Great-West Life Assurance Company v. The Queen, 2015 TCC 225 -- summary under Subsection 4(2)

By services, 28 November, 2015

The appellant ("Great-West") provided prescription drug plans to the employees of various employers. The claims were processed by a third party ("Emergis") using its "Assure Card System." The plan members' claims were adjudicated electronically immediately upon being charged for filling a prescription at a participating pharmacy. Emergis would then reimburse the pharmacies for the claim amount, and submit periodic invoices to Great-West. The appellant sought a refund of GST and HST that it had paid on Emergis's fees, on the basis that Emergis was providing a financial service.

Owen J found that that the supply by Emergis came within para. (f.1) of "financial service", but was excluded by s. 4(2) of the Financial Services and Financial Institutions (GST/HST) Regulations (i.e. Emergis was providing administrative services and was not a "person at risk"). He stated (at paras. 107-09):

The group of services making up the single supply by Emergis can be described as administrative services for two principal reasons.

First, the services provided by Emergis to Great-West do not involve any independent decision making by Emergis. ... In essence, Emergis provides a computer system that allows the decision regarding a drug benefit claim to be made in real time, but the decision itself stems from the terms of the group health benefits plan and not from Emergis.

Second, the services provided by Emergis are quintessentially administrative in nature. ... The Assure Card ... does not alter the substance of what is being done, which is established by the terms of the drug benefit plans provided by Great-West to Emergis. ... Emergis is a pharmacy benefits manager and nothing more.

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electronic drug plan adjudication and processing was "quintessentially administrative in nature"
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