The Latest
Submission to AMF on Students Group Insurance
Published on 17/10/2022
Group Insurance > Employee benefit plansOn October 17, the CLHIA responded to the AMF’s consultation on group insurance offered to student associations in Quebec. The CLHIA commented that students group insurance plans, as designed today with automatic enrollment with an opt-out option, meet a need expressed by student associations and their members, and ensure that all students continue to benefit from coverage available at an affordable cost. Therefore, the CLHIA recommended the AMF should maintain the current regulatory framework allowing for such a plan design. We indicated that not doing so will disadvantage students, including those with low incomes who would not otherwise be able to obtain insurance. Our response provided recommendations for a continued dialogue to optimize communications and coordination by all stakeholders involved in the design and administration of students group insurance plans. The CLHIA will continue to keep the industry updated when the AMF issues its report and makes recommendations to Quebec’s Finance Minister.
Submission to BC regarding implementation of the Financial Institutions Amendment Act, 2019 (Bill 37): Consultation Regarding Restricted Insurance Licenses
Published on 03/10/2022
Distribution > Market conductOn October 3, the CLHIA responded to the Government of British Columbia’s consultation regarding restricted insurance licences. The CLHIA commended the government’s efforts to promote consistency, simplicity, and harmonization amongst the provinces that have, or will soon have restricted insurance agent licences.
The CLHIA commented on the prospective classes of applicants and insurance as well as on repealing exemptions in BC’s insurance licensing exemptions regulation. Our response also provided detailed comments against limits to commissions, value limits on insurance sold by restricted licence holders, and deferred sales charges models. Finally, the CLHIA addressed transitional considerations, businesses outside of British Columbia being eligible for restricted licences, and strongly discouraged the government from using the term “post-claim underwriting.”
The CLHIA will continue to keep the industry updated when British Columbia’s next steps for this initiative become clearer.
Submission on Modernizing Corporate Governance for Federally Regulated Financial Institutions
Published on 23/09/2022
Government Relations > Government MonitoringOn September 23, the CLHIA provided its comments to the federal government’s consultation on modernizing the governance framework for federally regulated financial institutions (FRFIs). The consultation is considering adapting and applying the Canada Business Corporations Act diversity disclosure requirements to FRFIs. Our submission notes the importance of balancing qualifications with efforts to encourage diversity on boards of directors. The consultation also considers expanding electronic communications, such as electronic distribution of materials and virtual stakeholder meetings. The CLHIA submission expressed support for these measures.
Canadians received a record $113 billion in life and health insurance benefits, 2021 data shows
Published on 15/09/2022
Consumers > CLHIA Consumer PublicationsIn mid-September, the CLHIA released the 2022 edition of Canadian Life and Health Insurance Facts. This year’s edition shows the important role insurers are playing in the recovery, helping employers and their employees get back on their feet with workplace benefits that help attract and retain talent and contribute to the health of millions.
Among the key facts are that in 2021, Canada’s life and health insurers:
Canadian Life and Health Insurance Facts is published annually by CLHIA relying on industry and publicly available data. Download it and related resources at https://www.clhia.ca/facts.
CLHIA submission on the development of a model Canadian digital trade agreement
Published on 13/09/2022
Trade & Commerce > PrivacyThe federal government has started work to develop a model Canadian digital trade agreement. On July 15, Global Affairs Canada launched a consultation inviting views on the potential scope and content of the agreement. On September 13, the CLHIA shared its views highlighting two key issues for consideration: that the agreement should prohibit data localization requirements; and that it should minimize the differences in digital regulation across jurisdictions.
Submission to the Employment and Social Development Canada - Premium Reduction Program
Published on 29/07/2022
Disability Group Insurance > Long term disability Employee benefit plansOn July 29, the CLHIA responded to an Employment and Social Development Canada (ESDC) consultation on revamping the current Premium Reduction Program. CLHIA’s recommendations intend to make the program flexible and simple, modernize and digitize processes, and develop initiatives to create awareness of the program among employers. For background, employers who offer a short-term disability program comparable to or better than Employment Insurance sickness benefits, pay reduced EI premiums. As the EI sickness program will be changing from 15 weeks to 26 weeks sometime later this year, it is important that the PRP be revamped in conjunction with this change.
Specifically, the CLHIA asked that all disability income-replacement programs (including sick days and LTD) be “counted” towards employer eligibility for the program. The many steps an employer takes to become recognized as eligible need to be reduced or eliminated. A simple employer attestation be put in place instead of the submission and review of insurance contracts by Service Canada. And that business process improvements to automate eligibility review and confirmation be made to free up resources for both employers and Service Canada.
ESDC has committed to continue to work with the CLHIA, employers and the insurance industry as they finalize the changes to the Premium Reduction Program.
Submission to Environment & Climate Change Canada on the National Adaptation Strategy Consultation
Published on 15/07/2022
Risk Management Sustainability and Climate Change > Operational Risk Government MonitoringOn July 15, the CLHIA provided its comments to the federal government on its National Adaptation Strategy. The submission focused on the infrastructure, health and wellbeing, and economy streams of the strategy. Specifically, the CLHIA recommended the federal government:
The CLHIA also recommended the development of data sharing mechanisms with the private sector concerning the impacts of climate change on public health.
Submission to the International Sustainability Standards Board on its proposed disclosure standards
Published on 29/07/2022
Sustainability and Climate Change Financial Reporting International > Government Monitoring International Financial Reporting Standards International MonitoringOn July 29, the CLHIA provided its comments to the International Sustainability Standards Board (ISSB) in response to its consultations on disclosure of sustainability-related financial information (IFRS S1) and climate-related disclosures (IFRS S2). The high-level letter reiterated key positions taken in the Global Federation of Insurance Associations (GFIA) submission, which the CLHIA contributed to, including:
Submission to the Securities and Exchange Commission on the Enhancement and Standardization of Climate-Related Disclosures
Published on 28/06/2022
Risk Management Sustainability and Climate Change International > Operational Risk Government Monitoring International MonitoringOn June 17, the CLHIA provided its comments to the United States Securities and Exchange Commission (SEC) in response to its notice of proposed rulemaking (NPRM) on the enhancement and standardization of climate-related disclosures for investors. CLHIA members support the SEC’s efforts to encourage disclosure of consistent and comparable climate-related information. The CLHIA members also agree with its current proposal not to amend Form 40-F for Canadian issuers under the multijurisdictional disclosure system (MJDS). This would recognize the significant work underway in Canada to develop and implement climate-related disclosures for Canadian issuers.
