GeSY Imposes €231,300 in Fines on 49 Healthcare Providers

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Penalties issued between January 2025 and June 2026 included major sanctions for billing irregularities, coding errors and insufficient clinical documentation.

The Health Insurance Organisation (HIO) imposed administrative fines totalling €231,300 on 49 healthcare providers between January 2025 and June 2026, according to an analysis of enforcement decisions published by the organisation.

For 2025, fines reached €166,800 and involved 38 providers, while during the first six months of 2026, administrative penalties amounting to €64,500 were imposed on 11 providers. During the corresponding period in 2025, fines totalled €81,300 and involved 25 providers.

The cases spanned almost the entire spectrum of GeSY services, including hospitals, personal and specialist doctors, dentists, physiotherapists and other healthcare providers.

In several instances, the findings resulted from targeted or random audits conducted by the HIO. Other investigations were initiated following complaints from beneficiaries or through cross-checking information recorded within the GeSY information system.

Largest fines imposed

The largest individual fine during the period, amounting to €30,000, was imposed on a plastic surgeon. According to the HIO, compensation claims submitted by the provider included identical photographs attached to claims for different beneficiaries, while the photographic documentation did not allow for patient identification.

A separate €30,000 fine was imposed on an inpatient care provider in a case involving the non-submission of claims for services provided to GeSY beneficiaries, failure to use the information system and alterations to patient histories resulting from the non-registration of relevant claims.

According to the HIO's decision, the case involved a series of omissions in the management and recording of cases, resulting in significant deviations from obligations arising from participation in GeSY.

Two additional fines of €15,000 were imposed. The first concerned an inpatient obstetrics and gynaecology provider for incorrect coding of cases that resulted in increased reimbursement payments. The second was imposed on a urologist for incorrect use of DRG coding in inpatient claims.

Among the larger sanctions was also a fine of up to €12,000 affecting providers in oncology and related specialties for submitting outpatient claims simultaneously with inpatient day-care services.

A further €5,000 fine was imposed on an orthopaedic specialist following beneficiary complaints concerning claims that were not adequately supported by clinical notes.

Common categories of violations

Analysis of the cases shows that the largest share of penalties was linked to reimbursement claims and incorrect coding practices, a category covering approximately 20 cases and accounting for the highest monetary penalties.

These cases included:

  • Incorrect or unjustified claims
  • Duplicate billing
  • Improper use of DRG codes
  • Practices resulting in reimbursement levels higher than those permitted under GeSY regulations

This category accounted for the most significant financial sanctions imposed by the organisation.

Documentation and prescribing issues

A second major group of cases involved insufficient documentation, including:

  • Inadequate clinical notes
  • Missing supporting documentation
  • Deficient photographic evidence
  • Failure to justify medical procedures

These issues appeared in approximately 14 cases across various medical specialties.

The HIO also identified a significant number of violations related to prescribing practices, including:

  • Prescription of medicines outside approved indications
  • Exceeding approved quantities or dosages
  • Prescribing without sufficient therapeutic justification

Specialties most frequently appearing in decisions

Among the medical specialties most frequently cited in HIO decisions were:

  • Orthopaedics
  • Obstetrics and Gynaecology
  • Radiodiagnostics

However, this does not necessarily mean these specialties received the highest fines, as the largest penalties were primarily associated with cases involving increased reimbursement claims and incorrect coding practices.

Recovery of improperly paid funds

In addition to administrative fines, the HIO proceeded in 2025 with the recovery of improperly paid amounts totalling approximately €167,360.