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Submission to FSRA on its Consultation on an Innovation Framework

Published on 29/11/2021

Compliance Distribution > Advisor regulatory requirements Market conduct

Select 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 Privacy

Submission 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 Monitoring

The 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 Legislation

The 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 Monitoring

On 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 insurance

On 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 Tax

On 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: 

  • over $12 billion in claims for prescriptions drugs;
  • $950 million in travel insurance claims – largely for trip cancellations;
  • $420 million in psychology-related claims to support mental health – up nearly a quarter from 2019; and
  • $154 million in life insurance claims from deaths related to COVID-19.


  • 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 Privacy

    On 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 Taxation

    Advisory: 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 Legislation

    Statement on federal support for public drug plans in Prince Edward Island

    Published on 11/08/2021

    Prescription Drug Costs > Pharmacare

    CLHIA 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 plans

    On 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 > Privacy

    On 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 Monitoring

    On 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 Monitoring

    On 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 investments

    On 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 Legislation

    On 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 Costs

    CLHIA Comments on FSRA financial professionals title protection rule and guidance

    Published on 21/06/2021

    Distribution > Advisor regulatory requirements Market conduct

    On 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 plans

    On 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 plans

    As 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.

    Michael Doughty elected CLHIA Chair

    Published on 01/06/2021

    CLHIA Governance > Board of Directors

    CLHIA Federal Submission on Targeted Infrastructure Investment

    Published on 26/05/2021

    Capital and Assets > Long-term investments

    Recently, 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 plans

    On 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 Trade

    The 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 Care

    On 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 professions

    On 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 Trade

    The 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 plans

    On 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 pricing

    On 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 Legislation

    On 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. 

    STATEMENT
    Know the facts: Getting the vaccine will not affect your insurance coverage

    Published on 08/03/2021

    Group Insurance > Employee benefit plans

    Consultation on Optometrists Profession Regulation

    Published on 01/03/2021

    Group Insurance Insurance > Provincial & Territorial Legislation

    On 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 Legislation

    On 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 > Staff

    CLHIA 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 Privacy

    On 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 Trade

    On 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 Monitoring

    On 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 Legislation

    On 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 Legislation

    On 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 Legislation

    Prince Edward Island 2021 Pre-Budget Submission

    Published on 22/01/2021

    Government Relations Insurance > Government Monitoring Provincial & Territorial Legislation

    On 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. 

    GFIA highlights insurance industry cyber-awareness initiatives

    Published on 21/01/2021

    International > Network of Insurance Associations

    CLHIA's submission to the Ontario Low-Carbon Hydrogen Strategy Consultation

    Published on 18/01/2021

    Sustainability and Climate Change > Government Monitoring

    On 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 Reviews

    On 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: 

  • Broadening the scope of VPLAs to enable viable risk solutions to be manufactured and managed effectively and competitively
  • Supporting the department’s temporary solvency funding relief to plan sponsors to mitigate the impacts of the pandemic on businesses while balancing retirees’ interests 
  • Harmonization of governance policies and best practices across Canada help ease administration burden. 
  • CLHIA submission to Nova Scotia in response to the 2021-22 Pre-Budget Consultation

    Published on 18/12/2020

    Taxation Pensions and Retirement Prescription Drug Costs Group Insurance > Provincial and Territorial Taxation Policyholder Tax Annuities Employer pension plans Drug pricing Generic drug pricing Provincial & territorial drug program information Employee benefit plans

    On December 18, the CLHIA submitted its recommendations to the Government of Nova Scotia in advance of its 2021 budget. The submission focuses on supporting access to affordable prescription drugs, pension innovation, removing tax disincentives on insurance, enhancing infrastructure investment opportunities and impacts of climate change on the industry.

    CLHIA becomes supporter of United Nations initiative on sustainable insurance

    Published on 15/12/2020

    International > International Monitoring

    Prince Edward Island becomes fifth province to update insurance act

    Published on 11/12/2020

    Insurance > Provincial & Territorial Legislation

    Advancing the sustainable agenda: Perspectives on insurers’ capacity as sustainable investors

    Published on 09/12/2020

    International > Network of Insurance Associations

    The global insurance industry is committed to contributing to collective efforts to make the global economy more sustainable. Aside from their efforts to enhance adaptation and the mitigation of climate risks, insurers also contribute through their role as investors in sustainable assets. In December, the Global Federation of Insurance Associations (GFIA) published a paper, Advancing the sustainable agenda: Perspectives on insurers’ capacity as sustainable investors. The CLHIA participated in the GFIA Climate Change Working Group responsible for drafting the paper.

