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 Behaviour Analysts in Ontario are authorized medical practitioners for purposes of the medical expense tax credit.
Position: Yes.
Reasons: There is specific legislation that governs the practice of Behavioural Analysts in Ontario.
XXXXXXXXXX 2025-106587
Tahirah Massop
June 18, 2025
Dear XXXXXXXXXX:
Re: Request to add Behaviour Analysts in Ontario to the Canada Revenue Agency's authorized medical practitioners list
We are writing in response to your correspondence dated May 22, 2025, in which you requested that the profession of Behaviour Analysts in the province of Ontario 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 Ontario, a medical practitioner is a practitioner of a health profession that is regulated under the Regulated Health Professions Act, 1991, S.O. 1991, c. 18 (RHP Act). Schedule 1, Self-Governing Health Professions of the RHP Act identifies psychology and applied behaviour analysis as health professions governed by the Psychology and Applied Behaviour Analysis Act, 2021, S.O. 2021, c. 27 (PABA Act). The PABA Act was proclaimed on July 1, 2024.
Under the authority of the PABA Act, the College of Psychologists and Behaviour Analysts of Ontario was established as the regulatory body responsible for overseeing the profession of applied behaviour analysis. Based on our review, there is specific legislation in place that governs and regulates the practice of applied behaviour analysis in Ontario. Therefore, as of July 1, 2024, under the laws of Ontario, a Behaviour Analyst 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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