CRA indicated that where a provincial government sponsors a program that is designed to deliver incentive payments or earnings supplements directly to eligible nurses, such amounts are included in their income under s. 56(1)(r)(i), whereas where it sponsors a program designed to have employers deliver the payments directly to them, such amounts are included in their employment income under s. 5(1). This distinction is significant, in part, because in the first case, no source deductions are required for Canada pension plan or employment insurance premiums.
CRA noted that the Ontario Community Commitment Program for Nurses (CCPN) (which is intended to attract eligible nurses who have not been recently in practice, by providing them with $25,000 in grant funding in exchange for a two-year commitment to an eligible employer) fell into the second (s. 5(1)) category.