British Columbia 2023 Pre-Budget Consultation
Published on 24/06/2022
Group Insurance Pensions and Retirement > Employee benefit plans Employer pension plansOn June 18, the CLHIA provided recommendations to the British Columbia Legislature’s Select Standing Committee on Finance and Government Services in advance of the province’s 2023 budget. The industry’s recommendations focused on four key areas:
1. Supporting workplace benefits plans which provide millions of British Columbians with comprehensive access to prescription medicines, dental care and mental health services;
2. Pension innovation to increase retirement savings and decumulation options for British Columbians;
3. Increasing private sector investment in sustainable and resiliency-building infrastructure to support the transition to a low-carbon economy and support the health and well-being of British Columbians; and
4. Supporting an innovative business environment by reducing the tax on health and disability insurance premiums.
CLHIA welcomes introduction of federal privacy legislation
Published on 20/06/2022
Trade & Commerce > PrivacyBernard Lord elected CLHIA Chair
Published on 09/06/2022
CLHIA Governance > Board of DirectorsThe members of the Canadian Life and Health Insurance Association have elected Bernard Lord, Chief Executive Officer of Medavie as Chair of the Board of Directors.
Mr. Lord became CEO of Medavie in September 2016 to provide strategic leadership and further the company’s mission to improve the wellbeing of Canadians. Prior to this, he served eight years on its board of directors. Mr. Lord was Premier of New Brunswick from 1999 to 2006.
He is currently the Chair of the International Federation of Health Plans, and the incoming President of the Canadian Association of Blue Cross Plans. He is a Queen’s Counsel and a member of the New Brunswick Law Society and Canadian Bar Association.
Submission to Alberta College of Pharmacy on draft Practice Standards for Virtual Care
Published on 24/05/2022
Group Insurance Prescription Drug Costs > Coordination of benefits Employee benefit plans Drug pricingThe Alberta College of Pharmacy has developed draft standards of practice for when virtual care can be delivered. Of particular note, section 5 of the draft states that “A determination by an employer, third-party payer or an insurer that compels or provides incentive for virtual care is not a unique circumstance for the purpose of section 3.” In our May 24 submission, the CLHIA recommended the removal of section 5 and that this restriction not be imposed on the provision of virtual care. If left to stand, it would effectively eliminate the provision of virtual care where any incentive might be involved. Incentives are not defined but could be reasonably assumed to include a reduced dispensing fee, the addition of extra services such as those provided by patient support programs, or any other “incentives” offered through preferred provider networks. While incentives are offered by a variety of community pharmacies, this practice standard seems to target virtual pharmacies and to be offside with the current preferences of Albertans to have options for how they obtain pharmacy services.
Recordings and presentations are now available for the May 4-5 Compliance and Consumer Complaints Virtual Annual Conference
Published on 10/05/2022
Compliance Consumers > Culture of compliance Fair treatment of customers (FTC) Compliance trends and developments Complaint HandlingExposés et enregistrements de la réunion de printemps de la Section juridique (Québec) de l’ACCAP maintenant affichés
Published on 27/04/2022
Insurance > Federal Legislation Provincial & Territorial LegislationSubmission on Expanding the scope of the VPLAs to enable more Canadians to access retirement income security
Published on 03/05/2022
Pensions and Retirement Taxation > Retirement Income System Reviews Wealth & Retirement Federal TaxationOn May 3, the CLHIA made a submission to the federal Department of Finance calling a broader scope for Variable Payment Life Annuities (VPLAs) that were brought into the Income Tax Act & Regulations (ITA) effective January 1, 2020. The submission argues that a standalone VPLA that can pool funds and longevity risks across members of smaller DC plans, RRSPs, RRIFs, etc., could provide an innovative decumulation solution that would benefit the over 500,000 Canadians retiring each year.
Saskatchewan Public Engagement on Virtual Care
Published on 30/04/2022
Group Insurance > Employee benefit plansOn April 30, the CLHIA wrote to the government of Saskatchewan to support the continued expansion of virtual care across the province with all health care practitioners, where appropriate. The government should assist disadvantaged and rural populations to access virtual care. The CLHIA submission also shared key insights that the private payer industry has gained through experience during the pandemic.
Virtual care is an important issue for the insurance industry as we provide access to this type of care through employer sponsored benefit plans. Canadians have access to virtual health care providers including doctors, nurse practitioners, and nurses, enabling them to discuss symptoms, obtain prescriptions, and get referrals to other providers.
Statement on the implementation of reforms to Patented Medicine Prices Review Board regulations
Published on 14/04/2022
Prescription Drug Costs > Drug pricingIn mid-April, Health Canada announced that changes to patent medicines pricing regulations, already postponed several times, would come into force on July 1, 2022. The changes will allow the Patented Medicine Prices Review Board to use a new list of comparator countries when evaluating drug prices. The CLHIA and the industry have strongly supported this measure that will remove jurisdictions considered high price outliers globally.
The government opted not to move forward with other measures related to the new price regulatory factors, and requirements to file information net of all price adjustments. The CLHIA issued a statement saying the announcement “represents good news for all Canadians who are currently paying some of the highest drug prices in the world.”
(Update) Recordings and presentations are available for the April 6 Legal Section Mid-term Meeting virtual event
Published on 05/04/2022
Insurance > Federal Legislation Provincial & Territorial LegislationThe CLHIA Legal Section’s mid-term meeting was held virtually again this year and was well attended by 125 attendees and speakers. The program featured a presentation from FSRA on its priorities for the life and health industry. The agenda also included presentations on federal and provincial regulatory matters, recent insurance and pension cases, and a panel discussion among government relations experts on industry regulation in Canada. A professionalism session focusing on implicit bias was very well received. The Legal Section’s Annual Meeting will be held in-person in The Blue Mountains, Ontario at the Westin Trillium House from Wednesday, September 21 to Friday, September 23.
