Pharmeca a.s. provides
services within the scope defined by the following legislative framework:
Act No. 48/1997 Coll.,on
Public Health Insurance and on Amendments to Certain Related Acts, as
amended.
Implementing regulations
(selected):
Decree
No. 376/2011 Coll.,
implementing certain provisions of the Public Health Insurance Act, as
amended,
Notice of the Ministry of Health No. 529/2025 Coll., on the
antigenic composition of vaccines against pneumococcal infections for
vaccination of insured persons over 65 years of age
Notice of the Ministry of Health No. 23/2024 Coll., on the
antigenic composition of vaccines against pneumococcal infections for childhood
vaccination and for insured persons with health risk factors
Notice of the Ministry of Health No. 273/2024 Coll., on the
antigenic composition of reimbursed vaccines for influenza vaccination of
persons over 65 years of age
Notice of the Ministry of Health No. 474/2021 Coll., on the
antigenic composition of reimbursed vaccines against human papillomavirus
Decree No. 432/2025 Coll., on the
determination of the value of a point, reimbursement levels for reimbursed
services, advance payments, and regulatory limitations for 2026
Notice of the Czech Statistical Office No. 159/2018 Coll.,
introducing the CZ-DRG classification of hospitalized patients
Decree No 384/2007 Coll., on
the list of reference groups, as amended,
Decree No 385/2007 Coll., on
the list of medicinal substances intended for supportive or adjunctive
treatment, as amended,
Decree No. 63/2007 Coll., on reimbursement
of medicinal products and foods for special medical purposes, as amended.
Decree No. 618/2006 Coll., issuing
framework contracts, as amended,
Decree No. 134/1998 Coll., issuing
the list of healthcare procedures with point values, as amended,
Decree No. 527/2021 Coll., on
the determination of the amount of reimbursement of expenses for expert
acts and the method for determining the amount of reimbursement of
expenses for expert consultations carried out by the State Institute for
Drug Control pursuant to the Act on Public Health Insurance, as amended,
Decree on the determination of the value of a
point, reimbursement levels for reimbursed services and regulatory
limitations – issued annually for the relevant period,
Government Regulation No. 307/2012 Coll., on
local and temporal availability of healthcare services, as amended.
Act No. 551/1991 Coll.,
on the General Health Insurance Company of the Czech Republic, as
amended.
Act No. 280/1992 Coll.,
on sectoral, professional, company and other health insurance companies, as
amended.
Implementing regulations to the
Health Insurance Acts (selected):
Decree No. 421/2025 Coll., on the
determination of certain contributions from the fund of generally
beneficial activities of the General Health Insurance Company of the Czech
Republic and sectoral, professional, company and other health insurance
companies for 2026, as amended
Decree No. 125/2018 Coll., on
information contained in health insurance plans and outlooks and on the
method of their submission by health insurance companies, as amended
Decree No. 362/2010 Coll., on the
method of providing information on the financial management of health
insurance companies and its scope, as amended
Decree No. 418/2003 Coll., laying
down more detailed specification of the scope and amount of income and
expenditure of public health insurance funds of health insurance
companies, the conditions for their creation, use, permissibility of
mutual transfers of financial resources and their management, the limit of
operating costs of health insurance companies covered from the resources
of the basic fund including the method of calculation of this limit, as
amended
Decree No. 41/2000 Coll., laying
down detailed conditions for the creation and use of financial resources
of the funds of the Military Health Insurance Company of the Czech
Republic for reimbursement of healthcare provided beyond the scope of
public health insurance from the state budget resources of the Ministry of
Defence, as amended
Measure of the Ministry of Health determining
financial performance indicators of health insurance companies for the
relevant year
Act No. 592/1992 Coll.,
on Premiums for Public Health Insurance, as amended.
