In recent discussions with the National Payroll Institute, Health Canada confirmed that employers and pension plan administrators remain legally responsible for dental benefits reporting, even where a payroll provider or other third party prepares slips on their behalf. For employers using a payroll service or software provider (PSSP), Health Canada also clarified that the provider may report a code “1” if the client fails to provide the required dental benefits reporting information, but only if:
- the employer or payer failed to populate Box 45 of the T4 or Box 015 of the T4A; and
- the PSSP has provided the employer/payer with sufficient warning that failure to respond would be interpreted as the employee or retiree having no access to dental benefits.
The PSSP should also advise that the employer or payer could incur penalties if the information later proves inaccurate.
This clarification reflects the government’s acceptance of NPI’s advocacy on how PSSPs may respond when clients do not provide the necessary coding, while also reinforcing that accountability for accurate reporting remains with the employer or pension plan administrator.
Key reminder for employers and pension plan administrators:
- Employers/payers must not report a “1” simply because an employee or retiree opted out of available dental coverage; if dental coverage was available, access is considered to have existed regardless of participation and regardless of the possibility that Health Canada later agrees to provide access into the Canadian Dental Care Plan.