    CLHIA submission to Alberta re: 2021 pre-budget consultations

    Published on 01/12/2020

    Government Relations > Government Monitoring

    On December 1, the CLHIA submitted its recommendations to the Government of Alberta in advance of its 2021 budget. The submission focuses on supporting access to affordable prescription drugs, pension innovation, removing tax disincentives on insurance and enhancing infrastructure investment opportunities.

    Advisory: Understanding your medical insurance options for travel outside Canada

    Published on 25/11/2020

    Group Insurance > Travel insurance

    Statement: CLHIA comments on the 2020 Ontario Budget

    Published on 05/11/2020

    Government Relations > Government Monitoring

    CLHIA welcomes final guidelines to keep prescription medications affordable

    Published on 23/10/2020

    Prescription Drug Costs > Catastrophic drug coverage Drug pricing Generic drug pricing

    2020 Ontario Fall Budget Submission

    Published on 16/10/2020

    Distribution Prescription Drug Costs > Advisor regulatory requirements Market conduct Sales practices Drug pricing Provincial & territorial drug program information Pharmacare

    On October 16, the CLHIA submitted its recommendations to Ontario’s Minister of Finance in advance of the Ontario’s 2020 budget. The submission focused on protecting group health benefits plans, increasing access to prescription medications, pension innovation, reducing premium taxes and financial titling. The submission generated interest from several media outlets including Benefits Canada.

    Submission to the Competition Bureau of Canada regarding Digital Transformation of the Health Care Sector

    Published on 09/10/2020

    Health Care Policy > Business continuation / pandemic planning

    The Competition Bureau of Canada consulted with stakeholders and Canadians regarding the barriers encountered when seeking health care virtually. Initially when the pandemic and states of emergency were declared back in March 2020, most non-emergency health care stopped. Soon after health care providers moved to offering virtual care wherever possible and insurers worked to understand what care could be provided effectively through virtual means. Among the areas impacted were health claims adjudication, including dental and prescription drugs; prior-authorizations and disability assessments where prescribers no longer provide “observed” criteria but rather “patient-reported” outcomes from a virtual consultation; and virtual rehabilitation programs for those on disability. The CLHIA’s submission makes a number of recommendations in the area of virtual care. First, regulatory colleges must move quickly to put regulations in place regarding virtual care scope of practice with consistency amongst jurisdictions being a prime goal. There needs to be documentation and reporting standards developed to ensure transparency regarding the services provided virtually. Other barriers to consider include privacy concerns, security of technology, linguistic challenges along with other more structural barriers.

    Submission to the Ontario Ministry of Government and Consumer Services regarding Private Sector Privacy Reform

    Published on 30/09/2020

    Trade & Commerce > Privacy

    On September 30, the CLHIA submitted its comments in response to the government’s discussion paper “Ontario’s Private Sector Privacy Reform: Improving private sector privacy for Ontarians in a digital age.” The CLHIA recommended that Ontario wait until the federal government introduces its updates to the Personal Information Protection and Electronic Documents Act (PIPEDA) before implementing any private sector privacy reforms.

    CLHIA Submission on Bill 64: An Act to modernize legislative provisions as regards the protection of personal information

    Published on 25/09/2020

    Trade & Commerce > Privacy

    On September 25, the CLHIA submitted its views to the Government of Quebec regarding Bill 64, An Act to modernize legislative provisions as regards the protection of personal information. CLHIA’s submission outlines the industry’s concerns with how the provisions of the bill differ significantly from other existing privacy legislation in Canada as well as concerns with how the bill will impede on the free flow of data across borders. Further technical comments on the legislation are also provided.

