Compulsory licensing applies to patient management software sold in Canada. The definition of "sell" in the Food and Drugs Act is very broad. The Act states "sell" includes offer for sale, expose for sale, have in possession for sale and distribute, whether or not the distribution is made for consideration.
According to an official of Health Canada contacted on this date, this means that any distribution of any patient management software, even if there is no financial transaction, constitutes a sale. This would include patient management software developed for one provincial Ministry of Health and provided to a Ministry of Health in another province (with or without financial charge).