There's been lots of discussion in the retirement community about the new CDCP and the eligibility requirements. In January of this year I was emailed by the Manager of Benefits with WSBC and asked whether the WCBREA had heard from any of our members about the federal plan. At that point we hadn't.
We now have.
I couldn't find any law passed by the federal parliament about the CDCP at the time, and all that was posted was policy / practice / interpretative guidance for the new plan, which seemed to rely on the previous child's dental benefit legislation.
Briefly, that federal policy provided that you were ineligible for the CDCP if you "have access" to 1) dental insurance through your employer; 2) dental insurance through your pension (previous employer); 3) dental insurance purchased by yourself or by a family member or through a group plan from an insurance or benefits company.
Backgrounder: There are 2500 retirees in receipt of a WSBC pension, all of whom were offered a right to purchase a WSBC Retiree Group Dental Plan at the time of their retirement (or with older retirees, presumably at the time the fully employer funded retiree dental plan was eliminated in the late '80s). That group plan on offer is fully paid for by the retirees who chose to enrol. Of the 2500 retirees in receipt of a pension, 1/3 have purchased the plan, and 2/3s have not.
The retiree dental plan offered by WSBC is not "dental insurance through the employer", as we are no longer employees. It is also not "dental insurance through our pension" as it is not a pension benefit funded through the superannuation fund, to which both the employer and worker have contributed. What the WSBC retirees dental plan is, is "dental insurance purchased by yourself, through a group plan" -- with the group defined as being WSBC retirees -- "from an insurance company" (PBS).
WSBC initially advised that its view (informed by its conversions with PBC and the Pensions Corp) was that whether a retiree had purchased coverage, or whether they declined it, they "had access" and would be ineligible for the CDCP. I disagreed, saying that the language was "has access", and the coverage was offered on a one time only basis (at the time of retirement) and couldn't be purchased today by retirees. I also disagreed with the WSBC dental benefit being characterized as a "pension benefit" as it was not paid for out of the superannuation plan, but paid for privately by retirees under a group plan through an insurer.
WSBC acknowledged the language was "has access", and responded indicating one of the options they would consider was asking PBC to allow late enrolment in the dental plan, or otherwise eliminate the dental plan completely to allow retirees to apply for the CDCP. I suggested they not change the plan to allow for late enrolment as that would be to the prejudice of the 2/3s of employees who had declined coverage, as it would change "had access" into "has access", and render uninsured retirees ineligible for CDCP coverage.
The federal government has made a mess out of all of this. But they recently tried to fix it. You are still excluded from coverage under the CDCP if you have dental coverage "through your pension benefits", but may claim the CDCP if you opted out of that coverage prior to December 11, 2023 (presumably the effective date of the CDCP), AND you can't opt back in under the pension rules. I don't believe this provision applies to those who bought the WSBC dental plan regardless, for as I've explained above it is not a pension benefit, but a private group plan purchased by the retiree from an insurer. And on that account the feds say: if you purchased your current dental insurance policy privately ..., you’re not eligible for the CDCP while that coverage is in effect.
What exactly "while that coverage is in effect" means -- like can you cancel your private coverage and be eligible for the CDCP -- is unclear. They have been quoted as saying: "A spokesman for Health Canada told CBC News that ppl who purchased private dental insurance plans on their own will qualify for the national program -- but only after their existing private policies are no longer in effect".
All as clear as mud?
Some final takeaways.
My belief is if you didn't purchase the optional WSBC retirees group dental plan at the time of retirement (and otherwise financially qualify) you should be eligible for the CDCP. That is based on "one time only" offer of coverage at the time of retirement.
If you purchased the coverage, you will likely wish to wait until there is further clarity around whether you can initiate cancellation of the coverage, and obtain replacement coverage under the CDCP. Of course you need to do your own due diligence around the costs and benefits around making such a significant change. Bear in mind coverage will likely be far more limited under any federal plan -- it will be financial means tested, and certainly considerably less generous than that available under a private plan.
Lots more to come on this, of that I'm sure.
Have you had any experience in dealing with applying for the CDCP, and if so, with what result? If you want to share your experience you can reply here, to this blog post, which can be seen by anyone who accesses the blog.
This is the WCBREA's first blog post. We hope to use it more in the interest of communicating with our members in a timely way on matters of interest to the membership.
