R v. Alberta Medical Association

The Alberta Medical Association and the Government couldn’t agree on the fourth-year wage increase under their 2022–2026 agreement. The AMA argued inflation and recruitment pressures warranted 13.6%. Arbitrator Kaplan disagreed — and his reasons on catch-up claims and the replication principle will be of broad interest.

Background

The Alberta Medical Association (AMA), which represents Alberta physicians, entered into a four-year agreement (2022–2026) that provided for 1% annual increases in the first three years, with a reopener clause for the fourth year to determine the percentage increase for 2025–26. The AMA sought a 13.6% increase, citing inflation, recruitment, and retention challenges. The Government proposed 2.7%, arguing that this would maintain Alberta physicians’ competitive compensation.

The parties attempted to resolve the dispute through mediation in November 2025, but were unsuccessful. In January 2026, the matter proceeded to binding arbitration before William Kaplan, Sole Arbitrator.

Issue

What percentage wage increase should be applied to physician compensation for the fourth year (2025–26) of the 2022–2026 agreement?

Decision

The arbitrator awarded a 3% increase for the fourth year of the agreement. Arbitrator Kaplan concluded that 3% was appropriate based on a balanced application of the criteria set out in the agreement. Notably, the arbitrator determined that the “change in the cost of living” criterion should be assessed only for the previous year, not the entire term of the agreement — rejecting the AMA’s claim for cumulative catch-up increases on the basis that the parties had freely negotiated the first three years with full knowledge of inflation rates at the time.

The arbitrator found no evidence of a recruitment and retention crisis warranting a higher increase. While challenges in capacity and distribution existed, the evidence showed a net increase in physician numbers and that government measures were addressing the issues. Arbitrator Kaplan gave significant weight to increases awarded to other government-funded groups, finding that 3% aligned with the established pattern for 2025–26 and was consistent with the replication principle.

The arbitrator also considered Alberta’s economic conditions and fiscal sustainability, finding that public funds must be allocated prudently. He rejected the Government’s reliance on interprovincial comparisons due to data challenges, but acknowledged that Alberta physicians were already well-compensated relative to counterparts in other provinces.

Citation: 2026 CanLII 16804 (AB GAA)