Reimbursement

The Public Health Services Price Tariff: A World Apart from SUT

· Omega Araştırma · 13 min read

The Public Health Services Price Tariff: A World Apart from SUT

Market access debates usually focus on medicines; but hospital services are priced through a second major instrument, the Public Health Services Price Tariff. Based on Fundamental Health Services Law No. 3359, it covers Ministry of Health facilities, state university hospitals, dental faculties and municipal hospitals — the superior regulation setting the public price of services regardless of payer. Read together with the 2025-2026 revision calendar, the health-tourism floor-price mechanism and the SGK Pricing Commission, it maps the full territory of non-drug market access. This article draws that map comprehensively.

Legal basis and scope

The tariff rests on Article 3 of Law No. 3359, the relevant provisions of Presidential Decree No. 1 and the authority article of Law No. 2219 on Private Hospitals. Three features define its scope. First, it covers Ministry facilities, state university hospitals/research centres, dental faculties and — under recent amendments — municipal hospitals and fee-based services in family medicine. Second, the regulation applies regardless of SGK financing: the public service price is a ceiling independent of the paying institution. Third, the latest change extended the scope to price health-tourism and tourist-health services across public and private providers alike.

The annex architecture: a tour from Annex-1 to Annex-8

The tariff is annex-centred, each annex carrying a distinct function: Annex-1 Principles of the price tariffs (the constitution of implementation); Annex-2 the health services price tariff (procedure-level amounts); Annex-2A the price tariff for health tourism and tourist health; Annex-3 simple medical consumables included in procedure points; Annex-4 the physiotherapy and rehabilitation diagnosis list; Annex-5 disability board report pricing; Annex-6 the TÜRKÖK overseas price tariff; Annex-7 the laboratory-animal price list; Annex-8 public health laboratory price lists. Which annex changed says directly which service group is affected.

The 2024-2026 revision calendar: an accelerating cycle

Like the SUT, the tariff now updates in fast cycles: the tariff enacted by the approval of 25.01.2024 was amended on 26.09.2025 (alongside an interim change effective 15.06.2025); then the approval of 16.02.2026 repealed the 2024 tariff entirely and enacted a new one, effective 23.02.2026; a further amendment followed on 28.07.2026. Three major moves in under a year — a tempo that drags facility price management and companies' hospital-economics analysis into a continuous monitoring discipline.

Health tourism: the floor-price + USHAŞ coefficient mechanism

One of 2026's most strategic novelties defines Annex-2 procedure prices as floor prices for patients within health tourism and tourist health, across public and private providers. The mechanism is two-layered: in Ministry facilities, the coefficient applied on floor prices is determined — on USHAŞ (International Health Services Inc.) recommendation — by the General Directorate of Public Hospitals, procedure-by-procedure or list-based; in state university hospitals the same authority rests with the Rectorate. This is the pricing core of the mechanism converting diagnostic and treatment services into tourism revenue, institutionally setting the lower bound of price competition in the international patient segment.

Two consequences follow for companies. (1) Suppliers of devices and medicines working with centres planning service exports should feed the floor-price-plus-coefficient structure into their ROI calculations. (2) Tourism coefficients increase Türkiye's service-cost visibility in international price comparisons; that visibility supports value-based service narratives.

The SGK Health Services Pricing Commission: the private sector's point value

Payments to private facilities working with the SGK are set by decisions of the SGK Health Services Pricing Commission. By assigning values to SUT procedure points, the Commission establishes the basis of private billing; two separate decisions for 2026 were published in the Official Gazette of 29.06.2026. Every point-value update in the public tariff forces a recalculation of private protocols and billing chains — because a private facility's economics balance between the cost structure in the public tariff and the revenue in Commission decisions.

How prices form in the public tariff

Prices in the tariff are expressed as TRY amounts per procedure, applied under the Annex-1 principles. The decisive difference from the SUT: the SUT governs what SGK will pay and its rules; the public tariff sets the ceiling the provider may charge (the official fee schedule). The same operation can carry different amounts in the public tariff and in SUT reimbursement; the gap defines the space of complementary insurance and patient co-payment models. Knowing this distinction is a core competence of facility management and the complementary-insurance ecosystem alike.

Overseas treatment and TÜRKÖK: the rare-disease connection

The tariff's rare-disease connection appears on two headings. Overseas treatment: the SGK's overseas-treatment mechanism covers, under defined conditions, the treatment costs abroad of patients who cannot be treated in Türkiye — with time limits including the rule that the total waiting period may not exceed two years. The TÜRKÖK overseas price tariff: a separate annex prices overseas procedures in stem-cell transplantation. Both mechanisms shape the cost visibility of rare-disease products unlicensed or unsupplyable in Türkiye and should be read together with early-access and Annex-4/C supply processes.

