Letters from APCCOA
Words from Dr. Kohler, our President and founder.
Primary care in Alberta is collapsing — and those who’ve held it together the longest are being left behind.
The AMA and Ministry of Health announced the new Primary Care Physician Compensation Model (PCPCM) as a “25% raise” that would rescue family medicine. It was neither.
It shifted funding away from clinics to direct physician payments, destabilizing the infrastructure that makes primary care possible.
Even the AMA admits that fees haven’t returned to pre-pandemic levels while costs have soared. The result?
Physicians who operate Alberta’s community clinics not as private owners, but as stewards of public healthcare infrastructure are going broke at the end of their careers, while others working within those same clinics often earn more than the people who sustain them.
Let’s be clear: these physicians never did it for profit.
If they were self-interested, they would have walked away long ago, taken contractual work or salaried positions, or closed their doors.
Instead, they poured their own savings and unpaid billings into keeping clinics open for their patients often at personal loss believing that eventually, the AMA or the Ministry would fix what’s broken. That faith has not been rewarded.
Under Alberta’s Medical Profession Act, the AMA has a duty to represent all physicians — including those who operate the infrastructure that keeps the system alive.
By refusing to represent them, or to fund the association that can, the AMA is failing in that duty.
The AMA’s response “take it to the Representative Forum” is circular and redundant. The Forum represents physicians, not the infrastructure they rely on. It cannot fix what the AMA itself broke.
Meanwhile, the income gap between family physicians and specialists has ballooned from 25% to, in some fields, several hundred percent, even as family doctors manage more complexity, paperwork, and chronic care than ever.
This inequity is driving graduates away from family medicine and deepening the access-to-care crisis.
If the AMA cannot represent clinic operators due to conflict of interest, it must fund and empower the association that can APCCOA.
Because if clinics fail, primary care fails.
And if primary care fails, Alberta’s healthcare system fails with it.
— Dr. Andrew Kohler
President, Alberta Primary Care Clinic Operators Association (APCCOA)
Open Letter to the Alberta Medical Association
The recent post from the CEO of the Alberta Medical Association (AMA) gives the impression that all is well in Alberta and that clinic operators simply need better “business arrangements.”
With respect, that could not be further from reality.
I must ask the AMA and its leadership to openly acknowledge three fundamental truths:
1. There are repeated complaints across the province from clinic operators facing financial crisis. These are not isolated “business failures” — they are systemic. Many physicians are now funding public-system primary care out of their own after-tax dollars. Has the AMA recognized these complaints? If so, what actions have been taken, and why has APCCOA not been informed?
2. No other province in Canada has experienced physician fee cuts of the magnitude seen in Alberta, particularly at the onset of COVID-19 when overhead, rent, PPE, and staffing costs were soaring. Are you, and the AMA, truly justifying that this timing and impact were acceptable and require no remedy?
3. Referring to clinic operators as “business people” or “service providers” is inaccurate and misleading. In Alberta’s single-payer system, the government owns the healthcare system and sets the fee schedule. Clinic operators are infrastructure providers within a publicly funded system. Why does the AMA deny that reality?
If the AMA insists that everything is “fine,” we ask it to publish a statement acknowledging:
• The scale of the financial crisis facing clinic operators,
• The unprecedented nature and timing of Alberta’s fee cuts,
• The clear gap in infrastructure and overhead supports compared to other provinces, and
• A plan to rectify these issues in collaboration with APCCOA.
If the AMA cannot respond to these questions — and continues to claim a “conflict of interest” between representing clinic operators and associate physicians — then it must accept the obvious truth: primary care medicine cannot exist without primary care infrastructure; one cannot function without the other.
Evidence of Structural Harm
The AMA’s actions during the Transitional Funding Program (TFP) and Primary Care Compensation Model (PCPCM) rollout have worsened the viability of clinic infrastructure.
By interfering with existing business arrangements, the AMA destabilized the traditional flow of funds. Billings once routed through clinics enabling shared overhead and fair distribution are now paid directly to associate physicians.
This shift has altered the power dynamic within clinics. Associates now control revenues and often demand unsustainable terms, while clinic owners continue to absorb rent, staffing, and technology costs.
The result is predictable: conflict, fragmentation, and the erosion of long-standing relationships across Alberta’s family-medicine community. The AMA’s approach has pitted colleagues against each other and accelerated the collapse of infrastructure that took decades to build.
Dereliction of Duty
By Dr. Andrew Kohler, MD CCFP
President, Alberta Primary Care Clinic Owners Association (APCCOA)
Family medicine in Alberta is in crisis.
