SGK Reimbursement under the SUT: Lists and Co-Payment Rules

1. Key takeaways

Reimbursement in Turkey is a separate world from registration: once a device is on the market, its commercial fate is decided by the rules of the social insurance system. This article summarises the governing communiqué, the pricing formula, the invoicing rules inside and outside the packaged payment system, the exception list for high-value implants, and the patient co-payment rules.

• The reimbursement side of the Turkish health system is governed by the Health Implementation Communiqué (Sağlık Uygulama Tebliği, SUT), first published in Resmî Gazete on 25 March 2010 (mükerrer issue; the existing literature cites it as Sayı 27532 Mükerrer, while the cross-reference of the same day’s index gives 27533 Mükerrer; when citing, it is advisable to state this discrepancy as well).
• The pricing mechanism is points × coefficient: the Health Services Pricing Committee determines the points, and the procedure fee equals the points multiplied by the coefficient (Madde 4.2/16; the coefficient in the text obtained for this verification is 0.593, a figure that is adjusted by committee decisions, with the latest publication prevailing).
• In the inpatient setting, apart from consumables on the EK-5/B list, the remaining consumables may be invoiced separately (Madde 4.2.2.A/2); items outside the EK-8 / EK-9 lists or without an included amount may likewise be invoiced separately (Madde 4.2.1.B.1/2).
• The exception list for high-value implants is written in Madde 4.2.2.B-5: coronary stents, heart valves, pacemakers and their electrodes, various joint and spinal implants, various vascular grafts and transplant / shunt materials, bone cement, external fixators and the like are not included in the diagnosis-related packaged payment and must be invoiced separately.
• The patient co-payment rules are written in Madde 3.2.3/2: external prostheses / orthoses carry a co-payment of 10% (for income or pension earners) or 20% (for others), capped at 75% of the gross minimum wage on the day of collection; medical disposable consumables carry no co-payment (Madde 3.2.5/9).
• Current amendment milestone: the SUT Amendment Communiqué published in Resmî Gazete on 29 June 2026, No. 33295, together with two Health Services Pricing Committee decisions of the same day.

2. Legal basis

The reimbursement rules rest on the SUT and its amendment communiqué, cited below with the gazette references and the specific articles and annex lists on which every point above relies. Because the SUT is amended frequently, the amendment row matters as much as the original one.

3. Expert insights

Insight one: reimbursement compliance is a matter of list management, not of price negotiation. Whether a product is reimbursed and how it is reimbursed depend on which list the product sits in and on the treatment prescribed for that list. The first step for a company is therefore not to negotiate prices but to determine the list category its product belongs to (EK-5/B, EK-8, EK-9, or the high-value implant exception list). Everything else, including pricing strategy and invoicing behaviour, follows from that classification.

Insight two: the separate-invoicing rule for high-value implants changes the business model. Products listed in Madde 4.2.2.B-5 do not run through the diagnosis-related packaged payment but are invoiced separately. This means that purchasing and usage decisions at the hospital side are more sensitive to price, and the focus of commercial negotiation falls on positioning within this list. Whether a product is on the exception list or not determines which conversation the company is actually having with its hospital customers.

Insight three: the co-payment ratios shape demand elasticity at the patient level. The distinction between 10% and 20% for external prostheses / orthoses, together with the cap of 75% of the gross minimum wage, directly affects affordability for patients. When running market calculations for products of this kind, converting that cap into a current monetary amount is more useful than estimating ratios, because the cap is the number that actually binds in real transactions.

4. Practical recommendations

• First perform the list positioning: confirm whether the product falls within EK-5/B, EK-8, EK-9 or the high-value implant exception list, and record the determination in the product file so that downstream invoicing decisions reference it.
• Run pricing calculations with the actual formula of points × coefficient, and always use the coefficient published in the latest decision of the Health Services Pricing Committee, since the coefficient moves with committee decisions.
• For products involving patient co-payments, convert the cap of the gross minimum wage × 75% into a current monetary amount and write it into the commercial plan, so that affordability is discussed in concrete figures rather than percentages.

5. Verification checklist

• □ The citation format of the SUT has been confirmed (stating the coexistence of Sayı 27532 and 27533 in the gazette index).
• □ The list to which the product belongs has been located (EK-5/B / EK-8 / EK-9 / high-value implant exception list).
• □ Calculations use the coefficient published in the latest decision of the Health Services Pricing Committee.
• □ For products involving co-payment, the 10% / 20% rates and the cap of 75% of the gross minimum wage have been applied.
• □ It has been checked whether the amendment of 2026-06-29, Sayı 33295, affects the product line.

Regulatory information verified as of 29 October 2026. The SUT provisions, ratios and the latest amendment issue cited in this article were checked against the original texts of the Turkish Official Gazette; the coefficient 0.593 was taken from the text seen during this verification, and the coefficient is adjusted by decisions of the Turkish Health Services Pricing Committee, with the latest publication prevailing.

How GRZAN can help. GRZAN provides medical device and IVD registration, quality system, authorised representative and local testing support for the Turkish market. Our team coordinates authorised representative and importer arrangements, and supports post-market vigilance obligations. Business enquiries: info@grzanglobal.com