Canadian Dental Care Plan: The Impact on Group Dental Plans & T4 Reporting
Dear Clients,
The Canadian Dental Care Plan (CDCP) is a federal initiative introduced to help eligible Canadians access essential dental care services, including exams, diagnostics, preventive, restorative, and emergency treatments. The program began a phased rollout in late 2023 and as of May 2025, is now available to eligible Canadians of all ages.
Understandably, many employers have questions about how the CDCP may affect private group dental plans – particularly regarding eligibility, plan design, and rates. Below is a summary of key information to help you navigate these changes.
Who Qualifies for the CDCP?
To qualify for the CDCP, an individual must:
- Not have access to dental coverage through a private or employer-sponsored plan (even if not currently enrolled)
- Have an adjusted family net income of less than $90,000 annually
- Be a Canadian resident for tax purposes
- Have filed a tax return in the previous year
Important: If an employee is eligible for your group dental plan, even if they waive coverage, they are not eligible for the CDCP. Based on eligibility criteria, some employees may have spouses that qualify for CDCP coverage. In this case, the CDCP acts as a payor of last resort. Private plans (if any) must be exhausted before CDCP coverage will apply.
Impact on Private Group Dental Plans
Because the CDCP does not replace or integrate with private dental plans, and access to group benefits disqualifies individuals from CDCP participation, employer plan enrolment is expected to remain stable, with most employees continuing to rely on their employer-sponsored dental benefits. Group plans also offer broader and more comprehensive coverage than the CDCP, including services like orthodontics and major restorative work. In addition, group plans generally provide more flexibility when choosing dental providers, generally lower annual limits, shorter wait times, and no income-based co-payments.
As a result, the CDCP is not expected to cause any significant changes in claim volumes or plan participation, and the overall impact on group dental premiums is anticipated to be very minimal at this time. We will continue to monitor trends as the program evolves and will provide updates as needed during your renewal process.
T4 Reporting Requirement
We would also like to remind you of an important reporting requirement introduced in 2023. Employers must now report whether employees (and their dependents) had access to any dental coverage (including health care/wellness spending accounts, co-paid dental benefits, or opt-in dental benefits) by completing Box 45 on each employee’s T4 slip. The available codes are as follows:
- Code 1: No access to any dental coverage
- Code 2: Access to dental coverage for the employee only
- Code 3: Access to dental coverage for the employee, spouse, and children
- Code 4: Access to dental coverage for the employee and spouse only
- Code 5: Access to dental coverage for the employee and children only
Please note, you must report the dental coverage the employee had access to in the previous tax year, not the coverage they chose to enroll in. Typically, employers offering a group dental plan will use Code 3; however, we recommend consulting your payroll provider or accountant to ensure accurate reporting on your T4 slips.
At this stage, the CDCP is not expected to significantly impact private group dental plans, but we will continue to monitor developments and provide updates as needed. If you have questions about how your current plan compares to the CDCP or would like to review your plan design, please contact your Lawrie Insurance Group Benefits Consultant or Account Manager.
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