Shared takeaways for facilities and companies

  • Track both calendars together: SUT (drugs + SGK payment) and Public Tariff (service prices) revisions shape hospital economics simultaneously. In device placement, the procedure point/price is part of the device's ROI calculation.
  • Revision protocol: within the first 72 hours after each approval: extract the annex-change table, update billing systems, recalculate tourism-coefficient price lists.
  • The tourism opportunity: the floor-price-plus-coefficient model is the pricing reference for working with centres planning service exports; it disciplines the lower bound in international package pricing.
  • Rare-disease supply cost: overseas-treatment limits and the TÜRKÖK tariff belong in the cost model of rare-disease product strategies.

A monitoring template: what, from whom, when?

TopicSourceFrequency
Public tariff amendmentsSGHSD announcements, Official GazettePublication day
Point values on SUT procedures (private sector)SGK Pricing Commission decisionsOn decision publication
Tourism coefficientsUSHAŞ / GDoPH announcementsQuarterly
Overseas-treatment arrangementsSGK announcementsPublication day

Facility types and the planning context

The universe of facilities subject to the tariff is interwoven with the health system's planning logic. Ministry hospitals (city hospitals included), state university hospitals and research centres, dental faculties and municipal hospitals are the tariff's principal addressees. Although price application is the same across facility types, the revenue-management objective differs: in Ministry facilities tariff revenue flows into budget accounts and links to investment planning; in university hospitals it finances academic and clinical capacity through the revolving-fund mechanism. In recent years, the ambition to grow education-research intensity and high-value procedure volume has put strategic management of tariff revenues on the agenda for both groups. For device and medicine suppliers this means: hospital purchasing decisions are now justified not only clinically but by procedure point/return arithmetic; a supplier whose sales arguments do not sit on this calculation loses in investment committees.

A price strategy for private hospitals: three baselines

The price space of private facilities is shaped between three regulatory lines. First line, SUT/Pricing Commission: the ceiling for bills to payer patients in SGK-contracted hospitals. Second line, the public-tariff logic: the official fee schedule serves as a reference ceiling for consultation and procedure fees; private facilities set their own lists within this frame. Third line, the tourism floor price: for international patients, Annex-2A and the coefficient regulation set the price floor. The space between the three lines defines the revenue mix of fully private patients, complementary insurance and package agreements. Facility management's task is to align this mix with capacity planning: payer volume carries occupancy and cash flow; the private/tourism segment carries margin. Every tariff revision forces this balance to be rebuilt.

How new procedures enter the tariff and SUT: the device company's perspective

Bringing a new diagnostic or therapeutic procedure into reimbursement usually requires two mechanisms working in sequence: defining the procedure point/price (public tariff or SUT annex) and valuing the associated material/device. The critical point for device companies: if the procedure definition does not reflect the technology's mode of use (a new energy source or imaging-assisted application not defined separately), the device cost is buried inside the procedure price and the investment case weakens. That is why, for innovative devices, access work begins before product approval — with procedure coding and valuation strategy: existing prices of comparable procedures, the precedent for requesting additional payment, and hospital-economics simulation. Since proposing new procedures to the tariff takes time with the institutions, early dialogue and evidence preparation are decisive.

Facility operations in revision waves: an implementation protocol

The 72-hour protocol facilities should run after every approval: (1) Diff analysis: a procedure-level change table between old and new tariffs; the list of affected services. (2) System update: updating price tables in the hospital information system, including billing processes, and verifying with test invoices. (3) Tourism lists: recalculating international price lists with Annex-2A floor prices and USHAŞ coefficients; reviewing agency and package agreements. (4) Communication: preparing patient information forms and contract annexes for items not affecting payer patients but changing private price lists. (5) Reporting: estimating the revision's revenue impact by service and product group and presenting it to management. Facilities that fail to institutionalise this protocol pay with invoice cancellations and patient complaints at every revision.

Frequently asked questions: from tariff practice

  • Are the tariff price and the SUT price the same? No; the public tariff sets the official fee a provider may charge while the SUT governs what the payer pays — the same procedure can carry different amounts at the two levels.
  • May a private hospital charge any price? No; the official fee schedule acts as a ceiling and payer-patient amounts follow Commission decisions.
  • Why is there a floor price in health tourism? The floor prevents price competition from dragging quality down for international patients and keeps revenue within the system.
  • Is the USHAŞ coefficient identical across facilities? The coefficient is set by the GDoPH for Ministry facilities and by Rectorates for university hospitals; it may differ by procedure or list.
  • Do revisions affect existing contracts? Revision clauses in package and agency agreements come into play; reviewing contract annexes is the facility's responsibility.
  • Is the device price included in the procedure fee? Depends on the procedure definition; without separate valuation the device cost stays inside the procedure fee — decisive in device selection.
  • What is the time limit in overseas treatment? The total waiting period may not exceed two years; extensions are conditional.
  • Whom does the TÜRKÖK tariff apply to? It prices procedures performed overseas within stem-cell processes.

