INVESTIGATION · HEALTH POLICY · PRIVATIZATION
This investigation draws on the text of Alberta’s Health Statutes Amendment Act, 2025 (No. 2) (Bill 11); the Alberta and federal Lobbyist Registries; the Canadian Life and Health Insurance Association’s January 2026 pre-budget submission to the Government of Alberta; the Canadian Centre for Policy Alternatives / Parkland Institute report The end of Canadian medicare? (February 2026); Ontario’s Financial Accountability Office and Auditor General reports on the Ontario Autism Program; and corporate filings retrieved from public registries.
Where this article describes a structural pattern or draws an inference from public facts, that analysis is identified as analysis. Where it states a fact, that fact is sourced. Quotations are reproduced from the on-the-record original.
This article focuses on structural and policy questions about the privatization of publicly funded care. It does not allege that the Canadian Life and Health Insurance Association, Manulife Financial Corporation, Sun Life Financial Inc., Canada Life Assurance Company, Accerta Services Inc., AccertaClaim Servicorp Inc., the Ontario Dental Association, Serefin, or any other organization named has acted improperly, breached any law, misused public funds, or failed to deliver on contractual obligations. Each entity acted in its corporate or institutional capacity in the events described, on the public record.
Begin with the receipt. On December 11, 2025, Alberta’s Health Statutes Amendment Act, 2025 (No. 2) — known as Bill 11 — received royal assent, and came into force shortly after. The bill changed how Alberta’s public health insurance plan interacts with private insurance. Two changes matter most. First, physicians can now work simultaneously in the public system and a private-pay market, billing patients out of pocket while continuing to bill the province. Second, when an Albertan is covered by a private health plan, the private insurer can be required to pay first for services that until December 2025 were paid for by the province.
The first change has been called two-tier health care. The second is the more consequential. It is the formal end, in one province, of Canada’s “single-payer” architecture for medically necessary care. And it was developed, in the words of the insurance industry’s own pre-budget submission to the province, with that industry as a “key partner.”
Our industry appreciates that the Alberta government considers life and health insurers as a key partner in the healthcare system, as demonstrated through the introduction of Bill 11.
— Canadian Life and Health Insurance Association · Pre-budget submission · January 2026
That sentence — published by the industry, on the public record, three weeks after Bill 11 took effect — is the single clearest statement of what this article is about. The reform was co-designed with the firms whose balance sheets it grows. And the model being scaled in Alberta is not new. Ontario built a prototype seven years ago. It is called the Ontario Autism Program.
Part I — The mechanism
Privatization in publicly funded systems rarely arrives as an announcement. It arrives as an administrative procurement, written in the language of “modernization,” “intake reform,” or “interoperability.” Beneath that vocabulary sits a single mechanism: the third-party administrator, or TPA.
The TPA is the company contracted by government to do the paperwork. It decides which families are eligible, which services are covered, which receipts will be reimbursed. Public dollars never stop being public — but every dollar passes through private hands on the way to the family or the clinician who actually delivers the care. The model originated in dental and group benefits, where the TPAs are subsidiaries of, or partners with, the major life and health insurance companies. It is now spreading across publicly funded care.
Two structural facts follow from the TPA model and apply wherever it is used. First, the administrator is paid an administration fee — a permanent overhead cost the public previously did not pay. Second, when the administrator is owned by, or commercially affiliated with, the upstream firms (insurers, providers, suppliers) whose business depends on the same flow of public funds, the conflicts of interest are not exceptions. They are structural.
Part II — The prototype
In December 2020, the Government of Ontario issued a Call for Applications for an “Independent Intake Organization” — the IIO — to administer the Ontario Autism Program. The IIO was to handle eligibility intake, family registration, plan administration, and the disbursement of “childhood budgets” to tens of thousands of children awaiting services. The Call closed on February 26, 2021. On December 3, 2021, the Ontario government announced that the successful partnership would be led by Accerta Services Inc., joined by Autism Ontario, McMaster University (CHEPA and the Offord Centre for Child Studies), and Serefin.
