Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the CRA.
Prenez note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle de l'ARC.
Principal Issues: Whether Medical Radiation Technologists in the province of NL can be added to the list of authorized medical practitioners on the CRA website.
Position: Yes.
Reasons: The Medical Radiation Technologists Regulation 78/24, which are enacted under the Health Professions Act of NL, came into force on May 1, 2025.
XXXXXXXXXX 2025-106552
Randa El-Kadi
July 24, 2025
Dear XXXXXXXXXX:
Re: Request to add Medical Radiation Technologists in Newfoundland and Labrador to the Canada Revenue Agency's list of authorized medical practitioners
We are writing in response to your correspondence dated May 16, 2025, in which you requested that Medical Radiation Technologist in the province of Newfoundland and Labrador be added to the Canada Revenue Agency’s (CRA) list titled “Authorized medical practitioners for the purposes of the medical expense tax credit” (the List).
Our comments
This technical interpretation provides general comments about the provisions of the Income Tax Act and related legislation (where referenced). It does not confirm the income tax treatment of a particular situation involving a specific taxpayer but is intended to assist you in making that determination. The income tax treatment of particular transactions proposed by a specific taxpayer will only be confirmed by this Directorate in the context of an advance income tax ruling request submitted in the manner set out in Information Circular IC 70-6R12, Advance Income Tax Rulings and Technical Interpretations.
For the purpose of claiming an amount for the medical expense tax credit (METC), paragraph 118.4(2)(a) of the Act provides that where the reference to a medical practitioner is used in respect of a service rendered to an individual, that reference is to a person authorized to practice as such pursuant to the laws of the jurisdiction in which the service is rendered. Therefore, in order to determine whether a particular medical practitioner qualifies as such under the Act, one must look to the relevant provincial or territorial legislation to determine whether the particular practitioner is authorized under the laws of that jurisdiction.
In our view, a person is authorized by the laws of the jurisdiction to act as a medical practitioner if there is specific legislation that enables, permits or empowers the person to perform medical services. Generally, such specific legislation would provide for the licensing or certification of the practitioner as well as for the establishment of a governing body (e.g., a college or board) with the authority to determine competency, enforce discipline and set basic standards of conduct.
In the province of Newfoundland and Labrador, Medical Radiation Technologists are currently authorized to practise under the Health Professions Act, SNL2010 CHAPTER H-1.02 (the HPA) and the Newfoundland and Labrador Regulation 78/24- Medical Radiation Technologists Regulations under the HPA. These regulations were proclaimed by Order in Council O.C. 2024-175 and were published in Part II of the Newfoundland and Labrador Gazette dated November 12, 2024. The regulations came into effect on May 1, 2025.
Under the HPA, the Newfoundland and Labrador Council of Health Professionals (the Council) is the regulatory body responsible for overseeing Medical Radiation Technologists, including certain other professions that are listed in the Schedule to the HPA.
Based on our review, there is specific legislation in place that governs and regulates Medical Radiation Technologists in Newfoundland and Labrador. Therefore, as of May 1, 2025, under the laws of Newfoundland and Labrador, a Medical Radiation Technologist meets the requirements of being an authorized medical practitioner for the purposes of the METC and will be added to the List.
We trust that these comments will be of assistance to you.
Yours truly,
Eric Wirag, CPA, CMA
Manager, Tax Credits and Ministerial Issues
Business and Employment Division
Income Tax Rulings Directorate
Legislative Policy and Regulatory Affairs Branch
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