financial stabilisation act
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The Financial Stabilisation Act is unlikely to offer the savings that were promised


DAK-Gesundheit, a health insurance company in Germany, published their AMNOG 2023 report on the 1st March and have concluded that the GKV Financial Stabilization Act will only allow for minor savings. 

On 1st March, DAK-Gesundheit gave a presentation of their company’s AMNOG Report, during this presentation Andreas Storm, CEO of DAK-Gesundheit commented “The results of the AMNOG Report 2023 show what was already widely suspected in autumn of last year: the planned AMNOG measures, in particular the retroactive effect of the reimbursement amount and the lowering of the orphan drug threshold, generate minor additional savings, but do not solve any structural problems” 

Here is a summary of what DAK-Gesundheit predict the savings to be compared to what was originally proposed: 

Cost saving measureGovernment Predication  DAK-Gesundheit Prediction (based on historical data) 
Increased retroactive reimbursement amount (from the 13th month to the 7th month after the market entry of a drug) €150 million €100 million 
Reduced threshold for orphan drugs (€30 million from €50 million) €100 million €30 – 40.5 million 
Discounts of 20% to combination products €185 million Not calculable until greater clarity is given on the criteria 

DAK-Gesundheit raise the point that covering the cost of developing pharmaceuticals is of great importance for the financial stability of the statutory health insurance system (GKV) as a whole. And therefor from their viewpoint, there must be further development – and not continued AMNOG moratoriums. 

On the point of how the financial issues can be tackled in healthcare in Germany, Storm commented that the GKV Financial Stabilization Act can only represent an interim solution and that “There should be an evaluation next year, which must be followed by a real AMNOG amendment that tackles the structural problems in a sustainable manner“. 


  1. AMNOG Report 2023. DAK Gesundheit. Accessed 2nd March 2023 
  1. AMNOG Report 2023 Das GKVFinanzstabilisierungsgesetz und seine Auswirkungen. Prof. Dr. Wolfgang Greiner. Accessed 2nd March 

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