Between one and two million Albertans no longer have a family doctor.
Clinics that once anchored communities are closing because overhead has exploded rent, staffing, IT, compliance while fees never recovered from the reckless cuts made during COVID, when costs soared and revenues collapsed.
Many clinic owners now earn less than the physicians who work in their clinics. Others are using personal savings just to keep the lights on.
Through emails from Dr. Paul Parks, Dr. Shelley Duggan, and a recorded meeting between APCCOA and AMA leadership Dr. Duggan, CEO Karina Guy, and AMA’s legal counsel it has become painfully clear that the AMA has lost direction and no longer understands how primary care medicine actually functions in Alberta.
The first misunderstanding was astonishing. AMA leadership disagreed when I explained that primary care medicine is not “owned” by physicians it’s owned by the Government of Alberta. That single misunderstanding explains so much of their failed policy. We have a single-payer system. How can clinics operate like small businesses inside a structure that’s, frankly, communistic in its design?
The second error was the claim that the government “doesn’t like for-profit clinics.” That statement is absurd. Every primary care clinic in Alberta was built by entrepreneurial physicians investing their own after-tax dollars not public money. To suggest those same physicians should continue subsidizing the health system privately is not only unrealistic, it’s insulting.
The third claim that the AMA faces a “conflict of interest” representing both primary care physicians and physician-clinic owners is perhaps the most damaging. They fail to grasp that one cannot exist without the other. It’s also hypocritical: the AMA has negotiated for clinic infrastructure before through the POSP and Business Cost Programs.
And finally, the AMA insists it does not involve itself in business arrangements. Yet through the Transitional Funding Program (TFP) and the Primary Care Physician Compensation Model (PCPCM), they directly reshaped those very arrangements. Both programs bypassed clinics entirely, redirected funds straight to physicians, and forced clinic owners to absorb massive financial losses while renegotiating contracts that had worked for years.
The result?
Conflict between clinic owners and associates.
A widening pay gap between family doctors and specialists.
Unsustainable overhead.
And a wave of clinic closures accelerating across Alberta.
APCCOA doesn’t have the exact closure numbers, but the stories from our members paint a very clear picture. There’s a growing shortage of family doctors, and the balance between supply and demand has completely collapsed. Associates often unaware of the true cost of running a clinic now expect unrealistic splits, while some earn more than the owner-operators who built and maintain the facilities they work in.
Clinic owners spend an average of 15 to 18 unpaid hours every week managing operations time that generates no billings simply to keep their doors open. Fees for family medicine are lower than they were five and a half years ago, while overhead has risen far faster than inflation.
What’s even more troubling is that AMA leadership doesn’t just fail to understand these realities they argue against them.
This isn’t just poor policy.
It’s a failure of representation.
It’s dereliction of duty.
And it’s negligence toward the very foundation of Alberta’s healthcare system.
Family doctors already earn the least, yet shoulder the highest overhead. The complexity of care has exploded over the past decade, and the PCPCM model which the AMA promoted as a “25% raise” has only made things worse. The model, copied from other provinces, is a complex bundle of metrics that can easily be manipulated. Even the AMA has since admitted it wasn’t a true 25% raise.
As Dr. Duggan herself later said, it was designed merely as an alternative to fee-for-service not a better one. In reality, it increases administrative burdens, destabilizes clinics, and forces owners to renegotiate agreements with associates who are now paid directly. Once they’re paid, many simply walk away keeping 100% of their billings while working out of clinics built and financed by others.
APCCOA has received multiple complaints about these practices. The AMA has received them too and has been referring them to us. That says everything you need to know.
It’s now obvious that the AMA is not aligned with restoring primary care medicine or making physician-owned clinics viable, sustainable, and capable of growing with Alberta’s rapidly expanding population.
That’s why the Alberta Primary Care Clinic Owners Association was formed — to fill the vacuum of representation for the very physicians who built and fund the infrastructure that keeps primary care alive in this province.
No other group of physicians has been hurt more than clinic owner-operators. Some have gone bankrupt. Others are earning less than their associates. Many have left their billings in their own clinics to pay staff, cashing in savings to keep patients cared for — while waiting for decision-makers to show the decency to fix what’s broken, acknowledge how disrespectful these policies have been, and finally do the right thing.
Alberta’s Primary Care System Is Breaking and No One Is Representing the Clinics
By Dr. Andrew Kohler, MD CCFP
President, Alberta Primary Care Clinic Owners Association (APCCOA)
Across Alberta, family medicine is hanging by a thread.
