Substitute Health Insurers Continue Reimbursement for Specialized Wound Dressings

Substitute health insurance providers in Germany have announced that they will maintain reimbursement for specialized wound dressings, following a request from the Federal Ministry of Health (BMG). This decision comes after the expiration of a transitional arrangement, with new legislation still pending.

As of early December, the responsibility for determining reimbursement of certain advanced wound care products shifted to the health insurers. The previous transitional period, which allowed for the coverage of specialized wound dressings without additional evidence of benefit, has ended. The anticipated legal framework that would have secured ongoing reimbursement--the so-called Nursing Bureaucracy Relief Act (BEEP)--has not yet been enacted, as it remains under review by the Mediation Committee. Implementation by early 2026 is currently considered unlikely.

To address this legislative gap, the Federal Ministry of Health has requested that insurers temporarily continue covering these products as a gesture of goodwill. The duration of this interim measure remains uncertain, but the ministry is optimistic that federal and state authorities will soon reach an agreement, allowing the necessary legislation to move forward.

Substitute health insurers, represented by their association, have confirmed their compliance with the ministry's request. They will maintain the previous reimbursement regulations, ensuring that insured persons can continue to receive specialized wound care products under the existing benefit principle. No special cost coverage statement is currently required from patients or providers.

Other statutory health insurers, such as AOK, are currently reviewing their positions and are expected to announce their decisions shortly.

For pharmacies, the situation remains complex. As in previous years, when previous transitional periods expired without legislative follow-up, the ministry had similarly called for insurers to act with leniency. In those instances, legal certainty for pharmacies and other providers was only restored once new regulations were enacted, such as the Health Care Strengthening Act earlier in 2025, which extended reimbursement until December 2025.

The German Pharmacists Association has advised pharmacies to continue relying on the official ABDA product database when dispensing wound dressings. Pharmacies are not obligated to supply products outside the scope of this database or in the absence of clear reimbursement guidelines.

The ongoing regulatory uncertainty is partly due to amendments in the Pharmaceutical Directive, which stipulate that specialized wound dressings--those differing from standard bandages, for example, due to antimicrobial properties--are only reimbursed by statutory health insurance if their benefit has been substantiated to the Federal Joint Committee. To date, only a limited number of manufacturers have provided the required evidence, resulting in a series of interim arrangements and extensions in recent years, most recently involving the BEEP legislation.

This regulatory environment underscores the ongoing challenges in ensuring patient access to advanced wound care products in Germany. While substitute health insurers have committed to maintaining coverage for the time being, the future of reimbursement remains uncertain pending legislative action. Stakeholders across the healthcare sector, including manufacturers, pharmacies, insurers, and patients, continue to await a permanent resolution that will provide clarity and stability in the provision of specialized wound dressings.