Advisory: What you need to know about mandatory destination-provided travel health insurance
Published on 01/04/2022
Group Insurance > Travel insuranceNew Brunswick 2022 Pre-Budget Consultation
Published on 28/02/2022
Group Insurance Pensions and Retirement Prescription Drug Costs Taxation > Employee benefit plans Annuities Employer pension plans Drug pricing Generic drug pricing Provincial & territorial drug program information Policyholder TaxOn February 28, the CLHIA provided its comments to New Brunswick in advance of its 2022 budget. The CLHIA recommended the government:
2022 Federal Pre-Budget Submission
Published on 25/02/2022
Group Insurance Pensions and Retirement Prescription Drug Costs Taxation > Employee benefit plans Annuities Employer pension plans Drug pricing Generic drug pricing Provincial & territorial drug program information Provincial and Territorial Taxation Policyholder TaxOn February 25, the CLHIA provided its comments to the Department of Finance in advance of the 2022 federal budget. Key recommendations include supporting workplace benefits plans (including a discussion of Employment Insurance reforms and their impacts), enhancing privacy protections, making retirement income more secure, releasing a full set of tax legislative changes to address IFRS 17, and increasing sustainable investing opportunities - including by bringing forward regulations to encourage private investment in infrastructure.
Submission to the CADTH on Building Toward a Potential pan-Canadian Formulary
Published on 25/02/2022
Prescription Drug Costs > Drug pricing Provincial & territorial drug program informationAs part of their work to recommend a national minimum drug formulary for the federal government, the Canadian Agency for Drugs and Technologies in Health (CADTH) has engaged an advisory panel to review and propose processes for creating a list of drugs and related products, as well as best practices for managing a formulary.
During the consultation period, which ended February 25, CADTH engaged with the insurance industry to understand our unique environment with respect to formulary management. Insurers recommended the formulary working group consider the views of employer-sponsored plans in the development of a national formulary and to draw on the expertise of insurers on it. It was emphasized that private plans cover the costs of a large number of prescription drugs, and that their contributions to workplace productivity and disability management need to be considered in the development of any formulary.
CADTH will prepare and submit their report with recommendations for consideration by the Canadian Drug Agency later in 2022.
Submission on the New Brunswick Climate Change Action Plan
Published on 24/02/2022
Sustainability and Climate Change > Government MonitoringOn February 24, the CLHIA provided its comments to New Brunswick on its proposed climate change action plan. The submission focused on the industry’s role as a source of stable capital for infrastructure projects that both mitigate GHG emissions and adapt to the impacts of climate change. It also addressed economic opportunities from transitioning to a resilient, lower carbon economy.
Newfoundland and Labrador 2022 Pre-Budget Consultation
Published on 17/02/2022
Group Insurance Pensions and Retirement Prescription Drug Costs Taxation > Employee benefit plans Annuities Employer pension plans Drug pricing Generic drug pricing Provincial & territorial drug program information Provincial and Territorial Taxation Policyholder TaxOn February 17, the CLHIA provided its comments to Newfoundland and Labrador in advance of its 2022 budget. The CLHIA recommended the government:
Submission to the Office of the Commissioner of Lobbying of Canada on the Lobbyists’ Code of Conduct
Published on 17/02/2022
Government Relations > Lobbyist RegistrationOn February 17, the CLHIA submitted its comments on the proposed changes by the Office of the Commissioner of Lobbying of Canada (OCL) to the Lobbyists’ Code of Conduct. In the submission, the industry raised four key issues with the proposed changes, including:
The comments in the CLHIA submission are consistent with those in the joint submission from the Government Relations Institute of Canada and the Public Affairs Association of Canada.
Submission to the Canadian Securities Administrators on Climate-Related Matters
Published on 16/02/2022
Sustainability and Climate Change > Government MonitoringOn February 16, the CLHIA responded to the Canadian Securities Administrators’ consultation on proposed National Instrument 51-107—Disclosure of Climate-related Matters. Canadian life and health insurers support the development of disclosure standards for climate-related risks and opportunities that are aligned with global disclosure standards. Given that standards are coalescing around the Task Force for Climate-related Financial Disclosure’s (TCFD) framework, the industry is pleased that the CSA is taking a similar approach. The industry supports mandatory disclosure of Scope 1 and 2 emissions with Scope 3 emissions on a comply-or-explain basis. At this time we support the deferral of scenario analysis as a reporting requirement until the Office of the Superintendent of Financial Institutions has developed standardized scenario analysis exercises. The submission is also available on the Ontario Securities Commission’s website.
Life and health insurers to use advanced artificial intelligence to reduce benefits fraud
Published on 14/02/2022
Compliance Group Insurance > Fraud risk management Employee benefit plansFor several years data pooling has been successfully used in P&C insurance and banking with positive outcomes in detecting fraud. On February 14, the CLHIA announced an initiative to enhance the detection and investigation of benefits fraud using data pooling and advanced artificial intelligence.
Led by the CLHIA and its technology partner Shift Technology, the project uses advanced AI to analyze anonymized claim records from group health insurers. The program will identify patterns across millions of records to enhance the effectiveness of benefits fraud investigations across the industry. This will complement the work insurers are doing to identify and investigate fraud across their own book of business.
The CLHIA intends for this project to be rolled out and further expanded over the next three years.
Statement on CCIR and CISRO announcement on deferred sales charges
Published on 10/02/2022
Distribution > Market conductOntario 2022 Pre-Budget Consultation
Published on 10/02/2022
Pensions and Retirement > Employer pension plansOn February 11, the CLHIA provided its comments to the government of Ontario in advance of its 2022 budget. Key recommendations focused on protecting workplace health benefits, pension innovation (including automatic enrolment and contribution escalation), sustainable investing opportunities and reducing and eventually eliminating the tax on life and health insurance premiums.