Accerta describes its operations as rooted in Ontario’s social services dental benefits program, which it has administered in various corporate forms since 1959. Its claims administration today is conducted using the Ontario Dental Association’s licensed fee guide. AccertaClaim Servicorp Inc., the corporate entity under which Accerta operates, declares in its federal lobbyist filings that it is not a subsidiary of any parent company and is not controlled or directed by another organization with an interest in its activities. Current corporate ownership is as Accerta itself describes it on its sworn lobbyist filings.
Two facts about the partnership and the funding flow deserve attention. First, ETWO’s analysis of MCCSS public spending data indicates that approximately $57.9 million in 2023–24 was directed to AccessOAP — the largest single non-therapy spending item in the Ontario Autism Program for that year. Second, Accerta Services Inc. was federally incorporated on October 14, 2021 — approximately seven weeks before the IIO partnership was publicly announced on December 3, 2021, and roughly eight months after the Call for Applications closed in February 2021. The bid was therefore submitted under a different corporate identity, with Accerta Services Inc. created subsequently as the operating entity.
None of the foregoing is, on its face, problematic. Sole-source procurements occur. Newly-incorporated subsidiaries and operating entities are routinely created for major government contracts. What this is, is a structure. A long-standing private administrator with deep operational ties to a publicly-funded benefits ecosystem now sits at the centre of a publicly funded program for a vulnerable, growing population. The structure of incentives is what readers should consider.
The structure is what readers should consider — not the people, the structure. Public dollars move from a ministry, through a privately-operated administrator, into a program whose users have no choice in administrator and no public reporting on cost-per-claim.
Ontario’s Auditor General and Financial Accountability Office have, in successive reports, documented the practical consequences. The OAP waitlist has grown rather than shrunk since the 2018 redesign. Posted hourly rates for the core clinical service — Applied Behaviour Analysis (ABA) — have risen materially over the same period, although precise province-wide rate data is not published by the ministry and must be reconstructed from clinic-level disclosures.
Part III — The fee escalation
The mechanism is empirically well-documented in healthcare economics, particularly from the United States, where most states mandated insurance coverage of autism services between 2007 and 2017. The pattern, repeatedly replicated in peer-reviewed analyses, is straightforward: when third-party payment is introduced into a service market, list prices rise faster than wages and faster than general health inflation. This is true across orthodontics, optometry, addiction services, hearing aids, and behavioural therapy. It is the structural counterpart of the well-known “education–tuition” inflation effect after federal student-loan expansion.
Two related mechanisms drive it. First, a third-party payer absorbs price-signal feedback that families would otherwise enforce. When the family pays the bill, posted prices reflect what families can bear. When the administrator pays, posted prices reflect what the administrator will reimburse. Second, the administrator’s own overhead — the fee it takes for processing — is itself layered onto the cost.
Figure · Administrative overhead, public vs. private
Public single-payer plans run on roughly one-fifth of private overhead.
Administrative cost as % of total program cost. Comparative figures; methodologies vary modestly across jurisdictions.
In the autism context, this dynamic is amplified by a second factor: clinical hour requirements. Evidence-informed ABA programs typically prescribe 20–40 hours of intervention per week for young children. At even a moderate hourly inflation — say, $80/hr to $130/hr over five years — the per-child annual cost of the same clinical intensity rises by tens of thousands of dollars. The province’s published “childhood budget” cap does not rise in step. The result is a quiet contraction in the actual hours of intervention each public dollar buys.
Part IV — The scaling
The structure that Ontario applied to one program — a vulnerable, growing program with a waitlist that already favoured private payment — Alberta has now applied, in principle, to all physician services and all hospital services not specifically retained by the public plan. This is the substance of Bill 11. The Canadian Centre for Policy Alternatives and Parkland Institute, in a February 2026 joint report, concluded that the bill likely violates the universality and accessibility principles of the federal Canada Health Act.
