Gender-affirming care

In 2024, the Health Statutes Amendment Act included amendments to the Health Professions Act (HPA) regarding gender-affirming care by the addition of sections 1.91, 1.92, and 1.93. 

Only section 1.91 took effect in 2024 and stated:

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Prohibition of sex reassignment surgery on minors

1.91 A regulated member shall not perform a sex reassignment surgery on a minor.

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Sections 1.92 and 1.93 were not proclaimed into force in 2024. Those sections stated:

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Prohibition of certain drug prescriptions for minors

1.92(1) A regulated member shall not prescribe a Schedule 1 drug within the meaning of the Pharmacy and Drug Act, or any other drug identified in the regulations, to a minor for the purposes of hormone therapy, including puberty suppression and hormone replacement therapy, for the treatment of gender dysphoria or gender incongruence except in accordance with an order of the Minister under section 1.93.

(2) The Minister may make regulations identifying any drug as a drug for the purposes of this section.

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Orders

1.93 The Minister may make orders

1. authorizing the prescription of a Schedule 1 drug within the meaning of the Pharmacy and Drug Act, or any other drug identified in the regulations made under section 1.92(2), to a minor for the purposes of hormone therapy, including puberty suppression and hormone replacement therapy, for the treatment of gender dysphoria or gender incongruence, and
2. respecting any such authorization, including any terms, conditions or limits that apply to an authorization.

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On Jan. 7, 2026, the Government of Alberta proclaimed sections 1.92 and 1.93 as now being in force.

Ministerial Order

Ministerial Order 31/2025, was released on January 8, 2026, and provided the specific and limited circumstances in which hormone therapy may be prescribed to minors for the treatment of gender incongruence or gender dysphoria. The order specifies

1. Continuation of existing treatment – Minors of any age who were prescribed hormone therapy for the treatment of gender dysphoria or gender incongruence on or before January 7, 2026, may continue that therapy.
2. Treatment started outside Alberta – Minors of any age who began hormone therapy for the treatment of gender dysphoria or gender incongruence while their ordinary place of residence was outside of Alberta may continue that therapy regardless of whether it began before or after January 7, 2026.
3. New prescriptions for 16- and 17-year-olds – Regulated members may prescribe hormone therapy to minors aged 16 and 17 years old for the treatment of gender dysphoria or gender incongruence if the three approvals in section 4 are met.
4. Required approvals – Required approvals for section 3 include
   • consent of a parental or legal guardian,
   • approval from a physician registered with the College of Physicians and Surgeons of Alberta authorized to practise in Alberta, and
   • approval from a psychologist registered with the College of Alberta Psychologists who is authorized to practise in Alberta.
5. Renewing or modifying existing prescriptions – Regulated members may renew or modify an existing hormone therapy prescription for a minor who was lawfully prescribed hormone therapy for the treatment of gender dysphoria or gender incongruence. Regulated members may only prescribe a different class of hormone therapy, such as switching from a puberty suppression hormone to hormone therapy or vice versa, if they meet the requirements set out in section 3.
6. Disorders of sex development – Regulated members may prescribe hormone therapy to minors diagnosed with a disorder of sexual development, regardless of a co-existing diagnosis of gender dysphoria or gender incongruence.

What does this mean for pharmacy teams?

• Regulated members can dispense prescriptions for hormone therapy for minors aged 16 or 17 years old for gender incongruence or gender dysphoria in accordance with the Ministerial Order.
• Regulated members may, where appropriate, adapt valid prescriptions for hormone therapy for minors aged 16 or 17 years old for gender incongruence or gender dysphoria by
  • renewing to ensure continuity of care; or
  • altering the dosage, formulation, or regimen.
• For the purpose of this legislation, regulated members may not substitute another drug that is expected to have a similar therapeutic effect. Any change in drug class constitutes a new prescription and must meet all applicable requirements and approvals.
• Regulated members may not prescribe hormone therapy for minors aged 16 or 17 years old for gender incongruence or gender dysphoria at initial access, to manage ongoing care, or in the case of emergency.

Patient assessment and collaboration with the circle of care

As with any patient presenting a prescription, pharmacists are expected to assess the patient in accordance with the Standards of Practice for Pharmacists and Pharmacy Technicians. Where appropriate, pharmacists should collaborate with the patient and their circle of care, including their physician, to ensure care is provided seamlessly to the patient.