Nova Scotia 2022 Pre-Budget Consultation
Published on 03/02/2022
Group Insurance Pensions and Retirement Prescription Drug Costs Taxation > Employee benefit plans Annuities Employer pension plans Drug pricing Generic drug pricing Provincial & territorial drug program information Provincial and Territorial Taxation Policyholder TaxOn February 4, the CLHIA provided its recommendations to Nova Scotia in advance of its 2022 budget. The CLHIA recommended the government:
Manitoba 2022 Pre-Budget Consultation
Published on 31/01/2022
Group Insurance Pensions and Retirement Prescription Drug Costs Taxation > Employee benefit plans Annuities Employer pension plans Drug pricing Generic drug pricing Provincial & territorial drug program information Provincial and Territorial Taxation Policyholder TaxSubmission on the pending proposal of the Federation of Associations of Counselling Therapists - Manitoba to become a regulated profession
Published on 31/01/2022
Government Relations Health Care Policy > Mental healthPrince Edward Island 2022 Pre-Budget Consultation
Published on 24/01/2022
Group Insurance Pensions and Retirement Prescription Drug Costs Taxation > Employee benefit plans Annuities Employer pension plans Drug pricing Generic drug pricing Provincial & territorial drug program information Provincial and Territorial Taxation Policyholder TaxOn January 24, the CLHIA provided its comments to PEI on key issues in advance of the 2022 budget. The CLHIA recommended the government:
Alberta 2022 Pre-Budget Consultation
Published on 21/01/2022
Government Relations Pensions and Retirement Prescription Drug Costs Taxation > Annuities Employer pension plans Drug pricing Generic drug pricing Provincial & territorial drug program information Provincial and Territorial Taxation Policyholder TaxOn January 21, the CLHIA provided comments to Alberta on key issues in advance of the 2022 budget. The CLHIA recommended the government:
Advisory: How does the federal travel advisory affect your travel insurance?
Published on 20/01/2022
Group Insurance > Travel insuranceSubmission to the Net-Zero Advisory Body on the Government of Canada’s 2030 emissions reduction plan
Published on 22/12/2021
Sustainability and Climate Change > Government MonitoringThe CLHIA submission to the Net-Zero Advisory Body (NZAB) outlined why the life and health insurance industry values long-term, sustainable infrastructure projects as investments. The NZAB is a permanent advisory group to the federal Minister of Environment and Climate Change created in 2021. Remarking on the advisory body’s lens of “finance and capital mobilization,” our submission noted that life and health insurance industry’s capacity to invest is not matched by available investment opportunities, particularly for infrastructure projects that reduce emissions and promotes resilience.
Submission to FSRA on its Consultation on an Innovation Framework
Published on 29/11/2021
Compliance Distribution > Advisor regulatory requirements Market conductIn late October, the Financial Services Regulatory Authority of Ontario (FSRA) launched a consultation on an innovation framework for a more innovative financial services sector in Ontario. It sought views from the industry on guiding principles to provide “test and learn” environments to encourage the development of new technologies. While the focus of the regulator at this point is on the auto insurance sector, the framework will also be used to support innovation in all sectors. In the industry’s response, the CLHIA stresses the importance of ensuring there is a level playing field between new entrants and existing regulated entities. It is important that new entrants are held to the same regulatory standards. The CLHIA also stressed the importance of ensuring any regulatory framework does not slow down innovation. The industry’s response to specific questions in the consultation can be found here.
Session recordings and select presentations for CLHIA's 2021 Wealth and Retirement Annual Conference are now available
Published on 18/11/2021
Pensions and Retirement > Wealth & RetirementThe CLHIA's virtual Wealth and Retirement Conference was a success. The program which ran on November 17 and 18 featured updates and panel discussions on the economy, product and business trends, and regulatory issues. Over 100 participants from the industry and regulators came together virtually to network and learn. Those who attended can access presentations and session recordings by returning to the virtual event space.
This successful event, the fourteenth virtual conference hosted by the CLHIA since the pandemic began, is expected to be the last in this series of on-line events. The CLHIA is planning to return to in-person events in 2022. For more information, visit clhia.ca/events.
CLHIA welcomes Supreme Court decision on Saskatchewan Court of Appeal ruling on life insurers
Published on 04/11/2021
MediaSelect presentations and on demand videos for CLHIA's 2021 Legal Section Annual Meeting are now available
Published on 20/10/2021
Insurance Trade & Commerce > Federal Legislation Provincial & Territorial Legislation Cyber Security Intellectual Property PrivacySubmission to Employment and Social Development Canada on Reforming Canada’s Employment Insurance Program
Published on 13/10/2021
Disability Government Relations > Long term disability Government MonitoringThe CLHIA responded to a federal consultation on “Reforming Canada’s Employment Insurance Program.” The consultation proposed expanding the EI benefits (including EI Sickness) from 15 weeks to 26 weeks, and updating the Premium Reduction Program, in which employers and employees participate when a comparable private short-term disability program is provided. With increasing benefits to 26 weeks, EI Sickness must mitigate the possibility of inadvertently prolonging claims by requiring intermittent medical documentation and providing return-to-work supports. The PRP requires significant reform to encourage employers to participate, including reducing bureaucratic oversight, increasing benefits for participants and encouraging transparency of requirements.
Submission to Employment and Social Development Canada on the Disability Inclusion Action Plan
Published on 05/10/2021
Disability Insurance > Long term disability Federal LegislationThe federal government is planning a multi-faceted approach to modernizing their approach to disability as well as Employment Insurance, EI sickness benefits and the Premium Reduction Program. This consultation, issued by Employment and Social Development Canada (ESDC), looks at Canadians living with disabilities in the context of four pillars: financial security, employment, disability-inclusive spaces and modernization. The CLHIA’s submission focused on three strategic considerations: 1) the need for a clear and consistent definition of disability in federal/provincial programs, 2) placing the lens of mental health on all initiatives and 3) looking at additional disability supports within the context of all available programs, including private disability income payments and other health supports.
British Columbia 2022 Pre-Budget Submission
Published on 01/10/2021
Prescription Drug Costs Insurance Government Relations > Pharmacare Provincial & Territorial Legislation Government MonitoringOn September 30, the CLHIA provided its comments to the British Columbia Select Standing Committee on Finance and Government Services as part of their consultation on Budget 2022. Among CLHIA’s five recommendations are that the province support workplace and individual drug plans that currently provide millions of residents with comprehensive access to medicine and other health services, and that the province extend automatic features to all capital accumulation plans (voluntary workplace pension and savings plans) where an employer matches contributions.
Submission to the Canadian Transportation Agency re: Airline Passenger Rights
Published on 29/09/2021
Group Insurance > Travel insuranceOn September 29, the CLHIA responded to a Canadian Transportation Agency (CTA) consultation on regulatory changes drawing on lessons learned from the pandemic, including the practice of Canadian airlines issuing travel vouchers for cancelled flights. The proposed regulations will require that refunds be provided in the form requested by the traveller (e.g. refund, voucher, points, etc.) and that there be strict timeframes and accountability. As with most APPRs globally, the new legislation will apply to all passenger flights arriving to and departing from Canada, regardless of the country of origin. The CLHIA recommended that there be consideration given to expanding Passenger Protection Regulations to other forms of transportation such as cruise ships and passenger trains. In addition, the CTA should look into coordinating approaches and aligning legislation with provincially regulated travel funds to allow consumers easier access to compensation.