Implementing Regulation:
Government Regulation No. 357/2025 Coll., on the
assessment base for public health insurance premiums paid by the state for
2026
Decree No. 107/2025 Coll., on
adjustable parameters of redistribution of public health insurance
premiums for 2026 and on the content, structure and format of data for
calculation of the calculated redistribution parameters
Decree No. 65/2025 Coll., on the
method of valuation of costs of healthcare services for the purposes of
redistribution of public health insurance premiums
Decree No. 351/2022 Coll., on
the transfer of data on consumption of medicinal products by insured
persons of public health insurance when changing a health insurance
company, as amended
Price Decision of the Ministry of Health No.
1/2026/OLZP, on price regulation of medicinal products and foods for special
medical purposes
Price Decision of the Ministry of Health No.
2/2026/OLZP, establishing the list of ATC groups of medicinal products
significant for the provision of healthcare, for which the maximum manufacturer
price is determined in the public interest of ensuring availability
Price Decision No. 2/2025/OLZP, on price regulation
of individually prepared medicinal products containing cannabis for medical use
Price Regulation of the Ministry of Health No.
4/2024/OLZP, on the determination of a special distribution margin for
medicinal products released from reserve stock system,
Price Decision of the Ministry of Health No.
3/2026/OLZP of 24 October 2025, on price regulation of medical devices and
in vitro diagnostic medical devices
Act No. 378/2007 Coll.,
on Medicinal Products and on Amendments to Certain Related Acts, as
amended.
Implementing regulation
(selected):
Government Regulation No. 552/2025 Coll., on
conditions for prescribing, dispensing and use of individually prepared
medicinal products containing psilocybin for medical use
Decree No. 457/2023 Coll., laying down
the list of human medicinal products to which the obligation of the marketing
authorisation holder to ensure their supply after the notified date of
interruption or termination of supplies does not apply, as amended.
Decree No. 84/2008 Coll., on
Good Pharmacy Practice, on detailed conditions for handling medicinal
products in pharmacies, healthcare facilities and by other operators and
establishments dispensing medicinal products, as amended,
Decree No. 85/2008 Coll., laying
down the list of medicinal substances and excipients that may be used for
the preparation of medicinal products, as amended,
Decree No. 86/2008 Coll., laying
down the principles of Good Laboratory Practice in the field of medicinal
products, as amended
Decree No. 106/2008 Coll., on
Good Practice for sellers of restricted medicinal products and on the
professional training course for sellers of restricted medicinal products,
as amended
Decree No. 143/2008 Coll., on
human blood, as amended
Decree No. 228/2008 Coll., on
registration of medicinal products, as amended,
Decree No. 229/2008 Coll.,
on the manufacture and distribution of medicinal products, as amended,
Decree No. 236/2015 Coll., laying
down the conditions for prescribing, preparation, distribution, dispensing
and use of individually prepared medicinal products containing cannabis
for medical use, as amended,
Decree No. 329/2019 Coll.,
on prescribing medicinal products in the provision of healthcare services,
as amended,
Decree No. 463/2021 Coll.,
on the detailed conditions for conduct of clinical trials of human medicinal
products, as amended.
Act No 167/1998 Coll,
on Addictive Substances and on Amendments to Certain Other Acts, as amended
Implementing regulation
(selected):
Government Regulation No. 552/2025 Coll., on the
conditions for prescribing, dispensing and use of individually prepared
medicinal products containing psilocybin for medical use, as amended
Government Regulation No. 456/2025 Coll., on the list
of psychomodulatory substances, as amended
Decree No. 448/2025 Coll., on
psychomodulatory substances, as amended
Decree No. 349/2025 Coll., on the
requirements for notifications submitted by persons cultivating opium poppy and
technical hemp, as amended
Decree No. 147/2025 Coll., on specimen
forms and records of psychomodulatory substances and classified psychoactive
substances, as amended
Government Regulation No. 11/2025 Coll., on the list
of classified psychoactive substances, as amended
Decree No. 53/2014 Coll., on
official forms pursuant to the Act on Addictive Substances, as amended,
Decree No. 123/2006 Coll., on
records and documentation of addictive substances and preparations
containing them, as amended,
Decree No. 243/2009 Coll., laying
down the list of persons, including specification of their workplaces, for
whose activities no permit for handling addictive substances or
preparations containing them is required, as amended,
Government Regulation No. 463/2013 Coll.,
on the lists of addictive substances, as amended,
Decree No. 235/2022 Coll.,
on the cultivation and processing of cannabis plants for medicinal use, as
amended,
Decree No 53/2022 Coll., on
the determination of the amount of reimbursement of expenses for expert
acts carried out by the State Institute for Drug Control pursuant to the
Act on Addictive Substances, as amended.
