the physician workforce shortages? So all of these things were part of the conversation. But I do want to acknowledge that though I get the point you’re asking about today, which I totally get, is the Disability Tax Credit.And so I’ll start with our position as the college: Family doctors have indicated to us that administrative burden is very high. Some some estimates of the administrative burden on family physicians is 19 hours per week. Doctors often work more than the average 40 or 35 hours per week. But obviously 19 hours is a big chunk of any work week and (doctors) have indicated that that administrative burden is high. It’s one of the things that people talk about that’s a deterrent to family medicine. It makes it less sustainable. So we wanted, and our members have said, this is important, and we surveyed 5,000 of them, and the disability tax credit was the number one thing as far as federal forms.Q: I think we even did an article a few years ago and anecdotally that was Canada’s worst form. It’s a big problem. (Right) so what they would like us to do is is remove the requirement for doctors to complete it. So what the problem with doctors completing it? Well, it’s the time and it’s the form that requires a difficult conversation where we’re kind of seen as a gatekeeper to a patient getting the Disability Tax Credit It’s a difficult relationship to manage. Now we’re used to dealing with difficult conversations in medicine, but we don’t need to add to that on top of the administrative burden of the form. So if we could get rid of that piece it would be good. So, and then the last piece, is the it’s not paid for. . . . Q: OK, well, but in terms of FPs not being involved in the form, there are other situations where physicians are gatekeepers, such as driver’s licenses, and in our online comments one reader even said “if not us, then who” so what is the proposal that would have patients evaluate themselves? Because, you know, the other thing I saw in our online comments is, some doctors feel like they’re being pushed by a patient to say something on the form that they don’t feel is true. And they feel like they’re being pushed to commit fraud.Totally understand. So it’s important to remember with the DTC form that there is an element to it that is about medical conditions. But mostly it’s around a functional assessment. It’s about disability. And who better to report that than the patients themselves? (So) when patients come in to (with) the form, often we’ll be saying to them, OK, this section is about the amount that you can physically (walk) so tell me your ability to walk, and how far you can go, and how fast you can go. Those kind of things. And that functional element really can be drawn out a bunch of different ways. It could be—AI could even assist with this. . . . We think it could be handled by an online service that could do a lot of the work to help guide patients through it. (It could also) be also done with a phone service. There’s a potential there. In our discussions. we’re not saying, this is how we think CRA should manage it. We’re saying we’d like to work with CRA to find a better solution. As you know there are lots of things that we, as individuals, fill out that we’re doing on faith. When you fill in your income tax, there is a system in place to check through your income taxes, identify likely areas that are potentially errors in filling out the form. I’m not going to use the word fraudulent, because I don’t know that that’s the reason for an error to occur, but if there is something of concern they can contact the person and ask for an audit. And we feel that that could be the same thing. Here we could find paths that would support patients in doing it. . . . Maybe there’s someone at CRA, or a nurse, or someone else to guide you through the form appropriately, and if something comes up you could always have that backstop of, ‘well, you know for this one, we would just like to have you run it by your family physician.’ rather than having all come. For example, you know there’s a lot in there that really is a functional assessment; things like hearing and vision, those could be done by an optometrist. But there’s stuff in there that doesn’t require a family doctor once. Q: Right, but just playing devil’s advocate, in the income tax situation, well, somewhere there’s a pay stub or some kind of paper record but, you know, some of these things are being asked about level of disability and there is a financial element and people in tight circumstances might have a natural tendency to, if asked to self-evaluate, to exaggerate their disability. I think what we need to do is examine: what is the risk of people being fraudulent. I’m not saying that the risk is zero. We also have to balance that against a lot of family physician hours. What is the amount of time we spend on these forms? We had some of that data recently. The estimate in 2022 is that there were 400,000 DTC forms filled out. If we think about that in physician time, even if we can imagine that the form only takes half an hour, that’s 200,000 hours of physician time. It’s not that we’re dismissing the idea that there needs to be checks and balances in place—there absolutely does—but we need to balance that against the cost of of family physician time, when people six million Canadians don’t have a family doctor, and we’re asking them to do this kind of work.You know we’ve spoken to disability groups, and they’re in favour of this. They feel that there’s a lot of barriers already, and then charging patients for the form, etc. it’s not ideal for them either.

Inside CFPC’s advocacy to reduce DTC form and other admin time

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