Alberta’s Bill 11 Makes Changes to Provincial Health Coverage – Key Changes and Potential Implications

In late November, the Government of Alberta put forward Bill 11: The Health Status Amendment Act, 2025 (“the Act”).It was subsequently passed and received Royal Assent on December 11, 2025.

Bill 11 will have material impact on many employment-based group benefit plans with employees in Alberta and could portend similar changes in Canada – Namely, Provincial Governments moving costs from themselves to employment-based group benefit plans. Bill 11 incorporates three key changes:

1. Dual Public-Private Health Care Model: The Act allows physicians to provide services in both the public and private sectors. Amendments related to modernizing practice rules for physicians would come into force upon proclamation planned for spring 2026.
2. Removal of Age Discrimination for Supplementary Health Care Plans: The Act removes the ability to terminate, reduce or modify coverage for active members for drug and supplemental health coverage solely on the basis of age. Drug and Supplemental Health plans with termination age of age 65 would require changes. Amendments related to drug coverage would come into force upon proclamation planned for summer 2026.We are assuming amendments to Supplemental Health will follow a similar timeline (was not explicitly stated).
3. Last Payor Provision for Alberta Public Health Care: Bill 11 revises the public health plan to be the payor of last resort. It specifies “no drug and supplemental benefit shall be paid under a public drug and supplemental benefits plan in respect of a drug or supplemental service provided to a member if the member is entitled to receive a drug and supplemental benefit from an alternative payor for the same or equivalent drug or supplemental service.” Amendments related to drug coverage would come into force upon proclamation planned for summer 2026.

Overall, the impacts of these changes could be substantial.#1 moves us closer to a US-style health care model, with a greater degree of private services, namely physicians. #2 and #3 together shift costs away from the provincial health care plan and towards group benefit plans – namely for plans with individuals over age 65 (currently having most of their claims covered through the Alberta Seniors’ Drug Plan).The greatest impact will be felt by plans that offer post-retirement benefits or those with a high proportion of active members over age 65.

Our Thoughts

Across the country, we are hearing more and more that provinces/territories are feeling the pressures of physician shortages, limited hospital capacity and limited funding available to fund the rising costs of an aging population. This strain on the healthcare system does not appear to be subsiding.

As provinces face this challenge, they will be forced to make difficult decisions.

We’ve seen Quebec pursue a few fairly bold changes in its healthcare delivery:

• Bill 2 (introduced in late 2025), proposing to introduce major changes to healthcare, including the introduction of compensation tied to physician performance targets (though subsequently several components had been rolled back).
• Bill 68 (effective January 1, 2025), limiting employer rights to request medical notes to supplement certain short-term claims in an effort to reduce the administrative burden on physicians.

At the same time, we are seeing situations where public plans position themselves as secondary to employment-based programs:

• The Canadian Dental Care Plan only being available to eligible Canadians without access to private dental insurance.
• In 2021, BC moving to its Insurance Corporation of British Columbia (ICBC) being second payor for wage replacement in auto accidents

We now have the Alberta Government passing Bill 11, which does shift a meaningful amount of healthcare costs to private programs.

The activity above stems from a public health model that is under significant strain and a few provinces, namely Quebec and Alberta, looking to take some bold actions to try to remedy and course-correct.

For plans with covered members in Alberta, we would suggest modelling the impacts of Bill 11 to understand the potential cost implications and risk exposures.

For plans outside of Alberta, we encourage you to begin considering the potential impacts of other provinces moving to second payor or changing their public programs in a way that shifts costs to group benefit plans. It may be too early to take action, but the timing may be right to revisit your plan from the perspective of ongoing sustainability and its ability to withstand major changes in the healthcare environment.

Jojy Oommen
Partner