Bill 11 – Part 1 – Alberta Provincial Changes to Benefit Plans
Written by: Christopher Smith, MBA, CEBS
President
Destiny Benefits Group
connect@destinybenefits.ca
Written June 10 2026, Updated June 19 2026
What is Bill 11?
Bill 11 has been a hot topic in the Employee Benefits space of late. It is also known as the “Health Statutes Amendment Act, 2025 (No. 2)”, and it received Royal Assent on December 11, 2025, becoming Law. Different aspects have and will come into effect at varying times, as it is a multifaceted piece of legislation. The most notable and newsworthy element being physician “Dual Practice”, the ability for physicians to work both in public and private sectors, which has come with its own complexity and discourse. The Bill also altered the Alberta Health-Card processes, laws/offences, and information sharing rules, and statutes related to the restructuring of AHS into 4 integrated agencies. Lastly (and the portion that HR teams, Employers, and Benefits Advisors are most concerned about), there are changes coming to the coordination and eligibility of members for employee benefits plans.
Bill 11 and Private Insurance Plans
There are 2 major implements that are to affect Group Benefit Plans:
1. The Alberta government health insurance plans will be thepayor of last resort, described in the bill as
“the public plan excludes services where the person is entitled to employer-sponsored health benefits”
2. No Age Restrictions for Health Benefits, stated in the bill as
“No employer who establishes, maintains in force or renews an employer-sponsored drug and supplemental benefits plan shall include or authorize the inclusion of a provision in the plan or in an agreement relating to the plan that allows the employer, solely on the basis of a member’s age, to
(a) terminate the member’s membership in the employer-sponsored drug and supplemental benefits plan, or
(b) terminate, reduce or modify the member’s drug and supplemental benefits under the employer-sponsored drug and supplemental benefits plan.”
On the surface, these do not seem like drastic changes to employer sponsored benefit plans, but digging deeper reveals a few issues to consider.
When is the Effective Date?
It may be sooner than you think ! The initial announcement from the government states “planned for summer 2026.” We do have industry insight that October 1st, 2026 will be the effective date, which is fast approaching.
What does this mean for benefits? More Claims = More Premium
The first questions we hear as a consultant are, “Which benefits are affected?” and “How do we make changes to our plan in time?”
Not all benefit lines are included in the bill, mainly Drugs and Supplemental Health coverage. As summarized by Manulife, the changes DO NOT apply to “life, disability, dental, travel insurance, Health Care Spending Accounts, or Lifestyle Spending Accounts.”
The Government of Alberta-sponsored programs, Non-Group Coverage and Coverage for Seniors, will become last payor for the following benefits:
Prescription drugs
Ambulance services
Clinical psychological services
Home nursing care
Chiropractic services
Prosthetic and orthotic benefits
Mastectomy prothesis
Hospital Accommodation
This will have a bottom-line impact to premium moving forward. With Alberta subsidized plans becoming the payor of last resort, any previously covered subsidized plan prescription medication and health claims will now be paid first by the employer or other private plans. Furthermore, many plans terminate Health benefits at age 65 (some at 70, 75, or retirement), and with age restrictions not allowed under Bill 11, those senior employees will become eligible and claim on private plans (a known high-needs group).
A double-whammy for employer health plans, so to speak.
Historical Coordination: Alberta Non-Group and Alberta Coverage for Seniors programs
Before Bill 11, Alberta Non-Group Coverage was generally coordinated similarly to a group plan under CLHIA coordination-of-benefits guidelines, while Coverage for Seniors remained first payor for some benefits.
There has been a strategy implemented by the insurance industry for many years in an effort to curb the rising costs of benefits; try to coordinate high-cost drugs with provincially subsidized plans. In Alberta that is Non-Group coverage through Alberta Blue Cross. Advisors could identify a high-cost drug at a claims review or annual renewal, and through an anonymous process, help that individual coordinate with the government plan and relieve some of the claims pressures for increasing premium to the health plan. For Seniors, there was a similar opportunity in coordinating with the Coverage for Seniors program, although many of these employees would already be excluded from health coverages.