Life and health insurers paid $100 billion to support Canadians through the pandemic, 2020 data shows
Published on 14/09/2021
Capital and Assets Group Insurance Pensions and Retirement Prescription Drug Costs Taxation > Long-term investments Coordination of benefits Dental insurance Employee benefit plans Travel insurance Annuities Public pensions (OAS/CPP/QPP/GIS) Employer pension plans Wealth & Retirement Drug pricing Provincial & territorial drug program information Policyholder TaxOn September 14, the CLHIA released our 2021 Canadian Life and Health Insurance Facts.
Using 2020 industry data, this year’s edition shows the remarkable resilience of life and health insurers’ products through the first nine months of the COVID-19 pandemic.
Among the key facts in this edition are that life and health insurers paid out:
In addition, 26 million Canadians had access to health benefits at the end of 2020 – the same as before the pandemic.
Read this year’s edition online or download it at clhia.ca/facts
Submission to the Ontario Ministry of Government and Consumer Services on Modernizing Privacy in Ontario
Published on 07/09/2021
Government Relations Trade & Commerce > Government Monitoring PrivacyOn September 7, the CLHIA provided its comments to the Ontario Ministry of Government and Consumer Services on its white paper Modernizing Privacy in Ontario: Empowering Ontarians and Enabling the Digital Economy. In our submission, we stressed the need for private sector privacy legislation to be harmonized across Canada. The industry believes a new privacy framework in Ontario is not needed. The submission urged that modernization be coordinated with the federal government’s privacy framework. However, we recommended that if the province chooses to introduce its own privacy legislation, it focus on those areas not captured by the federal regime.
Statement on federal election taxation announcement
Published on 25/08/2021
Taxation > Provincial and Territorial TaxationAdvisory: Potential changes to eye exam coverage under the Ontario Health Insurance Plan (OHIP) effective September 2021
Published on 12/08/2021
Group Insurance Health Care Policy Insurance Consumers > Employee benefit plans CLHIA Health Care Policy Papers Provincial & Territorial LegislationSubmission to the Department of Finance Consultation on Tax Implications of International Accounting rules for Insurance Contracts (IFRS 17)
Published on 12/08/2021
Financial Reporting > International Financial Reporting StandardsOn July 30, the CLHIA responded to Finance Canada’s public consultation on the tax implications of moving to IFRS 17. While the CLHIA is pleased that IFRS 17 will be the starting point for tax reporting, we strongly opposed the proposal to disallow the deduction of Contractual Service Margin (CSM) at transition and on new business. The CLHIA stressed that the proposal will have a material impact on our members and is not consistent with the core tax principle of taxing profits when they are earned. The fundamental argument in the CLHIA’s submission is that CSM represents unearned profit and so should be deductible for tax purposes. This is aligned with the IASB’s recognition criteria.
The CLHIA has had number of meetings with Finance Canada officials to discuss the proposed tax policy and we have established bi-weekly meetings with Finance through the fall on this matter.
The CLHIA also separately submitted technical considerations to Finance as they look to develop legislation.
Statement on federal support for public drug plans in Prince Edward Island
Published on 11/08/2021
Prescription Drug Costs > PharmacareCLHIA Submission to the Standing Committee on Finance 2022 Pre-Budget Consultation
Published on 06/08/2021
Capital and Assets Group Insurance Health Care Policy Prescription Drug Costs Pensions and Retirement > Long-term investments Minimum Continuing Capital and Surplus Requirements Employee benefit plans Drug pricing Pharmacare Employer pension plansOn August 6, the CLHIA made its submission to the House of Commons Standing Committee on Finance in response to its 2022 pre-budget consultation. The CLHIA made six recommendations, notably calling on the federal government to: work collaboratively with provincial and territorial governments and private insurers to support workplace and individual drug plans that currently provide millions of Canadians with comprehensive access to medicines; expeditiously move ahead with Bill C-11; and develop policies and bring forward regulations to encourage private sector investment in infrastructure.
Submission to the BC Special Committee to Review the Personal Information Protection Act
Published on 05/08/2021
Trade & Commerce > PrivacyOn July 30, the CLHIA provided its written comments to the British Columbia Special Committee to Review the Personal Information Protection Act (PIPA). The submission highlighted that protecting the confidentiality of personal information is crucial to maintaining public confidence in our industry. We noted that the CLHIA and its members are keen to work with the government to put in place a robust, coherent regulatory framework that will protect consumers while promoting innovation and a dynamic insurance market in British Columbia and across Canada. The CLHIA also provided an oral statement to the Special Committee on July 6.
Response to British Columbia’s Consultation on its Climate Preparedness and Adaptation Strategy
Published on 05/08/2021
Sustainability and Climate Change > Government MonitoringOn August 12, the CLHIA responded to the Government of British Columbia’s Climate Preparedness and Adaptation Strategy, Draft Strategy and Phase 1 Actions for 2021-22. The draft strategy made the explicit connection between the climate and the physical, social, economic and mental health and well-being of Canadians. The CLHIA commended the government’s decision to establish a new BC Climate Action Secretariat to increase understanding of climate risks through improved data, monitoring and forecasting. The CLHIA also highlighted the industry’s role as a source of stable capital for sustainable infrastructure projects.
Response to the Nova Scotia Climate Change Plan for Clean Growth: Discussion Paper
Published on 30/07/2021
Sustainability and Climate Change > Government MonitoringOn July 30, the CLHIA responded to the Government of Nova Scotia’s Climate Change Plan for Clean Growth: Discussion Paper. The submission highlighted the industry’s ability to provide a stable source of capital for sustainable infrastructure projects.
Submission to Canada’s First Public Engagement on a National Infrastructure Assessment
Published on 30/07/2021
Capital and Assets > Long-term investmentsOn July 30, the CLHIA responded to Infrastructure Canada’s discussion paper Building the Canada we Want in 2050: Engagement Paper on the National Infrastructure Assessment. CLHIA’s submission highlighted the industry’s role as a source of stable, long-term capital for infrastructure, including projects which support Canada’s transition to a lower carbon economy. It recommended that regulators examine infrastructure as an investment category and, where appropriate, adjust prudential standards to reflect the lower risk of investments in high-quality infrastructure. It also recommended that the Office of the Superintendent of Financial Institutions carefully review the Life Insurance Capital Adequacy Test (LICAT) for any undue barriers that may be built into the framework.