The legislative history is documented in the Alberta Hansard. The drafting history is, in part, documented in the Alberta Lobbyist Registry. By the start of 2026, according to that registry, the Canadian Life and Health Insurance Association had at least eighteen registered lobbyists active in the province. Counting the major member companies’ own in-house lobbyists, the total registered insurance-industry footprint in Alberta on Bill 11–related subjects exceeded twenty-five.
Figure · Bill 11 working group · Alberta Lobbyist Registry · Q1 2026
Twenty-five insurance lobbyists. No patient organizations. No medical association.
Sources: Alberta Lobbyist Registry (Q1 2026, as compiled by The Breach, April 2026); CLHIA membership directory; CLHIA pre-budget submission to Alberta (Jan. 2026). Counts capture lobbyists registered to CLHIA, Manulife, Sun Life, and Canada Life on Alberta health-policy subjects.
The CLHIA’s own January 2026 pre-budget submission states, in its words, that the association sat on a “working group of industry representatives” within the Alberta government to oversee Bill 11’s drug insurance regulations. The submission thanked the province for letting the industry weigh in on “the technical implementation of certain aspects of the changes” contained in the bill.
The same period saw no equivalent working group of practising physicians, of patient organizations, or of the Alberta Medical Association on the technical implementation of these particular sections of the bill. Submissions from physician groups and from the medical association were filed through the ordinary public consultation channels. The industry consultation was structural; the public consultation was procedural.
| Insurance interest | Alberta footprint, Q1 2026 | Reg. lobbyists |
|---|---|---|
| CLHIA — umbrella body for 99% of Canadian L&H insurers | Sits on Bill 11 drug-insurance “working group of industry representatives,” per its own pre-budget submission | 18 |
| Sun Life Financial | Lobbied public office holders on “health innovation”; updated Alberta registration in fall 2025 | 4 |
| Manulife | Lobbied Alberta Health on making care “interoperable” with the insurer’s business; updated Alberta registration fall 2025 | 3 |
| Canada Life | Named alongside Manulife and Sun Life as a CLHIA-coordinated voice on Bill 11 implementation | — |
| Other CLHIA members | Green Shield Canada, Blue Cross (Medavie / Canassurance), Desjardins — represented through CLHIA | — |
Sources: Alberta Lobbyist Registry (Q1 2026), as compiled by The Breach (April 2026); CLHIA membership directory; CLHIA pre-budget submission to Alberta (Jan. 2026).
Together, Manulife, Canada Life, and Sun Life hold an estimated 63 per cent of Canada’s $64 billion life and health insurance market — roughly $40 billion in premiums, fees, and asset management revenue. Each is publicly traded. Each has reported in successive annual reports that the strategic growth of Canadian “group benefits” — including expansion into services that have historically been publicly funded — is a priority. In its 2024 annual report, Sun Life’s chief executive described Canada as “a growth engine” for the company in the context of the company’s growing role “in addressing the healthcare gap.”
“The healthcare gap,” in this usage, denotes the part of Canadian healthcare not currently financed by private insurers. Bill 11 narrows that gap by statute.
Part V — Where the money goes
Treat Bill 11 and AccessOAP as two instances of the same instrument and the financial architecture comes into focus. Public health and social-services budgets are large, slow-moving, and politically protected. They are difficult for private capital to access directly. But they are straightforward to access indirectly, by becoming the administrator, the insurer, or the contractor through which public funds reach the public.
The Ontario Autism Program redesign of 2018 did not reduce ministry expenditure on autism services. It restructured how that expenditure flowed. Bill 11 in Alberta does not reduce the province’s $24 billion health budget — it restructures the path along which $24 billion travels. In both cases, the change is in routing, not totals. And in both cases, the routing places a privately operated administrator or insurer at a position where it captures fees on each transit, builds market share over time, and lobbies — successfully — to expand the share of services it administers.
