Canada Dental Care Plan and T4 Reporting for Employers

Overview of the Canada Dental Care Plan 

Many employers offer health and dental insurance as part of employee compensation packages; the plans vary in coverage depending on the employer's chosen provider and negotiated terms. Covered services often include routine check-ups, cleanings, fillings, and more extensive procedures like root canals or orthodontic treatments.

The Federal Budget for 2023 included plans to create a permanent dental program for Canadians: the Canada Dental Care Plan  (CDCP). Many Canadians are already eligible to apply and the plan is expected to complete its rollout by 2025. Sunlife has been awarded the contract to create the foundation of the CDCP.

Dental Care Providers

Dental care providers can get information on how to participate in this program through Sunlife.

It is important to note that nothing prevents a participating dental care provider from charging more than they will be reimbursed. Dental care providers just need to disclose in advance what those additional costs are. This will assist their clients in determining if they will be able to proceed with treatment or not. 

Who can access the CDCP? 

The CDCP will be available to Canadians with an annual family income of less than $90,000 who do not have access to dental coverage. For those that make under $70,000, co-pays will not apply. Additional details on eligibility can be found here . If an individual has access to dental coverage through employment benefits, they are not eligible for the CDCP, even if they choose not to take the coverage, don’t pay a premium for it, or don’t use it. 

New requirements for employers completing a T4 or T4A

For calendar year 2023, and moving forward, employers must indicate on the T4 slip and/or the T4A whether, on December 31st of the taxation year applicable, an employee (or former employee) was eligible to access dental insurance or coverage of any kind. This includes health spending accounts.

The T4 and T4A forms have now been amended to include box 45(T4) or box 015(T4A).
 
Please note that filling out box 45 on the T4 is mandatory. 

When filling out a T4A, if an amount is reported in box 016, then box 015 is mandatory. Otherwise, box 015 is optional. 
 
Employers must select one of the 5 code options to report in box 45 or Box 015:

* Payee in this case refers to the employee/former employee.
 
 Please see the following update as per the Canadian Revenue Agency: 
 
Use of code 1 – T4 slips filed for calendar year 2023 only   
To reduce the burden on employers, for calendar year 2023 only, it is not mandatory to fill out box 45 when and only when code 1 is applicable.

This administrative policy applies only if all reasonable efforts have been made to comply with the reporting requirements.
 
T4 slips filed before January 2024
To reduce the burden on employers, if you filed your T4 slips for calendar year 2023 before January 2024, you do not have to file amended T4 slips to report this code.
 
If you use a CPA or payroll provider, we highly recommend reaching out to them for further information and assistance.

Resources:

• Canada Dental Benefit
• Getting Canadians the dental care they need (Government news release)
• T4 Slip – Information for employers
• Canadian Dental Care Plan Update (SunLife)
• Canadian Dental Care Plan Support (SunLife)
• Oral Health Provider FAQ (SunLife)

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FAQ for Employers: Completing the T4 for the Canada Dental Benefit Program and employer-provided dental benefits

Q1: What is Box 45 on the T4 slip, and why is it important for the Canada Dental Benefit Program?

Box 45 on the T4 slip is designated for reporting whether an employee was eligible to access dental benefits or coverage of any kind, including health spending accounts. 

Q2: Are employer-provided dental benefits taxable for employees?

In Quebec, employer-provided dental benefits are taxable, but they are not taxable in the rest of Canada. 

Q3: When should I issue T4 slips to employees with the reported dental benefits?

T4 slips must be provided to employees by the end of February following the tax year. Use the table above to determine which code to enter in box 45.

Q4: How do I submit T4 information, including dental benefits, to the CRA?

T4 information, including dental benefits reported in Box 45, must be submitted to the CRA by the required deadline using the appropriate filing method. Employers can choose to file electronically or by mail, depending on their preference and the size of their business.

Q5: Where can I find more information about reporting dental benefits on T4 slips?

For detailed guidance on reporting dental benefits on T4 slips, refer to the CRA's official website or consult with a tax professional for expert advice tailored to your specific situation.

Q6: I offer a Health Spending Account to my employees. Does this mean that they have access to dental benefits and which code should be used on the T4? 

Yes, this could mean that your employees have access to dental benefits. When you fill out box 45 it indicates if you, the employer, provide access to any dental benefit for your employees. This includes access to a Health Spending Account (HSA) or Wellness Spending Account (WSA). 

Q7: I offer different access to benefits for different categories of employees. How do I proceed with the reporting? 

In instances where you have different categories of employees who have different access to benefits (whether they be part-time or full time, etc.) you will have to pay close attention to the T4 that you are filling out and indicate the appropriate code in box 45 for that specific employee.