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Agreement between pharmacists, insurers and third-party payers on pharmacy services in Quebec
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Agreement between pharmacists, insurers and third-party payers on pharmacy services in Quebec


On January 16, 2020, life and health insurers, represented by the Canadian Life and Health Insurance Association (CLHIA), owner pharmacists, represented by the Quebec Association of Owner Pharmacists (AQPP), and third-party payers concluded an agreement that will have an impact on drug costs management of private drug insurance plans in Quebec.

The agreement will remain in effect from February 1, 2020 to March 31, 2023 and covers a wide range of issues relevant to plan sponsors with participants in Quebec.


  1. Incentives : Insurers and third-party payers recognize the freedom for an insured to choose his pharmacist. Therefore, they agreed not to offer or promote the offer of incentives to the insured to purchase prescription drugs from a particular pharmacist or a particular group of pharmacies. It is relevant to mention that the agreement expressly provides that it does not have the effect of preventing a plan sponsor from offering incentives, being understood however that insurers and third-party payers agree not to promote incentives.
    It may be relevant here to mention that this freedom to choose one’s own pharmacist, deriving from section 2 of the Health Insurance Act, has been repeatedly invoked by the AQPP in recent years, notably in the context of its representations made during the legislative amendment requiring pharmacists to present a detailed invoice to customers. 
  2. Price comparison : Insurers are authorized to develop and provide online comparison tools on their secure sites (and not on public sites) in order to allow promoters and insureds to be better equipped to locate pharmacies where they can get their medication at a lower price.
    Several insurers already make a price comparison tool available to their participants, however the information provided is limited. It is expected that following the new agreement, these insurers will improve their comparison tool in the months that follow. Insurers who offered this service in other provinces will also be able to deploy these tools to participants residing in Quebec. 
  3. Fair and reasonable prices : The agreement recognizes the principle that private payers should pay fair and reasonable prices for dispensing fees and pharmacy services. The agreement provides that the multiplication of fees according to the number of units constitutes an excessive pricing. In addition, a working group will examine what constitutes a specialty drug and what constitutes a fair and reasonable price for this type of medication.
    Although there are few or no savings related to drug insurance costs as a result of this measure, in the long term, plan sponsors can expect to benefit from better governance rules regarding the price of drugs charged by Quebec pharmacists. 
  4. New services : The agreement provides a framework for the expansion of available pharmaceutical services and the terms of their reimbursement by private plans. This reflects the Quebec pharmacists’ desire to diversify their service offer and move away from a remuneration model almost exclusively linked to the distribution of drugs. 
  5. Regarding the right of the insurer or the plan administrator to consult the detailed pharmacist's invoice issued to the client when costs are reimbursed, the agreement does not address it. Probably because this question still remains before the courts following the appeal filed by the AQPP of the judgment that recognized it in the case opposing the AQPP to the Régie de l'assurance maladie du Québec.

Contact your Aon consultant for more information on this and to discuss issues and opportunities within your organization.