13 September 2011 Ruling Case No. 102589 (similar to 13 September 2011 Ruling Case No. 118500)

CRA stated:

Nursing homes, which have registered nurses on staff to provide 24-hour nursing care to the residents, are the type of facilities that we consider to fall within paragraph (c) of the definition of "health care facility" section 1 of Part II of Schedule V. In contrast, a facility operated to provide only support services and assistance with activities of daily living without nursing care would not meet the criteria of this paragraph.

The registrant's "group homes" for people with developmental disabilities did not so qualify as health care facilities as the residents did not "require continuous nursing and personal care under the direction or supervision of qualified medical and nursing care staff."

The registrant (a charity) operated "group homes" whose main function was to give on-going life skills training and life-long learning and support in developments skills to people with significant developmental disabilities. The individuals providing these services worked in the fields of social services, nursing and psychology. After already having ruled that the group homes did not qualify as health care facilities, CRA went on to note that as the above activities did not fit the definition of a "facility supply," the registrant was not a "facility operator" and not eligible for the public service body GST rebate.