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Alberta Bill 11: Health Statutes Amendment Act Updates

The Alberta government has confirmed key details of Bill 11, the Health Statutes Amendment Act, 2025 (No. 2), since our last update. The legislation received royal assent on December 11, 2025, and insurers have confirmed that both changes affecting group benefits plans will take effect on October 1, 2026. Here is what we now know.

Payor of Last Resort: Confirmed Details

Employer-sponsored plans will become the first payor for prescription drugs and select supplemental health benefits. Alberta’s government programs (Coverage for Seniors and Non-Group Coverage) will pay last, covering only what private plans do not. This reverses the current payment order and applies to both active employee and retiree plans.

Beyond prescription drugs, the change extends to ambulance services, clinical psychological services, home nursing care, chiropractic services, prosthetic and orthotic benefits, mastectomy prostheses, and hospital accommodation.

Health Spending Accounts are excluded. Plan members are not required to exhaust their HSA before accessing government coverage.

Age-Based Termination: Confirmed Details

Employers cannot terminate or reduce prescription drug and select extended health coverage for actively working employees. Insurers have confirmed the following:

  • Re-enrolment required: Active employees previously removed from coverage due to age must be added back to the plan.
  • Opt-out permitted: Employees may choose to opt out, provided the choice is offered to all employees.
  • Alberta residents only: The requirement does not apply to out-of-province employees.
  • Some benefits excluded: Life, disability, dental, and travel benefits are not included, and may still be subject to age-based termination.
  • Coverage for Seniors (provincial plan): Not required to maintain coverage but remains subject to the payor of last resort rules.

Physician Services

Bill 11 also allows employer plans to offer coverage for private physician services, such as physician visits and diagnostic testing. This may shift some medically necessary costs to private plans over time. We will share more as details emerge.

What does this mean for you?

Plan sponsors should expect drug and extended health costs to increase as private plans move into the first payor position, particularly for plans with members who currently coordinate with provincial programs. Ahead of October 1, 2026, we recommend:

  • Reviewing plan documents and contract wording for age-based termination language.
  • Identifying actively working employees aged [insert termination age noted in plan documents] who may need to be re-enrolled.
  • Modelling the cost impact with your Sterling advisor ahead of your next renewal.

Our team is monitoring implementation closely and will share updates as the Alberta government and insurers release further guidance.

 

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