RAMQ interpretation of amendments to the Act respecting prescription drug insuranceLinkedIn
There, in black and white
NB Bulletin Vol. 10 N. 15, December 2007
This bulletin is a follow up to our bulletins of March 2007 (Vol. 10, No. 4) and July 2007 (Vol. 10, No. 8) on amendments to the Act respecting prescription drug insurance.
Our March bulletin discussed the new interpretation by the Régie de l'assurance maladie du Québec (RAMQ) on application of the Act respecting prescription drug insurance (the Act) to drugs not on the list of medications covered by the RAMQ. According to the RAMQ, at that time, the Act required private group insurance plans covering such drugs to offer reimbursement conditions at least as generous as those provided under the Act for listed drugs. This interpretation affected calculations of out-of-pocket maximums for plan members, among other things.
The RAMQ recently issued a new bulletin (Info assurance médicaments) on its website specifying that the Act governs only "basic" coverage and not unlisted drugs basic coverage meaning coverage for drugs on the regular and exception medication lists and any drugs covered under the exception patient measure of the general plan. In other words, the RAMQ has changed its position, bringing it in line with current practice in most private group insurance plan.
Though the RAMQ has changed its interpretation of this aspect, it has held its position regarding the definition of eligible dependents, discussed in our July bulletin. According to the RAMQ, private group insurance plans must define dependents as specified in the Act and may not be more generous. This means coverage must end at age 18, except for full-time students, whereas most private plans cover dependent children to age 21.
The RAMQ's definition raises a number of questions that remain unanswered. Discussions are currently under way between the RAMQ and the Canadian Life and Health Insurance Association Inc. (CLHIA) in hopes of arriving at a consensus. Most insurers are not therefore planning to amend their group insurance contracts for the moment.
We will inform you of the results of these discussions as soon as possible.
Please feel free to contact us for additional information.
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