    Statement: Prescription drug benefits have remained resilient during COVID-19

    Published on 16/09/2020

    Prescription Drug Costs Group Insurance > Provincial & territorial drug program information Employee benefit plans

    Life and health insurers made a record $103 billion in benefits payments in 2019

    Published on 15/09/2020

    Group Insurance Health Care Policy Prescription Drug Costs Taxation Capital and Assets > Coordination of benefits Dental insurance Employee benefit plans Travel insurance Generic drug pricing Drug pricing Provincial & territorial drug program information Provincial and Territorial Taxation Policyholder Tax Long-term investments

    Global Federation of Insurance Associations (GFIA) releases new position paper on climate adaptation and mitigation

    Published on 03/09/2020

    International > International Monitoring Network of Insurance Associations

    On September 3, GFIA released a position paper outlining the role insurers around the world can play in adapting to and mitigating the impacts of climate change. The position paper was drafted in consultation with GFIA’s Climate Change Working Group, which the CLHIA participates in.

    Letter to Alberta Health re: "Proposals to Amend the Health Professions Act to Improve Regulatory Effectiveness and Efficiency"

    Published on 18/08/2020

    Group Insurance > Regulated professions

    On August 18, the CLHIA responded to a consultation on the proposed modernization of Alberta’s Health Professions Act, which governs 28 regulated professions within 25 regulatory colleges. The CLHIA commented on six of the proposals, largely supporting the recommendations, while offering suggestions about a central registry and the complaints and discipline process. The objectives of modernization include enhancing governance and discipline in the professions, increasing transparency to Albertans and enhancing provisions for engagement and collaboration, amongst others. Some of the ways that the government proposes to achieve their objectives include separating all associations from their corresponding college, establishing separate government or oversight bodies for registries of providers as well as for the complaint process, and reducing the numbers of colleges. This means combining regulatory colleges, such as a college for oral health professionals that would govern dental hygienists, denturists, dentists and dental assistants. Combining colleges is expected to make regulation easier and reduce duplication of resource requirements.

    Letter to BC PIPA regarding the review of the Personal Information Protection Act

    Published on 10/08/2020

    Trade & Commerce > Privacy

    On August 10, the CLHIA submitted a letter to the BC Legislature’s Special Committee to Review the Personal Information Protection Act (PIPA) which highlighted the life and health insurance industry’s views on several key issues with the current legislation. The letter covers disclosure of personal information without consent in the context of fraud, privacy breach notification, access rights involving medical information, access rights used for litigation purposes, and cross-border data flows. It also reinforced the importance of PIPA remaining substantially similar to the federal Personal Information Protection and Electronic Document Act (PIPEDA) and to maintain adequacy status in relation to the EU’s General Data Protection Regulation (GDPR).

    2021 Pre-Budget Submission to the House of Commons Standing Committee on Finance

    Published on 06/08/2020

    Capital and Assets Group Insurance Health Care Policy Prescription Drug Costs > Long-term investments Coordination of benefits Employee benefit plans Pharmacare

    On August 6, the CLHIA provided the life and health insurance industry’s recommendations for the 2021 Federal Budget to the House of Commons Standing Committee on Finance. The CLHIA highlighted the need to implement changes to the Patented Medicine Regulations as planned on January 1, 2021, the industry’s wish to work with the government as it updates its privacy legislation to ensure a balanced approach between an individual’s right to control their personal information, and the need to maintain a vibrant and sustainable insurance market, among other recommendations.

    Submission to the Patented Medicine Prices Review Board on the proposed draft guidelines

    Published on 05/08/2020

    Prescription Drug Costs > Drug pricing Pharmacare

    PMPRB Consultation On August 5, the CLHIA responded to the June 20 Patented Medicines Pricing Review Board (PMPRB) consultation on its revised draft guidelines. The Guidelines will support the government’s implementation of the amended Patented Medicines Regulations planned for January 1, 2021. The CLHIA continued to provide the industry’s support for the planned reforms. We indicated that in our view, the proposed changes strike the right balance between reducing the high cost of prescription drugs in Canada, while also continuing to ensure Canadians have access to affordable and necessary medications. We also reinforced the importance of moving forward as planned on January 1, 2021 without further delays. CLHIA will continue to monitor for any updates. The final guidelines are expected to be available in the next few months in preparation for the January 1 implementation.

