The federal government will not collect up to $434.8 million that the Canadian Dental Care Plan (CDCP) has paid, or will pay, for people later found to have had access to private dental coverage. At first, the plan relied on applicants’ word that they lacked that access. The government’s note says only that “a small number” of people are affected. It does not say how many.
A year earlier, the government said something different. The explanatory note to its October 2025 order on dental care debts said: “The standard funds recovery process will apply to any future instances where individuals are found to be ineligible for CDCP services received.”
The new order was made September 25.
What is being forgiven
A remission order is one way cabinet cancels a debt owed to the government. The Financial Administration Act allows it, on the Treasury Board’s recommendation, when cabinet considers collection “unreasonable or unjust” or considers that “it is otherwise in the public interest” to remit the debt. This order relies on the first ground: it says collection is unreasonable.
This order cancels what the plan paid providers for the affected people’s care, plus interest, across the plan’s first three benefit periods, from May 1, 2024, to June 30, 2027. The note says those who had repaid “will be reimbursed for the debt paid, plus any applicable interest.” The last period hasn’t ended, so the order also covers care that may not have happened yet.
The $434.8 million is an upper estimate, not a tally of money already spent. The note says it is “based on an analysis of member eligibility files and CDCP claims information.”
In its first benefit period, the plan paid $2.1 billion toward care, according to its annual report. As of September 30, 5,015,189 members were enrolled for the 2026 to 2027 benefit period, including 645,410 in BC, Health Canada’s plan statistics show.
How the plan checks who qualifies
The plan covers dental care for people whose adjusted family net income is under $90,000 and who have no access to private dental insurance, such as through work, a pension or a family member’s plan. The CDCP pays the dentist, denturist or hygienist directly.
Applicants attest that they have no access to private coverage. The new order’s note says tax slips for 2022, the tax year used when the plan launched, didn’t report dental coverage. The government’s checks after enrolment found that some people had incorrectly attested. They were removed from the CDCP and, the note says, “notified that they may need to repay the cost of care they received.”
The Dental Care Measures Act took effect in June 2023. Starting with the 2023 tax year, it requires employers and pension plan administrators to state on T4 and T4A slips whether employees, pensioners and their families were eligible for dental coverage offered through them. That doesn’t capture plans people buy themselves. Under a Health Canada administrative policy announced by the Canada Revenue Agency, employers and plan administrators didn’t have to fill in the dental box for 2023 and 2024 when no coverage was offered, if they had made all reasonable efforts to comply.
The annual report says Health Canada and Service Canada “use this information on dental insurance to verify whether applicants are eligible.” The new order’s note says “it is now possible to confirm eligibility before persons are enrolled,” and that the application review process “is being revised” to do so. It doesn’t say when that revision will be done.
Two orders, two groups
The October 2025 order forgave up to $29 million. It covered people who were approved, or charged the wrong co-payment, because of a government error in calculating family income. It also covered people with access to dental insurance who applied before May 1, 2024, when only seniors 70 and older could apply and, the note says, “explanations about CDCP eligibility criteria were being clarified.”
Its income-error relief excluded anyone who “incorrectly attested in their application that they did not have access to dental insurance on or after May 1, 2024,” and its other relief reached only people who applied before that date.
The new order covers people in that position across all three benefit periods, with a ceiling about 15 times the 2025 order’s, though the two cover different groups and periods.
The government’s case
According to the note, those affected generally have low or modest incomes and received “a service covered by the CDCP” rather than a direct payment. Some who were billed told the government the rule was unclear and that “they cannot afford to repay the cost.”
The note says: “Given the reliance on self-attestation during the initial implementation of the CDCP and the inability to distinguish among the circumstances that led to incorrect attestations, pursuing recovery of the resulting debts would, in these circumstances, be unreasonable.” It says it is “not possible to determine with certainty why a person incorrectly attested” that they lacked access to private coverage, “but it is plausible that at least some persons misunderstood this eligibility requirement.” It also says the cost of pursuing the money “may be disproportionate to the amounts recoverable.”
The note concludes: “Therefore, remission represents an efficient and proportionate response that allows resources to be focused on strengthened eligibility verification measures and ongoing program delivery.”
What the order doesn’t say
The order doesn’t say how many people have repaid, how much will be refunded or how much of the estimate is care still to come. Its note doesn’t give the size of individual debts. It says “many of the debts” are “relatively small on an individual basis” but “may be significant to those persons.” It also doesn’t give an estimate of what collecting would cost, or mention the 2025 order. The Auditor General of Canada is scheduled to deliver an audit of the dental care plan to the House of Commons on October 29.