Statement by the Joint Diagnostics Commission of the DVV and GfV on the planned amendment to the German Medical Fee Schedule (GOÄneu) and its impact on virological diagnostics

22/10/2024

After more than 40 years, the planned amendment to the German Medical Fee Schedule (GOÄneu) represents a significant change in the structure of medical billing. While the strengthening of the disciplines involved in direct patient care is to be welcomed, the amendment entails considerable negative adjustments at the expense of the technical disciplines. In particular, the significant reduction in service remuneration in these areas raises considerable concerns. The lack of transparency regarding the negotiations, the tight deadlines and the inconsistent image of the medical profession, especially the technical disciplines, are further points of criticism that we share as a virology society.

Our fundamental concerns include the following points:

  1. Increased personnel and material costs: In a healthcare sector already affected by rising personnel costs, the reduction in revenue in technical subjects means additional financial pressure. This burden will have a negative impact on the personnel structure and the quality of care, particularly in areas such as laboratory diagnostics, which is dependent on highly qualified personnel. In addition, some of the new figures do not cover costs in any way. In recent years, there have been massive increases in material costs on the part of laboratory diagnostics manufacturers, which have not been taken into account. In addition, laboratories are also faced with energy and general cost increases.
  2. Additional costs due to the IVDR: With the implementation of the new In Vitro Diagnostics Regulation (IVDR), the elimination of so-called in-house test procedures (= laboratory developed tests (LDTs)) will lead to considerable additional costs. These LDTs are a central component of diagnostics, especially in highly specialized laboratories (e.g. diagnostic laboratories at university hospitals, consulting laboratories or national reference centers). The restrictions on the use of LDTs jeopardize innovation and the rapid development of specialized diagnostics (also with regard to pandemic prepardness) and increase costs through alternative tests with EU approval. A reduction in revenue does not reflect this development in any way.
  3. Specialdiagnosticsat university hospitals: University hospitals play a central role in carrying out special examination procedures that are of great importance for the Public Health Service (ÖGD), among others, such as tests for Mpox, measles and other highly contagious diseases. Specialized procedures also play an important role for immunosuppressed patients who are treated at the university's maximum care facilities. These tests are often not offered in private laboratories due to the rarity of their requirement. Insufficient funding will mean that these important examination procedures will no longer be available to a sufficient extent, which will considerably weaken public healthcare and university healthcare.
  4. Reductionofdiagnosticsto high-throughput analyses: In order to reduce costs, there will be an increased focus on high-throughput analyses. However, this standardization comes with the risk that individualized, personalized and evidence-based diagnostics will be neglected. This worsens the care of highly vulnerable patient groups, such as immunocompromised patients in adult as well as pediatric and adolescent medicine, who are preferably treated at university centers.
  5. Development andinnovation in university medicine: University hospitals and research institutes play a key role in the development of new diagnostic procedures and technologies. A reduction in remuneration in the technical disciplines jeopardizes the necessary financial resources to drive these innovations forward. This will set Germany back significantly in international comparison in medical research and development.
  6. Loss of quality and deterioration in care: There is a high risk that costly examination methods, which are necessary for precise and high-quality diagnostics, will be discontinued due to a lack of financial viability. This will lead to a significant deterioration in care, particularly for complex or rare diseases that rely on specialized tests.
  7. Threat toemergencydiagnostics: The potential threat to emergency diagnostics is particularly worrying. It is to be feared that diagnostic procedures that have to be available at weekends or in the evenings will be significantly restricted in their provision due to the loss of revenue. This poses a serious risk to patient care.
  8. Shiftingdiagnosticsto the outpatient sector: An increasing shift of diagnostics to the outpatient sector will be accompanied by a loss of high-quality diagnostics. Many specialized tests require technical equipment and specialist expertise that is not available in the outpatient sector to the same extent as in specialized laboratories. This will lead to a significant deterioration in patient care.

Conclusion: The amendment of the GOÄ results in considerable financial restrictions for virological diagnostics and other specialized technical procedures. These measures jeopardize the quality of patient care in Germany and will lead to massive gaps in care, particularly in the area of specialized diagnostics. A strict revision of the current draft of the GOÄ is urgently required in order to avert damage to patient care, but also to Germany as a location for research and innovation.

For the Joint Diagnostics Commission of the DVV/GfV
PD Dr. Nadine Lübke and Prof. Dr. Marcus Panning, Düsseldorf and Freiburg on 01.10.2024
(Chairwoman of the Joint Diagnostics Commission of the DVV/GfV)