    Advisory: Planning out-of-country travel? Make talking with your insurer part of your plans

    Published on 07/07/2020

    Group Insurance > Travel insurance

    Given the federal government’s global "avoid all non-essential travel" advisory, individual insurance for non-essential travel purposes is not being sold. The closure of the US border remains in effect until at least September 21. Despite these measures, some international destinations such as the European Union have reduced or eliminated travel restrictions for Canadians. Canadian businesses involved in the travel industry, such as airlines, are putting tremendous pressure on the Canadian government to lift travel restrictions.

    Given this situation and the fact that travelling Canadians may not be aware of the questions that they should ask before making arrangements, the CLHIA and its members have put together a consumer advisory with questions and considerations for Canadians to think about or reach out to their insurer with. There is a communication plan for social media to distribute to other stakeholders such as CCIR, and to circulate to media. This advisory will remain evergreen as the situation with respect to travel continues to evolve.

    Submission to OSC re 52-112 Non-GAAP and other Financial Measures Disclosure

    Published on 29/06/2020

    Capital and Assets Financial Reporting > Securities Generally Accepted Accounting Principles (GAAP)

    On June 29, the CLHIA responded to a consultation issued by the Canadian Securities Administrators (CSA) on the proposed National Instrument 52-112 Non-GAAP and Other Financial Measures Disclosures that lays out guidance for reporting issuers to follow when disclosing non-GAAP and other financial measures in published documents. While we support the overall goal of the proposed instrument to provide high quality financial information to the users of published financial reports, the CLHIA provided some specific recommendations to enhance the clarity of the final standard and lower the compliance burden on our members that will be impacted by the proposed instrument.

    2021 British Columbia Pre-Budget Submission

    Published on 24/06/2020

    Capital and Assets Group Insurance Prescription Drug Costs Taxation > Long-term investments Employee benefit plans Drug pricing Pharmacare

    On June 25, the CLHIA shared the life and health insurance industry’s recommendations for the 2021 British Columbia budget with the province’s Select Standing Committee on Finance and Government Services. Recommendations notably included: supporting workplace and individual drug plans that currently provide millions of B.C. residents with comprehensive access to prescription drugs; leveraging the industry’s investment capacity to accelerate long-term infrastructure projects; creating more opportunities for insurers to invest in assets that meet sustainability goals; and reducing and eventually eliminating the premium tax on life and health insurance premiums.

    Advisory: Health Protection Standards for Paramedical Lab Testing for Insurance During COVID-19

    Published on 09/06/2020

    Risk Management > Underwriting

    In response to provinces that are beginning to resume non-emergency health services, the CLHIA issued an advisory on June 9 to raise awareness of paramedical lab testing for insurance. Life and health insurers are urging governments and providers to ensure appropriate health protection standards are met to protect the health and safety of our clients and the broader community.

    CLHIA Submission on the Canada Emergency Wage Subsidy Program

    Published on 04/06/2020

    Government Relations > Government Monitoring

    On June 4, the CLHIA shared the life and health insurance industry’s views on the Canada Emergency Wage Subsidy (CEWS) program with the federal government. The CLHIA supports the CEWS and believes it is crucial to help sustain the employer-employee linkage during the COVID-19 pandemic. The CLHIA highlighted that there continues to be uncertainty over the eligibility criteria among some of our members and that more clarity and useful FAQs would be helpful.

    Jean-François Chalifoux elected as CLHIA Chair

    Published on 08/06/2020

    CLHIA Governance > Board of Directors

    The members of the Canadian Life and Health Insurance Association have elected Jean-François Chalifoux, Chief Executive Officer of SSQ Insurance as Chair.

    Founded in 1944, SSQ Insurance is now one of the largest insurance companies in Canada, with $13 billion in assets under management.

    Jean-François holds a bachelor's degree in actuarial sciences from Laval University, is a Fellow of both the Canadian Institute of Actuaries and the Casualty Actuarial Society, and is a graduate of the Queen’s Executive Development Program. Prior to joining SSQ Insurance in 2015, he held several executive roles with major Canadian insurance companies.