Submission to the Ontario Ministry of Finance and FSRA regarding the Fraud and Abuse Strategy for the Auto Insurance Sector
Published on 19/07/2021
Compliance Insurance > Fraud risk management Federal LegislationOn July 19, the CLHIA responded to a Ministry of Finance and Financial Services Regulatory Authority of Ontario (FSRA) consultation on a fraud and abuse strategy for the auto insurance sector. While this consultation was focused on auto insurance, development of such a strategy is of importance to life and health insurers. Many of the clinics and providers that may engage in fraudulent auto claims also provide care to Ontarians with private health insurance coverage and so our industry is also exposed. The industry believes it is critical that any new anti-fraud regime cover the entire insurance industry. Focusing on auto insurance and excluding life and health from any new regime will result in fraudsters targeting life and health insurance claims and may not result in a reduction in overall fraud.
Submission regarding PMPRB's Guideline Monitoring and Evaluation Plan
Published on 07/07/2021
Group Insurance Insurance Prescription Drug CostsCLHIA Comments on FSRA financial professionals title protection rule and guidance
Published on 21/06/2021
Distribution > Advisor regulatory requirements Market conductOn June 21, the CLHIA made a submission supporting the overall objective of FSRA’s title protection rule and guidance. The submission raised concerns and sought clarification in certain areas, specifically that the rule clearly allow the term “advisor” in the context of life and health insurance distribution. Additionally, we followed up with FSRA’s response to our first submission that noted that the LLQP training, and being subsequently life licenced, would not exempt advisors from having to acquire an additional credential to use the Financial Advisor (FA) title. Our submission sought to better understand what the training gaps are, and what paths (e.g., top-up courses) may be required to address them. Further, we noted that the policy objectives of creating a credentialing framework overlap with the current licensing regime, particularly, those that relate to training and oversight. Additionally, we indicated our concern about fees, and the costs to new entrants. The CLHIA will continue to engage with FSRA on this initiative, including a third consultation that will focus on fees, which is expected over the summer.
Submission to the Government of Saskatchewan on the Consultation on a Review of the Pension Funding Framework for Single Employer Defined Benefit Plans in the Private Sector and Other Complementary Reform Measures Applicable to all Defined Benefit Plans
Published on 16/06/2021
Pensions and Retirement > Employer pension plansOn June 11, the CLHIA responded to the Financial and Consumer Affairs Authority of Saskatchewan’s “Review of the Pension Funding Framework for Single Employer Defined Benefit Plans in the Private Sector and Other Complementary Reform Measures Applicable to All Defined Benefit Plan,” released on March 23. The CLHIA commended the Government of Saskatchewan for its actions in examining issues related to solvency funding, restrictions on contribution holidays, and annuity discharge provisions.
Advisory: Refunds from travel providers will affect travel cancelation insurance claims and payouts
Published on 11/06/2021
Group Insurance > Employee benefit plansAs Canadian airlines have begun to refund customers for cancelled trips, the CLHIA issued a public advisory helping consumers understand the steps they should take if they have already received reimbursement from a travel insurer for the same expense.
CLHIA Federal Submission on Targeted Infrastructure Investment
Published on 26/05/2021
Capital and Assets > Long-term investmentsRecently, the House of Commons Standing Committee on Transportation, Infrastructure and Communities held hearings on the topic of targeting infrastructure investment to achieve social, economic and environmental outcomes. The CLHIA made a submission to the committee highlighting the industry’s ability to make significant, long-term investments in infrastructure and sustainable assets.
Submission to the Financial Services Regulatory Authority of Ontario (FSRA) on the Proposed Guidance: Administration of Pension Benefits Upon Marriage Breakdown
Published on 04/05/2021
Pensions and Retirement > Employer pension plansOn May 3, the CLHIA made a submission to the Financial Services Regulatory Authority of Ontario (FSRA) on the proposed “Interpretation and Approach Guidance regarding the processes for the valuation and division of pensions upon marriage breakdown,” released March 18. The CLHIA commended FSRA’s role in providing the industry with a comprehensive and current guide on the processes for the valuation and division of pensions on marriage breakdown.
Submission to the Government of Canada on Possible Accession to the Digital Economy Partnership Agreement
Published on 03/05/2021
Insurance International > Federal Legislation International TradeThe CLHIA provided its views to the federal government on Canada’s possible accession to the Digital Economy Partnership Agreement (DEPA). The agreement’s current signatories include Chile, New Zealand, and Singapore. Given the importance of the digital economy to the international operations and the economic success of some insurers, we note in our submission that the industry supports Canada’s accession to the DEPA. Further, we encouraged the government to consider expanding the provisions in the DEPA to include financial services. The full submission can be found here.
Submission to the New Brunswick Health Council on its healthcare system review
Published on 30/04/2021
Health Care Policy > Business continuation / pandemic planning Long-term CareOn April 30, the CLHIA responded to a New Brunswick government consultation on its healthcare system review, which included a discussion paper detailing the challenges that the public system currently faces. This includes an aging population, hospitals providing care to individuals better served outside of hospital and a lack of family physicians. Over the month of April the government engaged New Brunswickers and other stakeholders in the review. The CLHIA provided suggestions around three areas of mutual interest, including New Brunswickers who are under-insured or not insured for prescription drug coverage, expanding access to virtual healthcare and, lastly, providing appropriate access to mental healthcare.
Consultation on The Professional Supervision of Osteopaths
Published on 30/04/2021
Group Insurance > Regulated professionsOn April 30, the CLHIA responded to a consultation by the Office des professions du Québec on the professional supervision of osteopaths in Quebec. The consultation’s primary aim was to identify osteopaths’ scope of practice and reserved acts, the reservation of a professional title and the creation of a separated order. The CLHIA’s response did not address the proper scope of practice per se, since other associations and health care providers can be expected to deal with this in their own submissions. Rather, our comments focused on considerations for creating and implementing an osteopath order, including public awareness; a code of conduct; ethics and accountability; training and ongoing education; a registry and memberships; and pricing and billing guidelines. We also advocated for a clear cut-off date by which members must be registered and comply with the regulatory body in order to legally be allowed to perform osteopathy in Quebec.
