Understanding Alberta’s Bill 11

Since we first wrote about Alberta's Bill 11, more information has become available. This follow-up shares additional detail to help employers understand the changes as they prepare for the provisions taking effect on October 1, 2026.

AGE-BASED RESTRICTIONS

Employer-sponsored group benefits plans with drug and certain supplemental health coverage under Extended Health Care (EHC) will no longer be permitted to terminate or reduce that coverage solely based on age for their Alberta employees. Coverage must continue for as long as they remain actively employed. This means:

• Contract Language: Insurer contract language must remove any age-based restrictions. For national plans that include Alberta residents, employers should confirm with their insurer whether the required changes will apply only to Alberta members or to everyone in their existing classes under the plan.

• Reinstatement & Opt-Out: Eligible active employees whose coverage previously ended because of an age restriction will need to be reinstated, with enrollment handled according to the applicable implementation requirements. If an employer allows employees to opt out of EHC benefits (such as in a flex plan), eligible Alberta employees must retain the same option regardless of age.

• Plan Design Changes: Employers may still change their EHC plan design and offer different benefits to different employee classes, provided those differences are not based on age.

• Other Group Benefits: An employer does not have to remove age-based restrictions on other benefits, such as Life/AD&D, Critical Illness, Disability, Emergency Travel, Dental Care, or Spending Accounts. Therefore, termination ages for these benefits may still vary. We do recommend that employers consider removing age-based restrictions on Dental Care, given that this is typically a core benefit for employees. Otherwise, an employee who remains actively employed may continue to receive EHC coverage but lose Dental Care coverage solely upon reaching that age restriction.

• Retiree Benefits: The requirement to remove age-based restrictions does not extend to retiree benefits. There is no requirement for employers to provide retiree benefit plans.

• Dependents: The requirement to remove age-based restrictions does not extend to a member's dependents. That said, we recommend that employers consider not applying an age restriction to dependents. Removing a member's family member from coverage due to age, while the member remains actively employed, could negatively affect the member's experience.

PAYOR PROVISIONS

The Alberta government-sponsored programs, Non-Group Coverage and Coverage for Seniors, will become payor of last resort for drug and certain supplemental health claims. This means employer-sponsored group benefits plans and any personally owned individual insurance plans with this coverage will adjudicate claims before the government-sponsored programs in the coordination of benefits process. It is important to note that where an Albertan has a Health Care Spending Account (HCSA), they will not be required to submit claims and exhaust these benefits before they are eligible to receive benefits under the government-sponsored programs.

• Coordination of Benefits: For simplicity, should an employee be covered under a government-sponsored program, this is how the coordination of benefits process will work. Should an individual also have coverage as a dependent under their spouse's or a stepparent's plan(s), that coverage is coordinated as an additional payor in the order below.

1) Group Benefits Plan(s)

2) Individual Insurance Plan (typically pays after group benefits plan)

3) Government-Sponsored Program

4) Health Care Spending Account(s)

• Government-Sponsored Programs: With employer-sponsored group benefits plans now paying before government coverage, it helps to know what these programs cover once a claim reaches them. The table below outlines what Non-Group Coverage and Coverage for Seniors provide as of October 1, 2026.

	Non-Group Coverage (under 65)	Coverage for Seniors (65+)
Prescription Drugs	~6,000 DINs under the ADBL
Clinical Psychological Services	$60 per visit; $300 per family per benefit year
Chiropractic Services	No coverage	$25 per visit; $200 per participant per benefit year
Prosthetic & Orthotic Devices (including mastectomy prosthesis)	Up to 25% of maximum allowable amount	No coverage
Land Ambulance Services	Coverage for medically necessary trips to and from an active treatment hospital
Hospital Accommodation	Differential cost for private or semi-private room in an active treatment hospital	No coverage
Home Nursing Care	$200 per family per benefit year

Alberta Drug Benefit List (ADBL) - Interactive List: www.ab.bluecross.ca/dbl/publication

Non-Group Coverage: www.alberta.ca/non-group-coverage

Coverage for Seniors: www.alberta.ca/coverage-for-seniors-program

EMPLOYER CONSIDERATIONS

• Employee Demographics: Review membership to identify any employees residing in Alberta, and consider how the changes affect contract language, plan design by class, reinstatement, and opt-out options.