    Letters to BC Government Re: Medical lab tests for insurance applications

    Published on 29/05/2020

    Risk Management > Underwriting

    The CLHIA sent letters to the Minister of Health and the Minister of Finance in British Columbia with respect to paramedical lab testing for insurance applications. The letters were in response to concerns raised publicly by an advisor in that province criticizing the industry for our approach to accepting test results during COVID-19. The CLHIA advised the Ministers of some temporary changes that have been immplemented since COVID-19 with respect to insurance applications and steps taken by member companies to ensure Canadians continue to receive insurance coverage.

    Statement: Update on Canada’s life and health insurers’ response to COVID-19

    Published on 01/05/2020

    Group Insurance > Employee benefit plans

    Beneficial Ownership Transparency Consultations: Canada and British Columbia - input from CLHIA

    Published on 30/04/2020

    Compliance > Anti-money laundering/anti-terrorist financing

    On April 30, the CLHIA responded to federal and British Columbia consultations, expressing support for the creation of a registry of beneficial owners of corporations. A registry could improve transparency and streamline interactions between insurers and their clients by enabling insurers to collect ownership information directly from the registry.

    The submission highlights the importance that information contained in the registry be reliable, accurate, complete and current, since there would be an expectation that financial institutions would consult the registry. The database should also be sufficiently flexible to accommodate new forms of digital identification.

    Governments should use tools at their disposal, such as auto-populating with licensing and tax information, to ensure the accuracy of the information contained in the registry.

    CLHIA welcomes New Brunswick’s announcement on prescription limits for drugs with strong supplies

    Published on 24/04/2020

    Prescription Drug Costs > Drug pricing Provincial & territorial drug program information

    Request to the Canada Revenue Agency to suspend minimum employer contributions to DC pensions

    Published on 13/04/2020

    Pensions and Retirement > Employer pension plans

    Multiple employers who sponsor defined contribution pension plans have expressed concern to CLHIA members about their inability to make required pension contributions given reduced cash flow due to COVID-19. Partly in response to a CLHIA request, the CRA has announced that, for the remainder of 2020, it will waive the 1 per cent “minimum contribution requirement” set out in Registered Plans Directorate Newsletter 91-4R. Note that this is not automatic and is subject to filing of a plan amendment with the CRA. A parallel amendment may also be required with the relevant regulator under pension benefits legislation.

    Statement from the Canadian Life and Health Insurance Association on the Canada Emergency Wage Subsidy

    Published on 08/04/2020

    Government Relations > Government Monitoring

    Advisory: Travel cancellation insurance and airline vouchers or credits

    Published on 01/04/2020

    Group Insurance > Travel insurance

    Letter to Canadian Association of Pension Supervisory Authorities (CAPSA) re: Quarterly Meeting COVID-19 Responses

    Published on 27/03/2020

    Pensions and Retirement > Public pensions (OAS/CPP/QPP/GIS) Pooled registered pension plans/PRPPs (and provincial variations) Registered Products (RRSP, LIRA, RRIF)

    Each Spring, the CLHIA meets with the Canadian Association of Pension Supervisory Authorities (CAPSA) to recommend issues for consideration in their 3-year strategic plan. This year, the CLHIA made two separate submissions as part of this process, separating COVID-19 priorities and longer-term objectives. Near-term deferral of reporting, pension contribution relief and enhanced withdrawal options to address financial hardship usurped much of CAPSA's longer-term planning agenda. At present, there does not appear to be a coordinated response by pension regulators to COVID-19, although some contribution suspension appears to be forthcoming based on follow-up discussions with individual regulators. While federally regulated pension plans have had limits imposed on de-risking when significantly under-funded, other regulators have not adopted such restrictions; these measures should have limited negative impact on annuity purchases.

    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)

    Travel insurers confirm individual health insurance coverage for commercial truckers

    Published on 25/03/2020

    Group Insurance > Employee benefit plans Travel insurance

    Urgent notice for Canadians currently in the USA and abroad

    Published on 20/03/2020

    Government Relations Group Insurance > Government Monitoring Travel insurance

    Insurers confirm continued out-of-country health insurance coverage for commercial trucking industry

    Published on 19/03/2020

    Group Insurance > Employee benefit plans Travel insurance

    COVID-19: Statement from the life and health insurance industry

    Published on 13/03/2020

    Group Insurance > Employee benefit plans Travel insurance

    Insurers welcome Insurance Act changes to protect vulnerable seniors

    Published on 11/03/2020

    Insurance > Provincial & Territorial Legislation

    Letter to the Prime Minister in support of the amendments to Patented Medicines Regulations