Submission to the Government of Saskatchewan on the Consultation on Financial Hardship Unlocking from a Locked-in Retirement Account
Published on 30/04/2021
Pensions and Retirement > Registered Products (RRSP, LIRA, RRIF)On April 6, the CLHIA made a submission to the Financial and Consumer Affairs Authority of Saskatchewan on amendments to the Pensions Benefits Act, 1992 released on March 11, 2021 regarding the unlocking of locked-in pension benefits. The submission, while recognizing the importance of considering an array of policy levers to assist Canadians experiencing financial pressures, stated the priority should be to preserve funds in pension plans in order to provide secure, adequate, post-retirement income. A main recommendation was to limit withdrawals from locked-in pension funds to a set of specified purposes with required supporting documentation. Further, the CLHIA urged the province to consider harmonizing legislation for unlocking with other provinces that have introduced similar provisions, such as Alberta.
Newfoundland and Labrador 2021 Pre-Budget Submission
Published on 30/04/2021
Health Care Policy Capital and Assets Pensions and Retirement > Generic drug pricing Long-term investments Pooled registered pension plans/PRPPs (and provincial variations)On April 30, the CLHIA made recommendations to the Government of Newfoundland and Labrador in advance of its 2021 budget. The submission highlighted the need to support workplace and individual drug plans that currently provide hundreds of thousands of residents with comprehensive access to medicines; encourage private sector investment in sustainable assets and long-term infrastructure projects; and support a dynamic and innovative business climate by reducing and eventually eliminating the five per cent tax on life, health and disability premiums, which is the highest in Canada.
Submission to the Government of Canada on future trade with the United Kingdom
Published on 28/04/2021
International > International TradeThe CLHIA provided its views to the Government of Canada on an anticipated free trade agreement with the United Kingdom and its possible accession to the Comprehensive and Progressive Agreement for Trans-Pacific Partnership (CPTPP). Canadian insurers have significant operations within the UK and sell a wide range of life and health insurance products within the nation. Our submission notes that the industry supports entering into a free trade agreement with the UK and its accession to the CPTPP to strengthen the long-standing trade relationship with the UK. The full submission can be found here.
The OECD Roadmap for the Good Design of Defined Contribution Retirement Savings Plans
Published on 14/04/2021
Pensions and Retirement > Employer pension plansOn April 14, the CLHIA responded to the Organization for Economic Cooperation and Development’s revised Roadmap on “Good Design of Defined Contribution Retirement Savings Plan,” released on March 4. The CLHIA commended the OECD for initiating the review and consultation with interested stakeholders to maintain and improve defined contribution plans for flexible design, education, and communication. Ensuring retirement income adequacy through the accumulation and decumulation phases with innovative plan design that considers age and socioeconomic considerations is essential to retirement income security.
Submission to the Government of Canada on its Consultation on a National Strategy for High-Cost Drugs for Rare Diseases
Published on 29/03/2021
Prescription Drug Costs > Drug pricingOn March 29, the CLHIA submitted its views to the Government of Canada on its consultation on a national strategy for high-cost drugs for rare diseases. The submission provides comments on how to address key issues in the government’s discussion paper, including improving patient access, evidence-based decision making and sustainability for an effective rare disease strategy. It also presents risk and cost sharing approaches that include private payers. These approaches will minimize impacts to patients and ensure the sustainability of the program over time.
CLHIA welcomes favourable ruling from Saskatchewan Court of Appeal for life insurers
Published on 10/03/2021
Insurance > Provincial & Territorial LegislationOn March 10, the Saskatchewan Court of Appeal ruled on litigation initiated by Atwater Investment LP, Ituna Investments LP and Mosten Investment LP that targeted several life insurance companies. These investment companies had sought to deposit unlimited amounts into universal life insurance policies they had acquired. The Court of Appeal held that a 2018 Saskatchewan government regulation which said life insurers are not permitted to accept deposits unrelated to insurance coverage prevents them from accepting amounts beyond that which may be required for insurance purposes. The CLHIA welcomed the decision as supporting a regulatory framework that protects consumer interests.
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Know the facts: Getting the vaccine will not affect your insurance coverage
Published on 08/03/2021
Group Insurance > Employee benefit plansConsultation on Optometrists Profession Regulation
Published on 01/03/2021
Group Insurance Insurance > Provincial & Territorial LegislationOn March 1, the CLHIA responded to an Alberta Health Services (AHS) consultation on a proposal from the Alberta College of Optometrists to expand the scope of practice to include some procedures currently allowed within the ophthalmology scope only. The CLHIA emphasized that allowing optometrists to deliver certain surgical, laser and other procedures that can be delivered in the office of the optometrist would result in these services being defunded from the AHS, as optometrists’ are not covered by the public plan. The CLHIA advised the AHS that private plans would be unlikely to cover these types of services under the vision care benefit, as this is typically reserved for lenses and frames. Therefore, these services would need to be paid by Albertans themselves.
Submission to the Canadian Transportation Agency in response to the Public Consultation on the Development of New Airline Refund Requirements
Published on 01/03/2021
Insurance > Federal LegislationOn March 1, the CLHIA responded to a Canadian Transportation Agency (CTA) consultation on proposed changes to the Air Passenger Protection Regulations as a result of the experience with trip cancellations and interruptions due to the COVID-19 pandemic. While the proposed changes will not be retroactive, the CLHIA pointed out the dissatisfaction many Canadians have expressed with having received a voucher. Any government funding paid to the airlines should come with a stipulation that airlines must reimburse consumers so-affected. In Canada, the CTA has allowed airlines to issue vouchers for credit instead of full refunds. In other jurisdictions such as the United Kingdom, Europe and the US, tighter regulations have required refunds and stipulate the turnaround time, as well as other requirements.
CLHIA opens Western Canada government affairs office
Published on 23/02/2021
CLHIA Governance > StaffCLHIA Budget 2021 Submission to the Department of Finance
Published on 22/02/2021
Capital and Assets Health Care Policy Pensions and Retirement Prescription Drug Costs Trade & Commerce > Long-term investments Retirement Income System Reviews Drug pricing Pharmacare PrivacyOn February 21, the CLHIA made its submission to the federal government in advance of budget 2021, including seven recommendations. In addition to long-standing recommendations such as supporting workplace and individual drug plans and eliminating the capital tax on Canadian financial institutions, this year the CLHIA also recommended the establishment of a 20-year federal debt instrument in order to aid in economic recovery. The submission also urges the government move ahead expeditiously with Bill C-11 to ensure a modernized and coherent regulatory framework across Canada.
