The Alberta government has recently passed Bill 11, the Health Statutes Amendment Act, 2025 (No. 2), which may have significant implications for private insurance plans and the broader healthcare landscape in Alberta. Three key changes are expected to stem from Bill 11:

• Provincial plans will become payors of last resort for drug coverage, shifting the role of private plans to first payor.
  
  
• Employers will no longer be allowed to terminate or reduce health benefit coverage for employees 65 years and older who are actively employed.
  
  
• Modifications to rules outlining how physicians participate in Alberta’s publicly funded Alberta Health Care Insurance Plan will give physicians more practice flexibility between the public and private plans.

Bill 11 changes are expected to begin taking effect in the summer of 2026; however, many details remain under development. These changes introduce several important considerations for Alberta plan sponsors and plan members ranging from plan design structure to contractual provisions and financial impacts. This article will provide an overview of the potential impact while helping plan sponsors prepare for the changes.

Provincial Plan: Payor of ‘Last Resort’

Bill 11 introduces a significant shift in the coordination of benefits involving the Alberta Seniors Drug Plan and the Non-Group Alberta Blue Cross Drug Plan.

At present, when an Alberta resident turns 65, the Alberta Seniors Drug Plan becomes the first payor for eligible prescriptions listed on the provincial formulary, as well as for certain health-related benefits. Coverage is currently set at 70%, subject to a maximum out-of-pocket cost of $35 per prescription (as of April 1, 2026), with the remaining balance typically paid by the individual’s employer-sponsored plan, if applicable.

Under the new legislation, the provincial plan will become the payor of last resort. As a result, individuals aged 65 and over who have coverage through an employer-sponsored benefit plan will be required to submit drug claims to their employer plan first, with any remaining unpaid balance eligible for submission to the provincial plan. This represents a first-of-its-kind policy shift in Canada.

All Alberta residents under the age of 65 are eligible to enrol in the Non-Group Alberta Blue Cross Drug Plan. This plan is not medically underwritten and requires payment of a modest monthly premium. Coverage includes 70% of eligible drug costs, with a maximum out-of-pocket amount of $35 per prescription (as of April 1, 2026).

For individuals under age 65 who are covered under both an employer-sponsored benefit plan and the Non-Group Drug Plan, Bill 11 similarly designates the government plan as payor of last resort. This change is expected to significantly affect employer plan claims experience and premium costs, particularly in situations involving high-cost drug claimants whose expenses were previously absorbed largely by the Non-Group plan. The impact may be especially pronounced for employer plans that do not include annual drug maximums.

What it Means for Employers and Employees

This change effectively shifts a portion of prescription drug costs from the provincial government to private employers. The increase in claims under private plans will vary based on various factors including the underlying group coverage plan design (e.g. coinsurance, annual maximums, formulary, etc.) as well as the distribution of prescription drug claims (e.g. presence of high claimants). This increase in claims is expected to place upward pressure on benefit plan premiums, necessitating future rate adjustments to ensure plans remain adequately funded. In cases where benefit plan costs are shared between employers and employees—as is most often the case—it may also result in increased premium costs for plan members over time, driven by higher claims experience.