Decree No. 329/2019 Coll., on
prescribing medicinal products in the provision of healthcare services, as
amended by Decree No. 53/2020 Coll., as amended
Act No. 288/2025 Coll., on the
Categorisation of Medical Devices Prescribed on Vouchers Reimbursed from Public
Health Insurance and on Amendments to Act No. 48/1997 Coll., on Public Health
Insurance and on Amendments to Certain Related Acts (the Medical Devices
Categorisation Act), as amended
Act No. 375/2022 Coll.,
on Medical Devices and In Vitro Diagnostic Medical Devices, as
amended.
Implementing regulation
(selected):
Decree No 377/2022 Coll., implementing
certain provisions of the Act on Medical Devices and In Vitro Diagnostic
Medical Devices, as amended,
Decree No. 378/2022 Coll., on the
specimen inspector identification card of the State Institute for Drug Control
pursuant to the Act on Medical Devices and In Vitro Diagnostic Medical Devices,
as amended.
Decree No 379/2022 Coll., on
the determination of the amount of reimbursement of expenses for expert
acts carried out by the State Institute for Drug Control pursuant to the
Act on Medical Devices and In Vitro Diagnostic Medical Devices, as
amended.
Act No 376/2022 Coll.,
amending certain Acts in connection with the adoption of the Act on Medical
Devices and In Vitro Diagnostic Medical Devices, as amended.
Act No.268/2014 Coll.,In
Vitro Diagnostic Medical Devices, as amended.
Act No. 89/2021 Coll.,
on Medical Devices and on Amendments to Act No. 378/2007 Coll., on Medicinal
Products and on Amendments to Certain Related Acts (the Medicinal Products Act),
as amended.
Implementing regulation:
Notification of the Ministry of Health No. 54/2022 Coll., on the
commissioning of the central repository of electronic vouchers.
Act No. 22/1997 Coll., on
Technical Requirements for Products and on Amendments to Certain Related Acts,
as amended.
Act No. 90/2016 Coll.,
on Conformity Assessment of Specified Products when Supplied on the Market, as
amended.
Act No. 325/2021 Coll., on
Healthcare Digitalisation, as amended, and other related acts, as amended
Act No. 372/2011 Coll.,
on Health Services and Conditions for Their Provision (the Health
Services Act), as amended.
Implementing regulations
(selected):
Decree No. 380/2025 Coll., on
emergency medical on-call services, as amended
Decree No. 30/2025 Coll., on
telemedicine health services, as amended
Decree No. 444/2024 Coll., on
healthcare documentation, as amended
Decree No. 373/2016 Coll., on the
transfer of data to the National Health Information System, as amended
Decree No. 70/2012 Coll., on
preventive medical examinations, as amended
Decree No. 39/2012 Coll., on
dispensary care, as amended
Act No. 40/1995 Coll.,
on Regulation of Advertising and on Amendments to Act No. 468/1991 Coll., on
the Operation of Radio and Television Broadcasting, as amended.
Act No 242/2022 Coll.,
on Video-sharing Platform Services and on Amendments to Certain Related Acts (the
Video-Sharing Platform Services Act), as amended.
Act No. 387/2024 Coll.,on
General Product Safety and on Amendments to Certain Related Acts, as
amended.
Act No. 500/2004 Coll.,
the Administrative Procedure Code, as amended.
In proceedings
concerningorphan medicinal products, State Institue for Drug Controla (SÚKL) is authorised to assess the
pharmacoeconomic analyses submitted by the partiesbut does not have the
competence to generate such analyses itself.