Submission to the Canadian Government on a Possible Economic Partnership Agreement with Indonesia
Published on 22/02/2021
International > International TradeOn February 22, the CLHIA provided its views to the government of Canada on a possible comprehensive economic partnership agreement with Indonesia. Given the international operations of the industry and its presence in Indonesia, the industry is supportive of entering into such an agreement with the country. The submission highlighted key issues that need to be considered as part of the economic partnership agreement, including further opening the Indonesia market to foreign investment and the free flow of data across borders. The full submission can be found here.
Manitoba 2021 Pre-Budget Submission
Published on 18/02/2021
Government Relations > Government MonitoringOn February 18, the CLHIA made its submission to the Manitoba 2021 pre-budget consultation. The document makes five recommendations including those geared towards protecting workplace and individual health benefits and removing tax disincentives on insurance.
Ontario 2021 Pre-Budget Submission
Published on 11/02/2021
Insurance > Provincial & Territorial LegislationOn February 11, the CLHIA submitted its recommendations to the government of Ontario in advance of its 2021 budget. The submission made seven recommendations including supporting access to affordable prescription drugs, protecting vulnerable Ontario seniors from financial exploitation and reducing and eventually eliminating the retail sales and premium taxes on life and health insurance.
New Brunswick 2021-22 Pre-Budget Consultation
Published on 11/02/2021
Insurance > Provincial & Territorial LegislationOn February 11, the CLHIA made its submission to the government of New Brunswick in advance of its 2021 budget. The submission made seven recommendations including supporting access to affordable prescription drugs, modernizing the agent licensing regime and prohibiting self-insured employer long-term disability benefits.
Letter to Ontario MPPs Re: Bill 219, Life Settlements and Loans Act
Published on 25/01/2021
Insurance > Provincial & Territorial LegislationPrince Edward Island 2021 Pre-Budget Submission
Published on 22/01/2021
Government Relations Insurance > Government Monitoring Provincial & Territorial LegislationOn January 22, the CLHIA submitted its comments to the Prince Edward Island government in advance of its 2021 budget. The submission made five recommendations including supporting access to affordable prescription drugs, pension innovation to provide more secure retirement income options and removing tax disincentives on insurance.
CLHIA's submission to the Ontario Low-Carbon Hydrogen Strategy Consultation
Published on 18/01/2021
Sustainability and Climate Change > Government MonitoringOn January 18, the CLHIA submitted its comments to the Ontario Ministry of Environment, Conservation and Parks in response to its consultation on the development of a low-carbon hydrogen strategy. The submission highlighted the industry’s support for the government creating new opportunities for investment in sustainable, long-term infrastructure assets.
Submission to the Department of Finance on Federally Regulated Private Pension Plans
Published on 18/01/2021
Pensions and Retirement > Employer pension plans Retirement Income System ReviewsOn January 14th, the CLHIA made its submission to a Finance Canada consultation on “Strengthening Canadians’ Retirement Security – Proposals to Support the Sustainability of and Strengthen the Framework for Federally Regulated Private Pension Plans.” The submission commended the department for initiating this consultation on the security and governance of Canada’s pension plans. However, it also proposed some enhancements to the proposal to ensure that they are workable and provide necessary retirement income security so that Canadians may retire with confidence:
Letter to the Secretariat of the Canadian Association of Pension Supervisory Authorities (CAPSA) re: Quarterly Meeting 3 year planning priorities
Published on 27/03/2020
Pensions and Retirement > Public pensions (OAS/CPP/QPP/GIS) Pooled registered pension plans/PRPPs (and provincial variations) Employer pension plans Registered Products (RRSP, LIRA, RRIF)CLHIA Process on Electronic Declarations
Published on 24/12/2019
Trade & Commerce > Electronic CommerceEnhancing retirement income options for Canadians
Published on 29/11/2019
Pensions and Retirement > CLHIA Pensions and Retirement Policy Paper Public pensions (OAS/CPP/QPP/GIS) Pooled registered pension plans/PRPPs (and provincial variations) Employer pension plansLetter to Minister of Social Development and Poverty Reduction re: British Columbia Framework for Accessibility Legislation
Published on 29/11/2019
Insurance > Provincial & Territorial LegislationInsurers and healthcare groups collaborate to help providers and patients better understand health insurance benefits
Published on 13/11/2019
Group Insurance > Employee benefit plansCritical Illness (CI) Benchmark Definitions
Published on 05/12/2024
Disability > Critical illnessUnderstanding Claims for Treatment of Obstructive Sleep Apnea with Positive Airway Pressure (PAP) Devices
Published on 03/01/2018
Group Insurance > CLHIA Group Insurance guidelines and reference documents Paramedical benefits Employee benefit plansA Canadian Success Story: PROMOTING TRADE IN LIFE AND HEALTH INSURANCE
Published on 16/05/2017
International > International Trade CLHIA International Trade Policy PaperThis position paper briefly describes the benefit of trade in financial services to Canada, the participation of our insurance companies in foreign markets, and the policy directions the Canadian government should take to promote and facilitate trade, particularly for financial services.
Retirement Income: Coalition appeals to finance ministers
Published on 27/06/2016
Pensions and Retirement > Public pensions (OAS/CPP/QPP/GIS) Retirement Income System ReviewsThe Insurance & Investment Journal
The financial downside of living too long
Published on 11/06/2016
Pensions and Retirement > Registered Products (RRSP, LIRA, RRIF) Wealth & RetirementWinnipeg Free Press
Good-bye travel incentives!
Published on 26/04/2016
Distribution > Sales practicesThe Insurance and Investment Journal
Group benefits providers report: Insurers get a boost in the battle against fraud
Published on 15/04/2016
Trade & Commerce > Privacy Federal LegislationBenefits Canada
Most Canadians think government programs will cover LTC
Published on 14/04/2016
Long-term CareInvestment Executive
Rest in peace: Weigh your needs when considering to buy life insurance
Published on 14/04/2016
Consumers > Financial Literacy InitiativesCanadian Press
CLHIA says sales practices could be improved
Published on 30/03/2016
Distribution > Sales practicesThe Insurance & Investment Journal