Letter to the Ontario Legalization of Cannabis Secretariat Re: Concerns about the potential impact of the future cannabis legalization framework

Date de parution : 07/28/2017
Personne(s)-ressource(s) : Joan Weir

July 28, 2017

Ontario Legalization of Cannabis Secretariat
Ministry of the Attorney General
720 Bay Street, 11th Floor
Toronto, ON
M7A 2S9

Sent by email: cannabis@ontario.ca

To the Secretariat,

On behalf of the Canadian life and health insurance industry, we are writing to raise awareness of the industry’s concerns about the potential impact of the future cannabis legalization framework in Ontario on the existing medical cannabis framework. The Canadian Life and Health Insurance Association is a voluntary association with member companies which account for 99 per cent of Canada’s life and health insurance business. In Ontario, for calendar year 2015, the life and health insurance industry provided more than 9.5 million Ontarians with private health plan coverage and made payments of about $14.1 billion on health services. These plans help ensure Ontarians have access to needed health care.

Coverage of medical cannabis is not a standard benefit offered by drug benefit plans. However, many drug benefit plans have companion healthcare spending accounts that provide coverage for products and services that are eligible under the Canada Revenue Agency’s medical exemption tax credit, and this includes medical cannabis and seeds. In addition, some plan sponsors have elected to add coverage for medical cannabis to their drug benefit plans.

At the same time, the numbers of medical cannabis permit holders has continued to escalate. In June 2014 there were fewer than 8,000 permit holders; 2 years later, there were almost 200,000 and this growth trend is expected to continue.

There are many decisions that the Government of Ontario must make as it considers its approach to legalization of recreational cannabis. By way of this letter, the CLHIA hopes to bring to your attention matters that may have an impact on whether individuals choose to obtain cannabis through the medical channel, as opposed to the recreational channel. Of particular interest will be the decisions made around price, taxation and distribution. Our request of the Government of Ontario is that, as you make decisions with respect to these matters, you consider the potential impact any price or taxation differential between medical and recreational cannabis may have on ‘pushing’ individuals into the medical system. For instance, if recreational cannabis were priced and/or taxed at a higher rate than medical cannabis, this could cause individuals to pursue a medical cannabis permit. The same analysis would apply to distribution of recreational cannabis where, today, distribution of medical cannabis is strictly controlled.


Joan Weir
Director, Health and Disability Policy