• Contract Language: Ensure the insurer’s contract language removes any age-based restrictions. Please note that most insurers are automatically updating their contracts to reflect these changes; however, this should be verified.

• Reinstatement & Opt-Out: Reinstate any eligible active employees whose coverage previously ended because of an age restriction. If employees are allowed to opt out of EHC benefits (such as in a flex plan), eligible Alberta employees must retain the same option. If an employer contravenes the legislation, the employer may be ordered to reinstate the employee’s coverage and reimburse the employee for any claims paid from when their coverage was cancelled.

• Plan Design Changes: Consider reviewing the plan's drug formulary, specialty drug management program, biosimilar substitution policy, prior or special authorization requirements, stop-loss and pooling thresholds, coinsurance levels, annual or lifetime maximums, and the potential introduction of a HCSA to offset increased member out-of-pocket costs. Also consider removing age-based restrictions on Dental Care. None of these are required or prohibited by Bill 11. The one principle that must hold is that a plan cannot be designed in a way that indirectly targets older employees, as this would reintroduce age discrimination through indirect means.

• Retiree Benefits: If offered, consider reviewing the termination age on these benefits as this is where one of the biggest impacts is expected to show up.

• Claims Experience: Higher claims can arise from two groups under these changes: employees rejoining or joining the plan because their coverage previously ended due to an age restriction, and employees already enrolled who also hold government-sponsored program coverage affected by the payor provisions. As a result of both the age-based restriction and payor provision changes, some employers may experience an increase in claims. Ongoing review of claims experience in advance of renewal is recommended, with estimates that account for the plan's membership, claims experience, plan design, and insurer pooling arrangements. The full financial impact may emerge over the 2027 and 2028 renewals.

• Renewals: Insurers are estimating that EHC claims could rise by roughly 2-5% on combined drug and supplemental health claims, though the actual impact will vary by group and some employers may fall outside that range. As costs previously paid by government-sponsored programs move to the group benefits plan, both claims and premiums may rise, and insurer stop-loss and pooling charges may be affected as well.

EMPLOYEE CONSIDERATIONS

• Reinstatement & Opt-Out: Eligible active employees whose coverage previously ended because of an age restriction should enroll in their group benefits plan according to the applicable implementation requirements. If employees are allowed to opt out of EHC benefits, they can consider this option given their personal circumstances and in relation to the government-sponsored programs if they are enrolled in one. Employees should also consider changes to single or family coverage and adding eligible dependents that were previously excluded because of an age-based restriction, unless the employer chooses to apply an age restriction to dependents.

• Prior or Special Authorization Requirements: Employees with both a group benefits plan and government-sponsored coverage may now need approval from the group benefits insurer for a drug previously paid through the government-sponsored program first, even if government approval is already in place. Employees should confirm that any required authorizations are in place to avoid delays in processing claims.

• Coordination of Benefits: Albertans are expected to disclose to the service provider all the drug and supplemental health insurance plans in which they are enrolled and have coverage. If the service provider does not have this information, they will not be able to submit claims in the correct order in accordance with the legislation.

• Plan Maximums: Employees with both group benefits and government-sponsored coverage may have an increased likelihood of reaching the annual or lifetime maximums in their group benefits plan. What’s important here is timing. If an employee uses their annual or lifetime maximums in their group benefits plan first and the drug and supplemental health claim is not covered under their government programs, they may see increased out-of-pocket expenses. It is important to note that members who don’t coordinate their benefits with government-sponsored programs won’t be impacted.

Much of the administrative work is being handled by insurers, but the changes are significant, and questions are natural as October 1, 2026 approaches. If anything about how these changes affect your plan is unclear, please reach out - we are glad to help you work through it.