GOÄneu: what changes for your private billing

For forty years, private billing in Germany has worked the same way. You choose a Ziffer, then you choose a Steigerungsfaktor, and if the factor is above the Regelhöchstsatz you write a Begründung. Difficulty gets expressed afterwards, in a number between 1.0 and 3.5.

The reform now sitting with the Bundesgesundheitsministerium removes that second step.

That is the change worth understanding. Not the timeline, which will move again, and not the volume projections, which are contested. The mechanical change: Steigerungsfaktoren give way to fixed prices, and the complexity that used to live in the factor moves into the catalog itself.

Where the reform actually stands

In July 2026, the Bundesärztekammer and the PKV-Verband submitted an updated version of their joint draft to the Bundesgesundheitsministerium. The ministry has said it is preparing a Referentenentwurf on that basis. Both organisations consider 1 January 2028 achievable.

Three things that matters for a practice.

No binding date exists. The BÄK's own draft still carries a placeholder where the date belongs. A Referentenentwurf is a working draft from a ministry, not law; after it come the Kabinett, the Bundesrat — whose Länder carry Beihilfe costs and have their own view — and then a transition period. Anyone quoting you a firm start date is quoting a hope.

The current GOÄ applies until it doesn't. There is no changeover to prepare for this quarter. Practices bill today exactly as they billed last year.

The draft is a proposal, not a regulation. It was agreed between the Bundesärztekammer, the PKV-Verband and the Beihilfe carriers, and approved by the Deutscher Ärztetag in 2025. It becomes binding only as a Rechtsverordnung with the Bundesrat's consent — and it can change on the way.

The one change that matters

Under today's GOÄ, two decisions determine what a private case is worth: which Ziffer you bill, and at what factor. The factor is where the work's difficulty gets recognised — the consultation that ran long, the case that was more involved than the position suggests — and the Begründung is where you defend it.

The draft replaces that. Valuations rest for the first time on a betriebswirtschaftliche Grundkalkulation, and the catalog is restructured around Komplexleistungen and Zuschläge across roughly 5,500 Gebührennummern. Difficulty stops being something you apply to a position afterwards. It becomes something the position already contains — or that a Zuschlag beside it contains.

This has a consequence people are not talking about enough: there is, as a rule, no 1:1 relationship between the old GOÄ and the new one. The PKV-Verband states this plainly. A position you bill weekly today may not have a single successor. Mapping tables that promise otherwise are selling comfort.

What it does to the daily decision

Today, if you are unsure whether a case was straightforward or demanding, you have a release valve: bill the position, set the factor, justify it. The decision can be corrected at the end, in the Rechnung.

Take the factor away and there is no release valve. The whole decision moves to the front — to which position you select. And a position that carries complexity in its own definition can only be selected if what happened is actually visible in the record.

Which means the note stops being the paperwork behind the bill and becomes the thing that decides what the bill can say.

That is not a new principle. It is the existing principle, with the escape hatch closed. The Begründung was the place where thin documentation could still be rescued by good prose. Under fixed prices, there is nowhere to write the prose.

What to do now — and what not to

Don't restructure anything. The text is not final. Any practice reorganising its billing around a draft is optimising for a document that will change.

Don't buy readiness. A regulation whose Referentenentwurf has not been published cannot be implemented in software yet — by anyone. What can be prepared is the practice's own habits.

Do notice which habits are about to expire. Two in particular. If your billing leans on Analogziffern for services the 1982 catalog never anticipated, the reform's purpose is to make most of them unnecessary — the Bundesregierung has itself pointed to the disputes analogue billing generates as a reason for reform. And if factor-setting has become routine in your practice — a default that rarely varies — that routine has no successor at all.

Do write down what actually happened. Time spent, what was discussed, what made a case more involved than the standard one. Under the current GOÄ that supports your factor. Under the draft it supports your position. It is the one preparation that pays under either regime, and it costs nothing but attention.

The honest uncertainty

You will read that the reform means more Honorar. You will also read that particular Fachgruppen face losses. Both claims circulate, both draw on figures attached to earlier versions of a draft that has since been revised twice, and neither can tell you what will happen to your practice — because that depends on your specialty, your service mix, and a catalog structure that does not map onto the one you bill today.

We are not going to give you a number. When the Referentenentwurf is published and the catalog is fixed, the arithmetic becomes possible per specialty, and we will publish ours with the method attached. Until then, anyone offering you a percentage is estimating.

Sources
Bundesärztekammer, GOÄ-Novellierung (updated draft submitted July 2026; ~5,500 Gebührennummern; draft public since January 2026) · PKV-Verband position paper (betriebswirtschaftliche Grundkalkulation; no 1:1 relationship between old and new; Komplexleistungen and Zuschläge) · joint BÄK/PKV-Verband press statement, 31 July 2026 (1 January 2028 considered achievable; BMG preparing the Referentenentwurf).