Although, in
proceedings under Section 39da initiated at the request of a health insurance
fund, the marketing authorisation holder is not formally subject to an
enforceable obligation to submit pharmacoeconomic analyses of a defined
quality, the assessment of clinical benefit, cost-effectiveness and budget
impact remains a key prerequisite for determining the appropriateness of
reimbursement from public health insurance. The absence of a cost-effectiveness
analysis is therefore considered a material deficiency.
While the results
of the cost-effectiveness analysis (ICER) are not formally applied as a
decision-making threshold, budget impact and value for money considerations
remain implicitly present in the assessment of the public interest.
A declared
intention to conclude budget cap agreements does not constitute a binding basis
for a reimbursement decision unless such arrangements have been incorporated
into SÚKL’s assessment report prior to the issuance of the opinion of the
Ministry of Health.
Individual
reimbursement granted under Section 16 for exceptional cases does not establish
an automatic entitlement to system-wide reimbursement under Section 39da, where
the existence of a public interest constitutes the primary statutory
condition.
Are you interested in reading regular commentaries on decisions by
Pharmeca a.s.? Feel free to contact us.
At Pharmeca, we help you navigate the complex landscape of
pharmaceutical and medical device information. We also offer flexible services
that can be tailored to your needs at any time.
Our market position and experience allow us to support you whenever you
need expert guidance.
A continuously
updated overview of decisions issued by SÚKL and the Ministry of Health in the
field of pricing and reimbursement is available on the Pharmeca a.s. website.
In the field of reimbursement and regulation of foods for special
medical purposes (FSMP) reimbursed from public health insurancewithin
outpatient care, significant changes will take effect from 1 January 2026 based
on the amendment to the Public Health Insurance Act.
New rules for FSMP reimbursement
FSMP will newly
be classified into reimbursement groups listed in the categorisation tree
attached to the Act, based on their composition and intended use (similarly to
medical devices).
The rules for
price and reimbursement regulation are also changing, the new system will take
into account whether a product is categorised (i.e., can be included in the
categorisation tree and is substitutable with reimbursed FSMP) or
non-categorised (i.e., cannot be included in the categorisation tree and is not
substitutable with reimbursed FSMP).
The reimbursement
amount for specific FSMP will be derived from the base reimbursement set by a
measure of general nature for the respective reimbursement group.
A new obligation
is introduced to notify the actual placing on the market and to maintain
detailed records of FSMP.
Transitional period
FSMP reimbursed
at the end of 2025 will continue to be reimbursed under the same conditions and
at the same reimbursement level. This applies until the State Institute for Drug Control (SÚKL) publishes their
new reimbursement within the new system.
The
manufacturer/importer (notifier) of FSMP reimbursed in 2025 must submit a
notification to SÚKL by the end of September 2026, otherwise, the respective
FSMP will cease to be reimbursed.
All
administrative proceedings concerning FSMP that have not been concluded under
the previous legislation will be discontinued as of 1 January 2026.
At Pharmeca, we help you navigate the complex landscape of
pharmaceutical and medical device information. We also offer flexible services
that can be tailored to your needs at any time.
Our market position and experience allow us to support you whenever you
need expert guidance.
As part of the Dawn of the Amendment to the Public Health Insurance Act article series, we have gradually introduced the updates related to medicinal products. In the following article, we focus on...
A health insurance fund may agree with an inpatient care provider on the method
of reporting and reimbursement of medicinal products used in the provision of
inpatient care, for which the fund has negotiated the reimbursement amount and
conditions with the marketing authorization holder or manufacturer.
For the purpose of negotiating the reimbursement amount and conditions between
payers and the marketing authorization holder for medicines used exclusively in
inpatient care, the State Institute for Drug Control (the Institute) will, at
the request of payers or the holder, conduct an assessment of benefits and
costs (analogous to HTA). All entities concerned (including marketing
authorization holders) are obliged to cooperate with the Institute.
Drug lump sums, which are no longer applied in practice, are abolished.
Deductible
co-payments
The conditions for recognizing co-payments for children under 4 years
of age are expanded by defining selected dosage forms and by specifying the
calculation method of the co-payment in these cases.
