Impacts of Bill 28 on Group Insurance Plans in Quebec


In Quebec, the adoption of Bill 28, aimed at returning to a balanced budget, had a direct impact on the reimbursement of prescription drugs for generic substitution plans and on pharmacy services coverage. This communiqué highlights how these changes affect iA Financial Group’s (Industrial Alliance Insurance and Financial Services Inc.) group insurance plans.


Effective October 1, 2015, for plans with a generic substitution clause, brand name drugs reimbursements no longer have to meet the 66% minimum (based on the public plan parameters) of the submitted amount. Consequently, brand name drug reimbursements for Quebec plan members will now be based on the price of the lowest-cost equivalent generic drug, with no minimum threshold. For
iA Financial Group’s plans with a generic substitution clause, these changes will take effect on January 8, 2016, following our system updates.

Furthermore, only deductible and coinsurance amounts paid by the plan member will be considered when calculating the maximum contribution (beyond which the full cost of the drugs is reimbursed by the plan). Plan members will have to cover the difference between the submitted amount for a brand name drug and the eligible amount for the lowest-cost generic equivalent. Once the maximum contribution is reached, full reimbursement will also be based on the lowest-cost generic equivalent.


Here is a message for plan members on this topic, complete with basic examples. We encourage you to forward it to your employees to let them know how their future claims will be impacted. Click here.

If you want to introduce a mandatory generic substitution clause in your contract, please contact your benefits advisor.


Since June 20, 2015, Quebec pharmacists are allowed, under certain circumstances, to offer new professional services to patients. A fee agreement for these services was reached between the Quebec government and the Quebec Association of Pharmacy Owners (AQPP), as shown in the following table.

New services rendered by pharmacists


Renew a physician’s prescription


Prescribe a medication when no diagnosis is required


Prescribe a medication for a minor condition
(where the diagnosis and treatment are known)


Adjust a physician’s prescription


According to Bill 28, these services have to be covered both by the public plan and private plans. Applicable fees for private plans were confirmed by an amendment to Bill 28 (adopted in Bill 20 on November 10, 2015), which states that fees for private plans, except for those claimed for filling or renewing a prescription, may not exceed the pricing established in the agreement for the public plan. This amendment clears up the confusion that prevented private plans from reimbursing pharmaceutical fees since they went into effect on June 20, 2015.

We will be able to properly adjudicate claim requests for pharmaceutical services (at the same coinsurance level as for prescription drugs) as soon as we obtain the final approval on pricing by the AQPP and update our systems.  

Quebec plan members may have already paid for some of these pharmaceutical services since
June 20, 2015. In order to be reimbursed, a claim request with the pharmacy receipt will have to be submitted for those services. Once our systems are ready, it will be possible for plan members with a pay direct or deferred drug card, to electronically submit future claim requests for pharmaceutical services to iA Financial Group at the pharmacy.


The changes explained in this communiqué may impact supplemental health benefit pricing. Any adjustments, if required, will be applied at the next renewal for affected groups.

If you have any questions or concerns regarding this communiqué, please contact your benefits advisor or your Industrial Alliance group account executive.