combination pricing
Insider Insights

More clarity given on the proposed changes to combination pricing in Germany


One measure as part of Germany’s Financial stabilisation Act, which was passed as a cost containment initiative, is the 20% discounts being applied to combination products unless they reach the highest two categories of additional benefit. Until now, limited information has been given about how this will work in practice but earlier this month the German government released some further details. 

So, what did we learn from the document:  

  • The measure will have no effect on the selling price of any product affected, the cost saving for the sickness funds will instead come from retrospective payments  
  • The measure will apply only to drugs with new active ingredients that are used in a combination previously specified by the G-BA 
  • The measure only affects free combinations of drugs (i.e. not packaged together), since fixed combinations are subject to a joint benefit assessment from the outset 
  • The G-BA will be responsible for deciding which combinations the rebates will apply to 
  • There is no plan to extend this to biosimilars as the combination discount only applies to products with new active ingredients 
  • Negotiations will continue between the associations of sickness funds and industry with the agreement of the exact terms to come into effect from 2nd May 2023 


Deutscher Bundestag 20. Wahlperiode. Der Dundesregierung. Accessed 20th March 2023 

Stay in the know, subscribe to our newsletter

Be the first to receive exclusive content on the latest from the pharmaceutical and market access sector.