GOÄneu: what changes for your private billing

For more than forty years, private billing in Germany has worked the same way. You choose a billing code (Ziffer), then you choose a Steigerungsfaktor, and if the factor is above the threshold (2.3; 1.8 or 1.15 in some sections) a written Begründung is required.¹ Difficulty gets expressed afterwards, in a factor between 1.0 and 3.5 (up to 2.5 or 1.3 in some sections).²

The reform now sitting with the Bundesgesundheitsministerium removes that second step for the normal case.³

That is the change worth understanding. Not the timeline, which will move again, and not the volume projections, which the ministry is having checked by an expert report.⁴ The mechanical change: in the normal case, 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.⁵ According to both organisations, the ministry is preparing a Referentenentwurf on that basis. They consider 1 January 2028 achievable.⁶

Three things that matter for a practice.

No binding date exists. A Referentenentwurf is a working draft from a ministry, not law; after it come the federal government's decision and the Bundesrat's consent. 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. The Bundesärztekammer and the PKV-Verband drew it up together. In May 2025 the 129th Deutscher Ärztetag instructed the Bundesärztekammer's board to conclude the talks with the PKV-Verband on the basis of the existing drafts and hand the drafts to the minister;⁷ in June 2025 the draft went to the ministry.⁵ It becomes binding only as a Rechtsverordnung of the federal government with the Bundesrat's consent;⁸ for that, the Bundesärzteordnung and SGB V also have to be amended.³ 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 code 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.³ 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.⁹ A position you bill weekly today may not have a single successor.

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.

Remove the factor, as the draft does for the normal case, and that release valve is gone. 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, in the normal case there is nowhere to write the prose.³

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 "GOÄneu readiness". As long as the text of the regulation is not settled, nobody can build its final version into software. 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 analogue billing codes (Analogziffern) for services a catalog largely dating from the 1980s never anticipated,⁹ the new catalog is meant to replace most of them: according to the PKV-Verband, billing through analogue codes will become "largely unnecessary".⁹ And if factor-setting has become routine in your practice — a default that rarely varies — in the normal case that routine has no successor.

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. For the first three years after entry into force, the Bundesärztekammer and the PKV-Verband project an increase in PKV spending of up to 13.2%;⁷⁹ the ministry is having the impact estimates of the Bundesärztekammer and the PKV-Verband checked by an expert report.⁴ None of these figures tells 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. Until then, anyone offering you a percentage is estimating.