Reimbursement
of expenses
Changes also apply to the reimbursement of expenses for acts performed
by the Institute, which will no longer apply to applicants requesting an
increase in the maximum price in the public interest or to applicants for
unregistered medicinal products whose use has been authorized under the
Medicines Act.
In brief: the amendment
On 12 August 2025, the amendment to the Act on Public Health Insurance was promulgated in the Collection of Laws as No. 289/2025 Coll. Its general effective date is 1 January 2026, with selected provisions taking effect during 2026 or in subsequent years.
The amendment proposes substantial changes to the regulation of public health insurance. In the area of pricing and reimbursement of medicinal products, it will affect, for example: the process of external price referencing (EPR), the rules on deemed availability, the definition of Highly Innovative Medicinal Products (VILP), proceedings on reimbursement for VILPs and orphan medicinal products (LPVOs) used in combination, contractual commitments with payers, assessment of a product as an LPVO, similar medicinal products, lis pendens (litispendence), the submission of models, and review (revision) proceedings.
The reimbursement mechanism will also change—especially for vaccines and monoclonal antibodies intended for prophylaxis—and a special procedure for immunization medicines will be introduced.
At Pharmeca, we help you navigate the complex landscape of
pharmaceutical and medical device information. We also offer flexible services
that can be tailored to your needs at any time.
Our market position and experience allow us to support you whenever you
need expert guidance.
As part of our new article series, we briefly outline the key changes in the medicines domain linked to the amendment to the Act on Public Health Insurance. This time on the topic of inpatient care...
The amendment
introduces the concept of an “original reimbursed product” and clarifies the
definition of the “first similar product,” for which a marketing commitment
will no longer be submitted; instead, its actual market availability will
trigger an abbreviated revision due to its entry into the reimbursement system.
The Institute will newly assess the appropriateness of therapeutic intervention
for similar products originating from the same marketing authorization holder,
with the aim of preventing circumvention of contractual arrangements.
The conditions for the automatic recognition of an appropriate therapeutic
intervention are defined.
The assessment of market availability of a similar product will now be governed
by criteria focused on the total quantity of all supplied similar products and
by calculating the average monthly volume.
Combination
product
The amendment introduces a significant change in the calculation of
reimbursement for combination products, taking into account situations where
all included active substances are reimbursed individually on the one hand, and
situations where one of the substances is not reimbursed on the other.
In brief: the amendment
On 12 August 2025, the amendment to the Act on Public Health Insurance was promulgated in the Collection of Laws as No. 289/2025 Coll. Its general effective date is 1 January 2026, with selected provisions taking effect during 2026 or in subsequent years.
The amendment proposes substantial changes to the regulation of public health insurance. In the area of pricing and reimbursement of medicinal products, it will affect, for example: the process of external price referencing (EPR), the rules on deemed availability, the definition of Highly Innovative Medicinal Products (VILP), proceedings on reimbursement for VILPs and orphan medicinal products (LPVOs) used in combination, contractual commitments with payers, assessment of a product as an LPVO, similar medicinal products, lis pendens (litispendence), the submission of models, and review (revision) proceedings.
The reimbursement mechanism will also change—especially for vaccines and monoclonal antibodies intended for prophylaxis—and a special procedure for immunization medicines will be introduced.
At Pharmeca, we help you navigate the complex landscape of
pharmaceutical and medical device information. We also offer flexible services
that can be tailored to your needs at any time.
Our market position and experience allow us to support you whenever you
need expert guidance.
As part of our new article series, we briefly outline the key changes in the medicines domain linked to the amendment to the Act on Public Health Insurance. This time on the topic of similar and...
The Ministry of Health of the
Czech Republic (MoH), acting as the appellate authority, examined whether the
submission of two consecutive applications for a change in the reimbursement of
the same medicinal product—applications concerning different therapeutic
indications or reimbursement conditions—constitutes two separate proceedings or
whether they relate to the same matter.
