Alberta Regulation 140/2026, the Dual Practice Records Regulation, establishes new record-keeping and reporting requirements for physicians who provide both publicly insured health services and privately paid non-Plan services under the Alberta Health Care Insurance Act. The regulation supports legislative amendments intended to increase transparency and oversight of dual practice arrangements in Alberta’s health care system.

Under the regulation, physicians who are “flexibly participating physicians” must create and maintain detailed electronic records for non-Plan services. Patient records related to non-Plan services must be created in a format capable of being submitted to Alberta’s provincial health information systems, including the Alberta Electronic Health Record (Alberta EHR). Physicians must submit these records within 30 days of providing the related service unless a different timeline is established under applicable medical staff bylaws. Physicians must retain both electronic and physical versions of records while providing the service and for at least six years after ending the provision of that service to the patient.

Flexibly participating physicians must also establish and maintain a comprehensive records management system covering both insured and non-Plan services under their custody or control. The system must clearly identify whether a service was publicly insured, privately paid by the patient, or paid by an insurer. This requirement is designed to improve accountability by ensuring that publicly funded and privately funded services can be distinguished and reviewed.

The same record-keeping requirements apply to non-participating physicians. The regulation incorporates the obligations imposed on flexibly participating physicians and applies them to physicians who have fully opted out of the public health insurance plan. This creates consistent documentation standards across physicians who provide services outside the publicly funded system.

A transitional framework is included for physicians who had previously opted out of the Alberta Health Care Insurance Plan before the regulation came into force. These transitioning physicians are temporarily exempt from certain requirements applicable to non-participating physicians for six months following implementation. They may request an extension from the Minister, provided the request is submitted at least 30 days before the transition period expires and explains the reasons for additional time. The Minister may grant an extension of up to an additional six months.

The regulation is intended to strengthen oversight of dual practice medicine by improving documentation, financial transparency, and government access to information regarding privately delivered medical services. The regulation comes into force when section 1(22)(a)(v) of the Health Statutes Amendment Act, 2025 (No. 2) takes effect, linking its implementation to broader reforms of Alberta’s health insurance framework.

Alberta (140/2026) July 15, 2026
Disclaimer: Insights are for informational purposes only and does not reflect RRI’s official position or constitute legal opinion.