    Published on 03/03/2020

    Prescription Drug Costs > Pharmacare

    2020 Ontario Budget Submission

    Published on 02/03/2020

    Capital and Assets Group Insurance Prescription Drug Costs Taxation > Long-term investments Employee benefit plans Drug pricing Pharmacare Premium tax

    Letter to Chairman Hoogervost re: Ensuring a common global adoption date for IFRS 17

    Published on 02/03/2020

    Financial Reporting > International Financial Reporting Standards

    Consistent with the CLHIA’s recommendations to the International Accounting Standards Board (IASB) in its letter dated March 2, the IASB voted on March 17 in favour of both:  

  • deferring the effective date of IFRS 17 to 2023, and
  • extending the fixed expiry date of the temporary exemption from applying IFRS 9 to 2023.

  • In its deliberations, the IASB reiterated some of the key considerations emphasized by the CLHIA, in particular, the importance of a common global adoption date and the potentially adverse effects for insurers in Canada and certain other regions if they were forced to implement IFRS 17 before Europe. The IASB has concluded its deliberations on the amendments to IFRS 17 and aims to publish the final standard in the second quarter of this year. The CLHIA would like to thank members for their support throughout the IASB’s consultation period in working toward an improved standard. We will continue to collaborate with members on the IFRS 17 Working Group to assess the impacts of the amended standard and ensure a robust implementation in Canada.

    Letter to the Canadian Accounting Standards Board re: Ensuring a common global adoption date for IFRS 17

    Published on 27/02/2020

    Financial Reporting > International Financial Reporting Standards

    2020 New Brunswick Pre-Budget Submission

    Published on 25/02/2020

    Capital and Assets Group Insurance Prescription Drug Costs Taxation > Long-term investments Employee benefit plans Drug pricing Pharmacare Premium tax

    2020 Prince Edward Island Pre-Budget Submission

    Published on 25/02/2020

    Capital and Assets Group Insurance Prescription Drug Costs Taxation > Long-term investments Employee benefit plans Drug pricing Pharmacare Provincial and Territorial Taxation Premium tax

    CLHIA letter to the Standing Committee on International Trade on the Implementation of CUSMA

    Published on 19/02/2020

    International > International Trade

    On February 19, the CLHIA submitted a letter to the House of Commons Standing Committee on International Trade calling on the federal government to pass Bill C-4, an act to implement the agreement between Canada, the United States of America, and the United Mexican States (CUSMA) as soon as possible. The letter reiterated the industry's support for the free trade agreement and encouraged the government to maintain the NAFTA Financial Services Committee, which provided a mechanism for regulators in the three countries to share information and discuss areas of concern in the financial services sector.

    Patented Medicine Prices Review Board Regulations (PMPRB) Consultation on Draft Guidelines Submission

    Published on 14/02/2020

    Prescription Drug Costs > Drug pricing

    On February 14, the CLHIA responded to the Patented Medicines Review Board’s (PMPRB) consultation on draft guidelines to support implementation of the amendments to the Patented Medicines Regulations that come into effect July 1, 2020. Our submission was supportive of the proposed changes and we conclude that the proposed changes strike the right balance between reducing the high cost of prescription drugs in Canada, while continuing to ensure Canadians have access to affordable and necessary medications. The industry noted that we will continue to look for ways to support these efforts as the PMPRB moves towards implementation.

    2020 Alberta Pre-Budget Submission

    Published on 12/02/2020

    Capital and Assets Group Insurance Prescription Drug Costs Taxation > Long-term investments Employee benefit plans Drug pricing Pharmacare Provincial and Territorial Taxation Premium tax

    CLHIA Letter to the Canadian Institute of Actuaries regarding national pharmacare

    Published on 11/02/2020

    Prescription Drug Costs > Pharmacare

    On February 11, the CLHIA responded to a call for input to inform the creation of a level-2 Canadian Institute of Actuaries public statement on national pharmacare. The submission recommended that any reform of the prescription drug system embody three elements: protecting and enhancing existing benefits plans, providing drug coverage for everyone, and ensuring affordability for consumers and taxpayers, including addressing high cost drugs.