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Jens Martin Hoyer, deputy chairman of the AOK Federal Association / Source: AOK Federal Association

Confidential reimbursement amounts only cause additional costs and bureaucracy

Until now, negotiated reimbursement prices for new pharmaceuticals have been transparent. The draft bill for the Medical Research Act (MFG) now stipulates that these prices will be confidential. Jens Martin Hoyer, deputy chairman of the AOK Federal Association, criticizes the regulation and points out that concrete improvements for insured persons and premium payers are lacking:

"The pharmaceutical strategy published by the federal government last year set the goal that the confidential reimbursement amount for new drugs must not lead to additional expenditure or new bureaucracy for the German healthcare system. This very goal is now clearly being missed: Contrary to the announcement, the intended implementation of the confidential reimbursement amount will result in considerably more bureaucracy and additional expenditure for the health insurance funds. Confidential prices will not improve care for the insured anyway.

Under the proposed rule, health insurance companies will have to establish additional administrative structures and plan for significant liquidity shifts to implement subsequent reimbursements – with the risk of lagging behind manufacturers' reimbursements. Thus, the confidentiality of the reimbursement amount already poses a risk of rising pharmaceutical costs.

Furthermore, many instruments that currently ensure the cost-effectiveness of pharmaceutical supply can no longer be implemented in the future. For example, the Federal Joint Committee can no longer identify the most cost-effective appropriate comparator therapy as part of the benefit assessment. Doctors or pharmacies can no longer estimate the costs of a treatment and prescribe or dispense it accordingly at a reasonable price. How the necessary cost-effectiveness of pharmaceutical supply can be ensured in light of these problems is completely unclear.

Finally, it remains completely unclear why the German pharmaceutical sales market should be made more attractive by a confidential reimbursement amount, as claimed in the explanatory memorandum to the law. Given the internationally unique early and broad availability of new pharmaceuticals, the manufacturer's freedom to set prices for market entry without a fourth hurdle, and the continued high spending dynamics in the market for patented pharmaceuticals, this promotional measure by the pharmaceutical industry at the expense of the contributors is neither necessary nor appropriate.

A real improvement and relief for contributors would be ensured if health insurance funds no longer had to pay the high VAT rate on excessive drug prices, but instead the reduced rate of seven percent that we have been demanding for years."

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