Between one and two million Albertans now live without a family doctor. Clinics that once anchored communities are closing as fees stagnate and overhead explodes- rent, staff, IT, regulation compliance, etc. Many clinic owners are working for less than their employed colleagues. Some are simply walking away altogether.
What the AMA Told Us
Earlier this year, APCCOA met with Alberta Medical Association leadership President- Dr. Shelley Duggan, CEO Karina Guy, and legal counsel Matt Serowski. The meeting was recorded with everyone’s consent. In their April 29 letter, the AMA stated that it “represents physicians as professionals… and not specifically physicians as business owners,” explaining that representing both owners and associates “creates a conflict of interest.”
In other words, the AMA does not represent clinic owners even though many of those owners are dues-paying members who provide the very infrastructure the system depends on. The AMA acknowledged the crisis and agreed that APCCOA “is filling a much-needed voice in the health system.” But their solution was limited to templates and webinars. There was no plan to address the structural collapse of community clinics.
Why That Matters
Without clinics, there is no primary care. Every family-medicine visit, every chronic-disease follow-up, every vaccination happens in space that a clinic owner must lease, staff, and maintain. When those clinics fail, patients lose access to- full stop. The AMA’s “conflict of interest” argument might be held legally, but it leaves Alberta’s most essential health infrastructure without representation. Fair representation means balancing interests, not abandoning one side of the table.
What We Proposed
APCCOA has called for a separate funding stream for clinic infrastructure -money that goes directly to operators who keep clinics open. Hospitals and surgical centers receive infrastructure support; family-medicine clinics deserve the same.
Moving Forward
To their credit, the AMA agreed to keep talking. Both organizations committed to find common ground and present joint recommendations to the government. That’s progress, however, talk alone won’t keep the lights on.
What Needs to Happen
1. Create a dedicated infrastructure fund for community clinics.
2. Recognize physician-owned clinics as essential health infrastructure.
3. Include clinic owners in negotiations shaping compensation and sustainability.
4. Close the representation gap so every physician member has a voice.
This isn’t about confrontation, it’s about survival. Family doctors can’t deliver care from empty buildings, and Albertans can’t wait another decade for the system to fix itself. APCCOA will keep collaborating wherever possible, but we’ll also keep speaking out when silence costs Albertans their access to care. Because when the clinics go, so does primary care.
Sincerely,
Andrew Kohler MD CCFP - President of the APCCOA
Healthcare delivery in Alberta has deteriorated so rapidly it feels like whiplash. We once had the best healthcare system in the country—efficient and affordable. Now we face a full-blown access crisis.
Primary care physicians (PCPs) handle over 80% of all healthcare problems. They monitor chronic disease, prevent hospitalizations, and act as the system’s gateway. Yet Alberta has too few PCPs in longitudinal care and the fastest-growing population in Canada. This isn’t just an Alberta issue—Canada is short 23,000 PCPs.
Why? The income gap between family doctors and specialists has grown too wide. PCPs face the highest overhead in medicine (35–40%), yet fees are lower than they were five years ago. Primary care infrastructure—clinics—aren’t government-built or operated. They’re funded by entrepreneurial physicians investing personal savings, only to see business models rendered unsustainable.
Alberta’s single-payer model changes fees without warning, while overhead costs skyrocket. Both the AMA and MOH claim they don’t involve themselves in clinic business arrangements, yet through TFP and PCPCM, they’ve reshaped them to the clinic owner’s detriment.
Primary care medicine cannot exist without clinic infrastructure. The AMA, as the sole bargaining agent for physicians—including clinic owners—cannot negotiate one without protecting the other.
The Ministry of Health is the true owner of this infrastructure. It must keep clinics viable, sustainable, and scalable. Without action, closures will continue, patient outcomes will worsen, and Alberta will keep losing the competition for new doctors.
Fixing the system starts with fixing how we support primary care.
No group of physicians has been more marginalized than clinic operators—those who invested their own money to build the infrastructure that supports primary care in Alberta. Some have gone bankrupt. Many now earn less than the doctors who practice out of the clinics they created, and all have seen the value of their equity investment become worthless.
Whether by negligence or denial, both the AMA and the Ministry of Health have been complicit in this failure. For years, neither stakeholder acknowledged or acted on the growing crisis—despite repeated warnings. This is why the Alberta Primary Care Clinic Owners Association (APCCOA) was formed: to stand up for those who’ve been ignored while propping up a collapsing system.
The consequences are now clear: an unprecedented access-to-care crisis, and a de facto two-tier system—those with a family doctor, and those without.
Healthcare is not free. It’s funded by taxpayers, and when millions of Albertans can’t access it, the system is not just broken—it’s unfair. Every tax-paying Albertan deserves access to care. That begins with protecting and restoring the infrastructure primary care depends on.