Additionally, some employees may have been coordinating with Alberta Non-Group on their own, knowing they had a high-cost drug that would be covered.
In an effort to cut the provincial costs to the subsidized government plans, this Bill removes the option for the above strategy and transfers claims to employers and individuals that have coverage.
Note: Both supplemental coverages (Non-Group and Seniors Coverage) will continue.
The Bottom-Line Impact
Through discussion with various industry professionals, there seems to be a consensus that the bottom-line impact on average will be at least 6% increases to health premiums (as market insight, not an established universal outcome). Insurers are not starting from scratch in estimating the impact, as they already receive coordination-of-benefits reporting that shows the portion of total claims currently being paid by other plans. This increase is compounded by general inflation, rising drug costs, increased healthcare and medical supply costs, and broader market pressure, with many organizations already reporting extended health cost increases of more than 10%. Claims drive premium, and the changes will be felt at the next renewal or sooner.
There are different ways for plans to fund claims, and those funding types will affect employers differently at the effective date of Bill 11. There are “Fully Insured” and “Self-Insured” benefits.
Fully Insured benefits predict premium moving forward, and therefore changes to premium likely won’t arise until the next renewal. This group should take note of their renewal date.
Self-Insured or ASO plans fund their claims directly on a monthly basis, and will feel the hit from the now uncoordinated claims at their next bill. These plans will need to react more quickly.
Part 1 – Conclusion
The major take-away being, there is legislative change coming Oct 1, 2026 that will alter the landscape of employer benefit plans in Alberta. Part 2 of this series is intended to provide the next steps and options for employers to better prepare organizations. All organizations will be affected differently, and we hope to bring clarity, context, and practical guidance as these developments take shape.
Sources
Alberta. (2026). Coverage for seniors program. Government of Alberta. https://www.alberta.ca/coverage-for-seniors-program
Alberta. (2026). Non-group coverage. Government of Alberta. https://www.alberta.ca/non-group-coverage
Alberta. (2026). Proclamations. Government of Alberta. https://www.alberta.ca/proclamations
Alberta. (2026). Supporting a world-class health care system. Government of Alberta. https://www.alberta.ca/supporting-a-world-class-health-care-system
Alberta Blue Cross. (2026, June 17). Understanding Alberta’s Bill 11 and its impact on health benefit plans. https://blog.ab.bluecross.ca/en/news/health-statutes-amendment-act-bill-11-alberta-benefit-plans/
Alberta Legislative Assembly. (2025). Bill 11: Health Statutes Amendment Act, 2025 (No. 2). https://docs.assembly.ab.ca/LADDAR_files/docs/bills/bill/legislature_31/session_2/20251023_bill-011.pdf
AGA Benefit Solutions. (2026, April 28). Alberta Bill 11 may shift some health costs to plan sponsors and members—3 solutions to explore. https://www.aga.ca/en/blogue/alberta-bill-11-shift-health-costs-plan-sponsors-members-3-solutions-to-explore
Manulife. (2026, June 4). Alberta Bill 11. https://www.manulife.ca/business/news/group-benefits-news/alberta-bill-11.html
Signal49 Research (formerly The Conference Board of Canada). (2026, April 15). Benefits benchmarking 2026: Insights for designing competitive benefits programs [Impact paper].
Sun Life. (2026, March 31). Alberta Bill 11: Legislative change taking effect in summer 2026. Workplace Benefits and Retirement Services. https://workplace.sunlife.ca/en/group-benefits/advisor/advisor-latest-news/alberta-bill-11--legislative-change-taking-effect-in-summer-2026/
Sun Life. (2026). Update on Alberta Bill 11: legislative changes effective October 1, 2026 [Email communication].