Bill 28 passed – implications for group benefits plans

The National Assembly passed Bill 28 on April 20, 2015. This bill includes a host of budget measures and numerous changes to different laws. Several of the measures announced impact directly or indirectly group benefits plans. The table below presents a summary of expected impacts on plans.

Over the past few months, a public consultation exercise was completed in relation to Bill 28. As part of this exercise, several stakeholders from the insurance sector, including the Regroupement des assureurs de personnes à charte du Québec (RACQ) and the Canadian Life and Health Insurance Association (CLHIA), expressed their views on the directions that the government should take on drug coverage. Normandin Beaudry consultants have also been focused on the elements necessary for ensuring the sustainability of group benefits plans.

The final content of Bill 28 was undoubtedly influenced by the actions taken by the industry to put forward the point of view of private plans. Although the final version of the bill is a step in the right direction from its original version, three key elements are still missing:

• Regarding drug costs, there is still no mechanism available to private plans to reduce the gap with the public plan. The last evaluation completed by private plan insurers indicates that drugs cost 17% more for insureds under private plans than for insureds of the Quebec public plan.
• Along with any other health professionals, including chiropractors, psychologists and dentists, private plan sponsors should be able to choose whether or not to cover the new medical services provided by pharmacists, and to determine the level of reimbursement if these services are covered.
•  Legislative barriers continue to prevent us from adequately guiding members to a pharmacy where the drug is the least expensive or from entering into agreements with a pharmacy chain to obtain lower drug costs. Quebec is the only province in which these barriers continue to exist.

Following the evaluation of the regulations that will be published by June 20, 2015, and the analysis of the impacts for our group benefits clients, we are examining the possibility of supporting a movement aimed at mobilizing plan sponsors to influence the government. The form and the specific objectives of this type of movement would need to be determined. If we want the government’s next actions to protect the interest of plan sponsors to the same extent as those of the public plan, the real payers, plan sponsors and their members, should perhaps get involved to present their point of view.

The government will deliver the regulations concerning the application of the legislation, which will allow us to determine the full impacts on plans. This step will be completed by June 20, 2015 and will also serve to establish fees for the new services provided by pharmacists. Stay tuned for our upcoming communications on this subject.

If you want to learn more about the expected impacts on your plans or required adjustments to your plans, get in touch with your usual contact who will refer you to a Normandin Beaudry group benefits consultant. If you are a Normandin Beaudry group benefits client, your consultant will be contacting you directly in the coming weeks.