The new PCPCM was launched with big promises—a 25% raise for longitudinal care and a plan to make Alberta competitive again in attracting family doctors. Yet both Alberta Health and the AMA continue to ignore the obvious: primary care medicine cannot function without viable clinics, and clinics cannot survive without sustainable funding.
Unlike other parts of the healthcare system, most medical clinics are built and operated by physicians—long-standing AMA members—using private dollars. These clinics function as small businesses, yet they are being crushed by stagnant fees and operating costs rising well beyond inflation.
The PCPCM does not deliver a real raise. At best, it’s break-even. For clinic owners, it introduces new business arrangement (BA) interference, more risk, more unpaid admin work, and higher overhead—with no compensation for the infrastructure burden. Despite public claims of neutrality, both stakeholders have directly impacted BAs, making clinic ownership even more unsustainable.
No other group of physicians has been so thoroughly siloed and neglected. Many clinic operators are working for no income—or negative income—while dipping into retirement savings just to keep doors open. Some have gone bankrupt. All have suffered undue hardship. That is a dereliction of duty by those tasked with system stewardship.
PCPCM does not restore real income for PCPs to pre-fee-cut levels five years ago. In fact, like the failed TFP, it has increased the barriers to clinic sustainability, deepening financial exposure for those operating vital healthcare infrastructure.
Clinic closures will continue—even as Alberta’s population surges and ERs are overwhelmed by non-urgent and chronically unmanaged patients. The Ministry of Health has assumed effective ownership of primary care infrastructure, but not responsibility for fixing the broken model.
That’s why APCCOA was formed—to advocate for those holding the system together. Momentum is growing. We’ve engaged Alberta Counsel as our professional lobbying firm and now have the attention of both stakeholders.
Why is there a national shortage of 23,000 PCPs? Because of stagnant fees, growing income disparities with specialists, and decades of neglecting primary care and the infrastructure that supports it. Most clinic owners are nearing retirement, and younger doctors have no interest in buying into a failing business model.
Without viable clinics, the system collapses. APCCOA is fighting to stop that.
Fixing health care starts with restoring family medicine as the cornerstone. PCM has been marginalized and neglected by the AMA over the decades.
Having a regular family physician can extend your life. Albertans with a family doctor are healthier, live longer, with less costly, invasive care. The evidence is overwhelming: investing in primary care improves patient outcomes the healthcare system while realizing billions in savings.
1 Significantly lower death rates- from cancer, heart disease, stroke, and other major illnesses. A major 2018 review in The BMJ linked continuity of care with reduced all-cause mortality.
2. Better Access to Care- People with a family doctor are more likely to get timely appointments, faster follow-up, and support, they’re also less reliant on ERs.
3. Early Detection and Prevention- Regular checkups help catch problems early Family doctors provide by far the majority of preventive medicine and treatment of new conditions
4. Effective Chronic Disease Management- Conditions like diabetes, high blood pressure, and obesity are best managed with regular follow-up. Family doctors monitor progress, adjust treatment, to prevent complications.
5. Fewer ER Visits and Hospitalizations- Patients are far less likely to visit emergency rooms or require hospitalization.
6. Whole-Person, Comprehensive Care- Treat patients of all ages and address physical, mental, and emotional health in one setting. They often manage multiple concerns in a single visit.
7. Trusted Relationships- Long-term doctor–patient relationships build trust. Patients feel more comfortable and more engaged in their health which improves outcomes
8. Mental Health Support- Family doctors are often the first to recognize anxiety, depression, or stress—and can provide treatment or referrals before symptoms worsen.
9. Coordination of Services- Family physicians are the gateway into the broader healthcare system
10. Healthier Lifestyles- Patients with a family doctor are more likely to receive regular advice to lifestyle leading to healthier long-term habits.
11 Numerous studies show restoring primary care would realize billions in savings
Finally PCM cannot exist without infrastructure, which is not paid for or operated by tax dollars unlike other healthcare infrastructure.
The AMA has failed to represent Primary Care Medicine which cannot exist without the infrastructure.
The new funding model PCPCM was advertised as a 25% raise.This is flawed. The model is a complex bundle of metrics that are easily misunderstood .There is no provision for rising overhead unlike Fee For Service which includes the BCB, no provision for physician clinic owners and the unpaid time spent on operations.
Contrary to their position of not getting involved with BAs they have yet claim a conflict of interest representing physician clinic owners who are also AMA members. Income disparity with specialties has grown to wide due to poor AMA representation and neglect for PCM.