The MoH clearly concluded that
the subject of the proceedings is identical and comprehensive, thereby
upholding the resolution of the State Institute for Drug Control (the
Institute) to discontinue the second proceeding due to litispendence.
At the same time, within the
proceedings, the MoH emphasized that the subject of the procedure is not an
isolated change to a single condition, but always a comprehensive assessment
and determination of a new, complete set of reimbursement levels and conditions
for the given product. The reimbursement level and reimbursement conditions
form an inseparable and mutually interconnected pair.
In its reasoning, the MoH
relied on case law of the Supreme Administrative Court (SAC), particularly on
its view that even an extension of indication (and even a completely new
indication) does not in itself constitute a change to the subject of the proceedings.
According to the MoH, allowing
two parallel proceedings would risk the issuance of two contradictory
reimbursement decisions, which would introduce absolute uncertainty into the
system.
For completeness, we add that under the amendment to the Act
on Public Health Insurance, from 1 January 2026 it will be possible to conduct
two parallel proceedings concerning an extension of reimbursement for the same
product, provided that the application for the later proceeding is submitted
after a decision has been issued in the earlier proceeding, and that both
proceedings are conducted for different indications.
Are you interested in reading regular commentaries on decisions by
Pharmeca a.s.? Feel free to contact us.
At Pharmeca, we help you navigate the complex landscape of
pharmaceutical and medical device information. We also offer flexible services
that can be tailored to your needs at any time.
Our market position and experience allow us to support you whenever you
need expert guidance.
A continuously
updated overview of decisions issued by SÚKL and the Ministry of Health in the
field of pricing and reimbursement is available on the Pharmeca a.s. website.
In-depth
reimbursement revision
Under the new rules, in an in-depth revision in which a significant decrease in
the basic reimbursement compared to the first in-depth revision is
demonstrated, the State Institute for Drug Control (Institute) will carry out a review or, where applicable,
cancellation of the indication restriction, and in certain cases also a
reassessment of the prescribing restriction, depending on the nature of the
medicinal product (Rx, ZULP).
A minimum interval between individual in-depth reimbursement revisions within
the same reference group is introduced in order to minimise excessive
administrative burden on the Institute.
Abbreviated
price and reimbursement revision
The amendment introduces changes to the thresholds relevant for initiating an
abbreviated reimbursement revision, depending on the type of medicinal
products.
Revisions of maximum prices will newly be conducted for products included in
the same reference group.
A deadline for commenting on the assessment report is introduced, excluding the
possibility of submitting an obstruction appeal against the resolution setting
this deadline.
The conditions for initiating a reimbursement revision due to product unavailability
are updated.
As with in-depth revisions, a minimum interval between individual revisions is
set, during which no new revision may be initiated. However, this time
limitation does not apply to revisions initiated, for example, due to the entry
of the first similar medicinal product or the need to ensure the availability
of a fully reimbursed product.
In brief: the amendment
On 12 August 2025, the amendment to the Act on Public Health Insurance was promulgated in the Collection of Laws as No. 289/2025 Coll. Its general effective date is 1 January 2026, with selected provisions taking effect during 2026 or in subsequent years.
The amendment proposes substantial changes to the regulation of public health insurance. In the area of pricing and reimbursement of medicinal products, it will affect, for example: the process of external price referencing (EPR), the rules on deemed availability, the definition of Highly Innovative Medicinal Products (VILP), proceedings on reimbursement for VILPs and orphan medicinal products (LPVOs) used in combination, contractual commitments with payers, assessment of a product as an LPVO, similar medicinal products, lis pendens (litispendence), the submission of models, and review (revision) proceedings.
The reimbursement mechanism will also change—especially for vaccines and monoclonal antibodies intended for prophylaxis—and a special procedure for immunization medicines will be introduced.
At Pharmeca, we help you navigate the complex landscape of
pharmaceutical and medical device information. We also offer flexible services
that can be tailored to your needs at any time.
Our market position and experience allow us to support you whenever you
need expert guidance.
As part of our new article series, we briefly outline the key changes in the medicines domain linked to the amendment to the Act on Public Health Insurance. This time on the topic of in-depth and...