What will the administrative burden be on employers? Will the federal government incentivize employers to keep their private dental plans? How will it screen dependents for eligibility? Will there be public consultations?
These are among the questions for which Benefits Alliance is seeking answers on behalf of its member firms and their clients, with just over six months to go until the scheduled launch of the Canadian Dental Care Plan (CDCP) at the end of 2023.
“We learned very little from the federal budget. Far too much is still open to interpretation,” says Doug Calow, Principal of Calow Benefits Group in Barrie, Ontario, and a member of Benefits Alliance’s advocacy committee.
The 2023 federal budget, released on March 28, includes three major points specific to the CDCP:
- $4.4 billion has been set aside for Health Canada to implement the plan “with support from a third-party benefits administrator.”
- An additional $13 billion over five years has been earmarked to provide dental coverage for uninsured Canadians with annual family incomes of less than $90,000. That budget states that “details on eligible coverage will be released later this year.”
- The government has proposed new legislation that will compel employers and employer pension plans to report dental coverage on annual T4/T4A statements to “ensure that the new Dental Care Plan is limited to Canadians with an unmet need for dental care who don’t have access to private insurance.” The legislation would also authorize Health Canada to collect and use social insurance numbers “for purposes of plan administration and enforcement.”
On the one hand, it’s good to get confirmation that Health Canada will “leverage a system that’s already in place in the private sector rather than set up their own claims adjudication system,” says Calow.
On the other hand, the lack of greater detail on eligibility, with just half a year to go and no indication of public consultations, is potentially concerning. While the government has made it clear that the CDCP is for uninsured Canadians only, has it considered the implications if that number swells due to plan sponsors establishing new criteria, based on CDCP eligibility, before their own dental coverage kicks in? Has it considered measures to encourage private plan sponsors to maintain their dental plans?
“We really would like to see greater consultation with our advisor community so we can get it right in terms of how the public and private plans can coexist together,” says Graham Young, chair of BA and employee benefits director at CAPCORP in Ottawa. “Ideally we’d like to see governments incentivize employers to maintain private dental plans as they contribute to overall health and take a considerable burden off public programs across the country.”
Summarizes Calow: “We do a good job already in the private sector looking after dental coverage for Canadians, regardless of a family’s household income. The industry has plan designs to mitigate abuse and contain costs. We don’t want to disrupt what is working well.”
In an earlier article for Take 5, Dr. Lynn Tomkins, President, Canadian Dental Association (CDA), echoed both Young and Calow. “Private dental benefits have been a significant factor in improving the oral health of Canadians and we wouldn’t want to see something brought in that would disrupt that,” she said.
As for the requirement to add dental coverage to T4 statements and Health Canada’s use of social insurance numbers, Calow agrees that’s “100 percent prudent” and the revised T4s should not be onerous for plan sponsors. However, he says a big question there has to do with spouses and dependents. “How will the new system capture social insurance numbers for spouses and dependent children for confirmation of dental coverage already in place? This is a very important cog in the wheel in understanding how the new plan will work.”
As more details come to light, Benefits Alliance will work closely with its member firms to raise awareness among plan sponsors—and offer guidance to Health Canada. “We’ve heard nothing about public consultations, but we are ready and able to represent plan sponsors. Our biggest goal is to prevent unintended negative consequences for private dental plans and for plan members who really value those plans,” says Calow.