The tariff's institutional memory: building the monitoring file

Institutionalising tariff monitoring is possible with simple file discipline. Folder 1 — current texts: the tariff and annexes in force, latest approvals, amendment comparison tables. Folder 2 — impact analyses: each revision's revenue effect by service/procedure, split by payer and private patients. Folder 3 — operational records: system-update tests, invoice cancellation/correction statistics, versions of tourism price lists. Folder 4 — institutional correspondence: SGK Commission decisions, information requests and replies. These four folders are the infrastructure enabling 72-hour compliance at every revision; for companies, a similar file (with a product-level procedure-fee map) is the backbone of device/medicine placement strategy. Without institutional memory every revision is learned from scratch; with it, each revision builds on the last.

Step by step: preparing a health-tourism price list

Preparing a price list for the tourism segment is a six-step process. Step 1 — Procedure inventory: the list of procedures the facility sells to international patients (packaged and single). Step 2 — Floor-price mapping: matching Annex-2A floor amounts to procedures; benchmarking against comparables. Step 3 — Coefficient application: updating the floor price with announced USHAŞ/GDoPH coefficients; in university facilities, querying the Rectorate's coefficient. Step 4 — Packaging: converting diagnosis-treatment-accommodation-transfer components into package prices; translating package content into contract language. Step 5 — Agency and partner communication: written notification of list version, validity date and revision conditions. Step 6 — Revision protocol: the 72-hour recalculation and customer-notification flow when the tariff changes. A facility that does not institutionalise this process faces both legal risk and margin loss with wrong offers below the floor; one that does converts tourism revenue into a predictable line item.

An ROI model for device placement: justifying investment with procedure points

Device investments at hospitals are now justified through procedure-point/return arithmetic. A simple ROI frame has five components: (1) Annual procedure-volume forecast: annual patients of the target indication and the device's share. (2) Revenue per procedure: the net amount retained by the facility from current tariff/SUT prices, split by payer-tourism-private. (3) Variable cost per device: consumables, maintenance, service. (4) Fixed investment and depreciation: device cost, installation, training. (5) Payback period and sensitivity: how the table shifts with a 20% deviation in volume assumptions. The supplier that turns this frame into a sales argument answers the investment committee's questions with numbers; one that cannot is rejected all the more loudly the stronger the clinical rationale. Nor should it be forgotten that tariff revisions change this table every time: the supplier should be the party updating the table with its customer after each revision.

Sources and key takeaways

Core sources: the Public Health Services Price Tariff and annexes (25.01.2024; amendments of 26.09.2025, 16.02.2026 and 28.07.2026); SGK Pricing Commission decisions; USHAŞ and GDoPH announcements; Law No. 3359. Recommended monitoring: the GHS price-tariffs page, the Official Gazette and SGK announcements; query tourism coefficients quarterly. Our key takeaways: (1) the public tariff is a regime apart from the SUT — it sets what providers may charge; (2) three 2026 revisions make continuous monitoring mandatory; (3) the floor-price + USHAŞ coefficient mechanism is the pricing core of service exports; (4) procedure points sit at the centre of device-placement ROI — build sales arguments on that table; (5) the institutional memory file (texts, impact analyses, operational records) is the infrastructure of 72-hour compliance.

Practical summary: the tariff team's period checklist

The checklist for every tariff revision runs in two tracks. Facility track (72 hours): (1) the diff-analysis table — which procedures, which services, in which direction; (2) billing-system update and test invoices; (3) verification of payer-patient protocols at new amounts; (4) recalculation of tourism price lists with Annex-2A floors and coefficients, agency notifications; (5) revision of private price lists and contract annexes; (6) the revenue-impact report to management. Company track (supplier): (1) which procedures your product/facility depends on — is the procedure map current; (2) the revision's effect on facility revenue and the ROI shift in your customer base; (3) new procedure/scope opportunities (e.g. device-placement windows where procedures entered coverage); (4) reflection of Pricing Commission decisions on private-sector pricing; (5) rebuilding sales arguments on current amounts. The tracks feed each other: a stronger facility scorecard widens the supplier's table — this shared language turns tariff revisions from risk into opportunity windows.

Conclusion

The Public Health Services Price Tariff is the regulation that forms the core of hospital economics and service exports while living in the shadow of drug reimbursement; the accelerating revision cycle of 2026 has made it an agenda item demanding permanent monitoring discipline. To decode service tariffs, procedure points and Commission decisions for your product or facility together, and to carry tourism pricing mechanisms into your business plan, reach out to Omega Arastirma.