6 November 2025 External T.I. 2025-1078851E5 - Social Service Workers in Ontario

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 Registered Social Service Workers in Ontario are authorized medical practitioners for purposes of the medical expense tax credit.

Position: Yes.

Reasons: As of August 15, 2000, the Social Work and Social Service Work Act, 1998, enables, permits, and empowers Social Service Workers in Ontario who are members of the Ontario College of Social Workers and Social Service Workers to perform medical services. As of December 30, 2017, Social Services Workers who are competent and authorized may perform the controlled act of psychotherapy under the Regulated Health Professions Act.

XXXXXXXXXX							2025-107885
								Tahirah Massop

November 6, 2025

Dear XXXXXXXXXX:

Re: Request to add Registered Social Service Workers (RSSWs) in Ontario to the Canada Revenue Agency's authorized medical practitioners list

We are writing in response to your correspondence dated September 17, 2025, in which you requested that the profession of Registered Social Service Workers (RSSWs) 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). Subsection 27(1) of the RHP Act, sets out that controlled acts can only be performed or delegated by an individual who is a member authorized by a health professional Act to perform the controlled act. Paragraph 14 of subsection 27(2) of the RHP Act lists psychotherapy as one of the controlled acts that may be performed by an individual.

As of December 30, 2017, subsection 27(4) of the RHP Act authorizes a member of the Ontario College of Social Workers and Social Service Workers (OCSWSSW) to perform the controlled act of psychotherapy in compliance with the Social Work and Social Service Work Act, 1998 (SWSSW Act), its regulations and by-laws. Therefore, subsection 27(4) of the RHP Act expressly authorizes RSSWs to perform the controlled act of psychotherapy, provided they are competent and acting within the scope of their practice.

RSSWs are regulated under the SWSSW Act which was proclaimed in full on August 15, 2000, establishing the OCSWSSW as the governing body for RSSWs. Pursuant to subsection 3(2) of the SWSSW Act, the OCSWSSW is responsible for regulating its members by setting entry-to-practice standards, maintaining a public register, establishing codes of ethics, and enforcing discipline to protect the public interest.

For the above reasons, RSSWs should be recognized as authorized medical practitioners for the purposes of the METC and will be added to the List.

It is our understanding that RSSWs provide a broad range of services beyond the controlled act of psychotherapy. Pursuant to paragraph 118.2(2)(a) of Act, an amount paid to a medical practitioner, dentist or nurse, or a public or licensed private hospital is considered to qualify as a medical expense of an individual only if it is paid in respect of a medical or dental service. A medical service is a service relating to the diagnosis, treatment or prevention of disease performed by a medical practitioner acting within the scope of his or her professional training. Since the RHP Act permits RSSWs to perform the controlled act of psychotherapy, psychotherapy services would be considered a medical service where an RSSW is acting within the scope of their professional training. As such, fees paid by a taxpayer to an RSSW for psychotherapy services may be considered eligible for the METC.

We trust that these comments will be of assistance to you.

Yours truly,

Christopher Brennan for
for Amanda Couvrette, CPA, CA
A/Director, Business and Employment Division
Income Tax Rulings Directorate
Legislative Policy and Regulatory Affairs Branch

cc. XXXXXXXXXX