CEWS Feedback Response Template

The Government of Canada is currently undertaking a consultation process for the CEWS programThe consultation will only be open for feedback until Friday, June 5th, 2020

 

To participate in the short survey included in the consultation process, please visit this link. The government has also suggested a number of framing questions to guide additional feedback, one of which relates directly to the issue facing SaskSport payroll customers. In order to provide more directed feedback to government as they consider program adjustments, we encourage your organization to email the program officers at fin.cews-succ.fin@canada.ca. Please feel free to cut and paste the messaging below to include in your response, along with any other comments you may have about the CEWS program.

 

SaskSport has put together the following template for organizations to use in response to this feedback; though organizations are encouraged to adapt and personalize the message as they see fit.

 

  1. Are there specific challenges associated with the CEWS program? For example, are there challenges with respect to its accessibility, its incentive impacts, or any other aspect?

The challenge our organization faces in applying for the CEWS is the way in which legislation was written for this program. The legislation bringing the CEWS into force requires that an entity had an RP account on March 15, 2020 to be deemed eligible and qualify for this emergency relief. We receive payroll services through a third party provider, which services the non-profit sport, culture and recreation sector in Saskatchewan. In the interest of efficiency and to keep costs low, this third party, has provided this service for 30+ years under an arrangement where each client’s statutory remittances have been made under one payroll account with CRA (“RP” account) which is more efficient for the service provider, our organization and the Canada Revenue Agency.  As such, we do not meet the eligibility requirement of having a RP account at March 15, 2020, and the third party cannot apply for the wage subsidy on behalf of an employer by using their own business number and payroll program account (as stated in FAQ 3-8). Such an arrangement is not uncommon and amateur sport federations in other provinces offer the same type of program.  Over the course of the 30+ years, it is our understanding that the third party has had different communications with CRA and Service Canada for consulting or advice on a variety of topics and both have been made aware of the unique situation and they were never advised that this arrangement for processing our payroll is incorrect or that changes should be made.

 

As clearly stated, the purpose of these programs is to support employers, including not-for-profits, during a time of crisis, and to support employees by keeping them on payroll and connected to their jobs. We trust that this administrative issue is not intended to act as a barrier for eligible organizations to access emergency programs. As it has been a number of weeks since this issue was raised, many organizations similar to our own, are now facing an uncertain future without access to these programs.

 

As a result of everything noted above, our organization is one of at least 140+ in Saskatchewan that cannot currently apply for the CEWS support, which we believe is unintentional and we ask that the issue be resolved as quickly as possible.


Letter Template for Mailing Members of Parliament 

May 28, 2020

 

Dear <<insert honorific, name>>

 

RE:  Canada Emergency Wage Subsidy and Canada Emergency Business Account

 

As a not-for-profit organization in Saskatchewan’s sport, culture and recreation sector, we wish to bring an issue to your attention which makes us unable to access the Canada Emergency Wage Subsidy (CEWS) and the Canada Emergency Business Account (CEBA) and threatens our ability to operate today and could be disastrous for our organization along with others in the province.

We receive payroll services through the Administration Centre for Sport, Culture and Recreation (Admin Centre).  The Admin Centre is a wholly owned subsidiary of Sask Sport Inc. and offers business support services to not-for-profit organizations in the sport, culture and recreation sectors. This includes payroll services for approximately 140 not-for-profit organizations like ours.

In the interest of efficiency and to keep costs low, the Admin Centre has provided this service for 30+ years under an arrangement where each client’s statutory remittances have been made under the Admin Centres payroll account with CRA (“RP” account) which is more efficient for the Admin Centre, our organization and the Canada Revenue Agency.  Such an arrangement is not uncommon and amateur sport federations in other provinces offer the same type of program.  Given this practice, many of the Admin Centre’s payroll clients, including <<insert PSO/club/association name>> do not have their own RP account.  Over the course of the 30+ years, it is our understanding that the Admin Centre has had many different communications with CRA and Service Canada for consulting or advice on a variety of topics and both have been made aware of the unique situation and they were never advised that this arrangement for processing our payroll is incorrect or that changes should be made.

The legislation bringing the Canada Emergency Wage Subsidy (CEWS) into force requires that an entity had an RP account on March 15, 2020 to be deemed eligible and qualify for this emergency relief. Further, the application process for the Canada Emergency Business Account (CEBA) requires the input of this same RP account number.  As a result, our organization is one of at least 140+ in Saskatchewan that cannot access the CEWS nor the CEBA. This unintended consequence of the legislation was brought to the attention of CRA and Finance in mid April by a number of concerned parties including CPA Canada and the Canadian Tax Foundation.

Organizations are now having to lay off employees, as any available cash flow is being used for rent, utilities and other mandatory payments. Funds are beginning to run out and some organizations may have to shut their doors.

We have been informed that under the current rules, CRA indicates that the Admin Centre is NOT able to make an application on our behalf, meaning that <<insert PSO/club/association name>> remains unable to access the emergency relief available under these programs.  We ask that this issue get brought to the immediate attention of the appropriate Ministry.

As clearly stated, the purpose of these programs is to support employers, including not-for-profits, during a time of crisis, and to support employees by keeping them on payroll and connected to their jobs. We trust that this administrative issue is not intended to act as a barrier for eligible organizations to access emergency programs. As it has been a number of weeks since this issue was raised, many organizations are now facing an uncertain future without access to these programs.  We believe this result is unintentional and we ask that the issue be resolved as quickly as possible.

Concerned,

 

Contact name

Organization name