An expanded interpretation of the Canada Health Act moves nurse practitioner, pharmacist, and midwife services into public coverage, ending their ability to seek private insurer reimbursement effective April 1, 2026.
The federal government has confirmed it is moving forward with the CHA Services Policy. As of this month, nurse practitioners, pharmacists, and midwives can no longer seek reimbursement from private insurers or charge patients out of pocket for "medically necessary" services otherwise covered by the public health system. Those services will instead be covered by provincial and territorial health coverage.
The change is not a legislative amendment. There has been no formal amendment to the Canada Health Act. Instead, the federal government has expanded its interpretation of who is considered a "physician" under Canadian public health insurance to include a broad scope of health care professionals, including nurse practitioners, pharmacists, and midwives, when providing "physician-equivalent services."
The CHA Services Policy was first announced last year by the Federal Minister of Health via a letter to all provincial and territorial ministers of health. At the time, Parliament was prorogued, and it was not clear whether the policy would be pursued. This year, the federal government announced its intention to move forward.
In its 2026-2027 Departmental Plan, Health Canada stated that patient charges for medically necessary services provided by health care professionals providing physician-equivalent services, for example nurse practitioners, will be considered extra-billing and user charges under the Canada Health Act. The plan further states that Health Canada will work with provinces and territories to address challenges in implementing the policy, while supporting compliance.
The Canada Health Act is the federal legislation that dictates the minimum requirements that provincial health plans must meet to receive eligible health care funding through federal transfer payments. Under the Act, public plans must cover "medically necessary" or "medically required" hospital, physician, and surgical-dental services to receive federal funding. If a province or territory's health care system does not comply with the Act, federal transfer payments can be withheld. Once the new interpretation is implemented, patients should not be charged for services that would otherwise be covered by a provincial or territorial health care plan if delivered by a physician. Provinces and territories must now amend their health insurance legislation to align with this new interpretation to avoid the withholding of health care funding they receive through federal transfer payments.
There is a grace period. While the policy takes effect on April 1, 2026, the initial implementation period is expected to be extended for one year to give provinces and territories time to align with the policy without facing compliance measures during the first year of transition, for example to update their fee models where required. This transition period reflects the federal government's commitment to working collaboratively with provinces and territories to ensure Canadians have access to the care they need. During that window, businesses and health care providers are not expected to face enforcement action if private insurers or patients pay for the cost of medically necessary health care services provided by these additional classes of health care providers. However, the federal government could seek to take additional measures should provincial and territorial governments not respect the new interpretation.
For private insurers, the consequences are real. Group benefit plans and supplementary health insurance products that currently reimburse nurse practitioner, pharmacist, or midwife services need to be re-examined. Where those services now fall under the public umbrella as medically necessary and physician-equivalent, the rationale for private coverage, the premiums built around it, and the claims infrastructure supporting it come into question. Health care providers who leverage non-physicians, such as nurse practitioners, for patient care may need to reconsider their fee models going forward, which has downstream effects on insurer provider networks and benefit design.
The Departmental Plan fills in the broader fiscal picture. Health Canada's total planned spending for 2026-27 is $10,978,991,599, with $9,816,898,007 directed to health care systems. Of the total 2026-27 planned spending for health care systems, over 90 percent of the funding supports the Canadian Dental Care Plan, transfers to provinces and territories under the Shared Health Priorities transfer payment program, the National Strategy for Drugs for Rare Diseases, and payments to provinces and territories to provide coverage for specific prescription drugs and related products under section 6 of the Pharmacare Act.
The Canadian Dental Care Plan makes oral health care more affordable for Canadian residents with an adjusted annual family net income of less than $90,000 without access to dental insurance. Health Canada has set a target of at least 50 percent of the eligible target population deemed eligible after applying and at least 85 percent of providers actively participating by March 31, 2027.
Health Canada is also planning spending reductions of $87.8 million in 2026-27, $152.5 million in 2027-28, and $198.2 million in 2028-29 as part of a Comprehensive Expenditure Review. It is anticipated that these spending reductions will involve a decrease of 942 full-time equivalents by 2028-29. Health Canada will achieve these reductions by modernizing and streamlining programs and operations, focusing resources on its core mandate and high-impact activities, adopting new ways of working and shifting toward a more agile, efficient, and integrated regulatory system, and modernizing regulatory and research functions to focus on highest-risk areas and enhance alignment with international best practices.
Stakeholders should continue to monitor the policy and transition period for relevant changes as the federal, provincial, and territorial governments seek to work through the complexity of this transition. Insurers, brokers, and benefits consultants operating in Canada will need to watch the provincial response closely and prepare accordingly.
