Bill 11: What It Means for Your Alberta Benefits Plan

Alberta’s Bill 11 is one of the most consequential pieces of legislation in a generation to affect healthcare and group benefits in the province. This article outlines what you need to know, and what steps we recommend you take now.  

The bill takes effect later in 2026 and has two central themes impacting employer benefits:

1.      The payor of the last resort will change from private plans to government, and

2.      Employers must continue unreduced coverage for active employees aged 65 and older.

The provincial government is still ironing out many of the details, but with the current confirmed information, we know that employers can expect the following:

·         Your plan costs will likely increase at your next renewal

·         Specialty drug coverage will be most affected

·         Employees over age 65 must maintain full coverage

·         We have steps you can take now to reduce the impact.

Not sure how this affects your specific plan? Please reach out to schedule a 20-minute call. We are here to help you navigate what this means to you.

Let’s dive into what we know and what will happen next.

When do the changes happen?

The Government of Alberta passed Bill 11, the Health Statutes Amendment Act, 2025 (No. 2), in November 2025. Certain measures, such as drug coverage, are slated to begin in summer 2026, with full implementation of the legislation by 2027. Exact dates have not yet been confirmed.

How does the change in Payor of Last Resort work?

Bill 11 changes the payment order between government-sponsored and private plans. Moving forward under Bill 11, when a claim is eligible under both an employer group plan (or other private plan) and a government-sponsored plan, the claim must be billed to the employer or private plan first, before government coverage applies. This affects plans covering both active employees and retirees.

Therefore, the Alberta Government becomes the Payor of Last Resort for prescription drugs and certain supplemental health benefits. This is a significant shift. Before this legislation, private plans were the payor of last resort, and employers with Alberta residents structured their group benefit plans with this framework to manage costs.

Note that in cases where private insurance does not cover benefits eligible under Alberta’s provincial program, for example, if a plan member is ineligible for coverage, the provincial program will continue to pay.

Importantly, Bill 11 does not mandate that employer benefit plans provide minimum coverage levels. This gives employers flexibility to adjust their plan designs, coverage levels, and drug maximums to manage costs in light of Bill 11.

Example of an individual, low-cost drug claim claim under Bill 11 where the plan member has Alberta Blue Cross Non-Group coverage.

Drug cost: $200

Private plan: 70% coverage

Alberta Blue Cross Non-Group plan: Pays the balance of the claim, with plan members paying no more than 30% up to a maximum of $35 per prescription (effective April 1, 2026).

How much does the employer plan, province and member pay before and after Bill 11 for the same claim?

Payor	Pre-Bill 11	Post-Bill 11
Employer plan	$60	$140
Alberta Blue Cross Non-Group Plan	$140	$50
Plan member	$0	$0

Notice how the employer group plan’s cost for the claim jumped from $60 to $140, a 133% increase.

Now let's consider an example of a specialty or high-cost drug claim

For over 20 years, many employers have contained specialty or high-cost drug costs by using the Alberta Blue Cross Non-Group Plan. This government pharmacare program offers an unlimited drug maximum and was first payor for plan members who were enrolled and paid premiums. This dynamic will also change under Bill 11.

According to the Canadian Group Insurance Brokers (CGIB), 1–3% of Albertans who use prescription drugs have annual drug costs over $10,000; many of these medications would be considered “specialty.”

Drug cost: $12,000

Private plan: 70% coverage up to $5,000 annual maximum

Payor	Pre-Bill 11	Post-Bill 11
Employer plan	$420	$5,000
Alberta Blue Cross Non-Group plan	$11,580	$6,860
Plan member	$0	$140

The employer group plan’s claim cost jumped from $420 to $5,000, a 1090% increase. Also, the plan member incurs an out-of-pocket expense of $140 under Bill 11.

The cost impact to plan members could potentially be reduced by adding a health spending account, however plan sponsors will be absorbing the brunt of the costs. Renewal rate adjustments will be impacted by more claims running through the plan and adjusted pooling charges.

Which supplemental health benefits does Bill 11 impact?

The Payor of Last Resort provision extends to certain supplemental health benefits currently covered by the provincial plan. These include:

-          Ambulance services

-          Clinical psychological services

-          Home nursing care

-          Chiropractic services

-          Prosthetic and orthotic benefits

-          Mastectomy prosthesis

-          Hospital accommodation

Coverage past age 65

As part of Bill 11, employers must continue drug and healthcare coverage without reduction for active employees aged 65 years or older.

Most employer plans do not limit coverage for employees aged 65 and older, but we recommend you review your contract details to ensure that extended health benefits do not cease at age 65.

The Government of Alberta is finalizing details, including:

-          How long coverage must continue

-          How different types of benefits are affected

-          How this fits with current insurance contracts

Note that group benefit plans may continue age-based restrictions for retiree plans.

Insurance carriers will need to update their contracts to accommodate employees working past age 65. Currently there is no consistency between carriers. Some allow for a termination age of “retirement” while others terminate coverage automatically at age 75, 80, or 85.

What are the impacts of Bill 11?

As Bill 11 shifts eligible costs from the provincial plans to private coverage, plan costs and claims experience may change, affecting rates. We expect the cost impact to be neutral or upward, depending on factors such as plan design, claims experience, and member demographics. The employer plans most affected will be:

1.      Employers with an aging workforce;

2.      Those where specialty drug programs are being claimed;

3.      Employer plans with higher drug maximums.

We anticipate the industry will start to see the impact on costs from Bill 11 by their 2027 renewals.

What’s next and what should we do?

We’re engaging with our insurer partners to learn how they will adjust their pricing in anticipation of Bill 11 and having initial discussions with clients to determine which adjustments we should recommend.

As the Government of Alberta finalizes the details of its implementation of Bill 11, we can work with you to examine factors such as the demographics of your team, existing exposure to high-cost specialty drugs, and drug plan design. Our goal is to help mitigate the financial impact of this new legislation. Our core philosophy is to ensure the long-term sustainability of our clients’ benefits plans.

Some of the initial steps we recommend:

1.      Look at exposure to high-cost or specialty drugs

2.      Review annual drug maximums

3.      Consider a Health Spending Account if your organization does not have one already. This tool can help plan members with out-of-pocket expenses resulting from Bill 11.

As the province finalizes Bill 11’s details, we will also work with clients to create clear employee communications on how the legislation will impact them.

Please look forward to future updates as we learn more about implementation dates and further details. Preparing for Bill 11 will require thoughtful planning to ensure any changes are fair, sustainable, and clear to employees.