A new path has opened up in this space. The crisis in health care is an opportunity for us to do better for Canadians, to do better for patients.
— Stephen Frank, President and CEO, CLHIA · Industry webinar with Empire Life, February 2023
Mr. Frank’s statement is an honest description of an industry strategy. The “new path” is the share of medically necessary services historically financed by provincial health plans. The “crisis” is the underfunding of those plans. The “opportunity” is the structural one: when a public system is starved enough that families with means turn to private payment, the firms that own the private payment market grow.
What is unusual about the present moment is that the largest Canadian insurers — Manulife, Canada Life, Sun Life — together with the umbrella body that represents them, are not denying this. They are publishing it. The CLHIA’s pre-budget submission, the Sun Life CEO’s annual letter, the Manulife “interoperability” filings: each is on the public record. The strategic objective is open. What this article describes is the policy infrastructure being built to deliver it.
Part VI — Why this is a national matter
The Canada Health Act sets five conditions on provincial health insurance: public administration, comprehensiveness, universality, portability, accessibility. Provinces in violation can have federal Canada Health Transfer dollars withheld. Alberta’s 2025–26 health budget includes $6.6 billion in such transfers — about 28 per cent of the province’s $24 billion health spend.
The CCPA / Parkland report concludes that Bill 11 likely violates the universality and accessibility principles. As of this writing, the federal response has been a statement. No transfer has been withheld. No formal review has been opened. And other premiers, beginning with Saskatchewan’s Scott Moe, have publicly suggested they may follow Alberta’s lead.
Ontario is the largest provincial health-care market in Canada. Should Ontario adopt Alberta’s framework — and the Ontario Autism Program structure suggests the Ontario government has been comfortable with the underlying TPA model for at least seven years — the Canada Health Act becomes a federal dam against a national dynamic that operates province by province. The political pressure for the federal government to enforce is then proportional to the political cost of doing so.
The dam holds, or it does not. There is no in-between in a market that, by industry’s own statement, regards the gap in public funding as a growth engine.
The privatization architecture described above advances when public attention is absent. It retreats when attention is present. Three actions, in declining order of leverage:
1. The federal government can enforce the Canada Health Act. The Minister of Health has explicit statutory authority to withhold Canada Health Transfer payments from provinces in violation. Withholding is the dam. Letters from constituents to the Minister and to one’s own Member of Parliament are how the dam gets resourced.
2. Provincial Auditors General can audit private administrators. When a TPA holds a sole-sourced contract for a public program with vulnerable users, an Auditor General can — and in Ontario, has — request value-for-money review. Such reviews depend on legislator demand. Constituents can request that demand from their MPP or MLA.
3. Lobbyist registries can be read. The Alberta Lobbyist Registry, the federal Office of the Commissioner of Lobbying, and the Ontario Integrity Commissioner all publish their data publicly. The patterns described in this article were assembled from those registries by a small number of researchers and journalists. Anyone can read them. Many more should.
Methodology & sources
Every numerical claim in this article is sourced to a public document — government Hansard, ministerial press release, lobbyist registry filing, peer-reviewed paper, or organizational pre-budget submission. Where a number was reconstructed from secondary reporting (for example, the count of CLHIA registered lobbyists in Alberta), the secondary source is named, and the primary registry is identified for independent verification.
Where this article uses words like “structural,” “pattern,” “consistent with,” or “architecture,” it is engaging in analysis of public facts, not making allegations about specific individuals. That distinction matters and is observed throughout.
Every claim sourced. No allegation of wrongdoing made or implied.
Verified Facts
87,692 — children are registered in the Ontario Autism Program
23.1% — Only 20,293 children have active funding agreements () — less than one in four
WHO recommends accessible, community-based early interventions for children with autism — timely evidence-based psychosocial interventions improve communication and social engagement