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Market access for medical technologies in Belgium

A brief overview of key market access pathways and challenges for medical devices, in-vitro diagnostic tests in Belgium

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Key topics

There is only one key theme describing market access for medical technologies in Belgium: 

  • Reimbursement: payment via composite model, including physician fees for procedures (INAMI/RIZIV Nomenclature or DRG system), ward stay, and individual implants and invasive non-implantable materials

There is no separate funding (approval by the payer) or health technology assessment challenges in Belgium. Elements of HTA are integrated into reimbursement decision-making. 

Belgium has one innovative payment scheme for medical technologies (Restricted Clinical Application for invasive medical devices and implants, Application Clinique Limitée). 

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Reimbursement

Belgium has one of the most complicated reimbursement systems in Europe. It is mainly based on the mixed model of per diem, per procedure (fee for service), and per material used payment:

  • Per diem payment: for hospital ward stays
  • Fee for service: for all services performed (interventional procedures, laboratory and imaging services, etc.)
  • Material fees: for implantable devices, non-implantable consumables, pharmaceuticals

The overall payment made to the hospital is based on the sum of these individual fees, which are incurred during the period of admission.

Reimbursed procedures are listed in the INAMI/RIZIV Nomenclature. Each procedure has associated codes and physician fees for ambulatory and hospital use. 

Invasive non-implantable devices and implants are reimbursed via the so-called “List of benefits” maintained by INAMI/RIZIV. There are eight different models of pricing that are determined within the “List of benefits,” ranging from free pricing to price registered per brand via Nominative Lists.

Since 2019, several low-cost and simple (low-variability) procedures are reimbursed not via individual INAMI/RIZIV codes but via APR-DRGs. The APR-DRG tariff covers only the procedural component (physician fees which are otherwise covered by the INAMI/RIZIV Nomenclature). 

Ward stay, and pharmaceuticals are paid separately in the system.

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Specifics for IVD tests

Reimbursement of laboratory testing includes several components:

  • Fee for individual tests performed using INAMI/RIZIV Nomenclature (usually reimbursed at 25% of the tariff; there are certain exceptions, e.g., genetic tests, where 100% tariff is reimbursed)
  • Lump-sum payment per day of stay (in hospitals)
  • Lump-sum payment per admission (in hospitals)
  • Lump-sum payment per prescription (in out-patient settings)
  • Copayment per test by patients
  • Specific reimbursement projects by INAMI/RIZIV (NGS, gene expression profiling tests, companion diagnostic tests)

The reimbursement tariff is covered by insurance companies at the 25% level for the majority of the IVD tests. The remaining amount is recovered by laboratories via lump sum payments and copayments (depending on the type of settings, e.g., using lump-sum payment per day of stay and per admission in hospital settings).

In order to be reimbursed, IVD tests shall be included in INAMI/RIZIV Nomenclature and/or be part of the specific agreements with INAMI/RIZIV (for specific projects, e.g., on NGS or gene expression profiling tests for early-stage breast cancer).

MTRC has experience with more than 160 projects in Belgium

News and insights

First health apps are expected to enter reimbursement in Belgium by the end of January 2025

In December 2024, MTRC reported that the first health app had entered Level 3+ of the mHealthBelgium validation pyramid, indicating eligibility for regular reimbursement. However, no health apps are currently listed at Level 3 on the validation pyramid. mHealthBelgium clarified to MTRC that the December 2024 listing was part of a visual test to demonstrate how an app would appear at Level 3 on their website. They anticipate that the first apps will officially reach Level 3 by the end of January 2025.

Belgian KCE report on expenditure control measures in DRG-based hospital payment systems

On December 20, 2024, the Belgian Health Care Knowledge Center (KCE) released the Health Services Research report on expenditure control measures in Diagnosis-Related Group (DRG)-based hospital payment systems. The report offers an overview of the current hospital financing model in Belgium, details proposed reforms toward case-based DRG payments, reviews expenditure control mechanisms in five European countries, and provides recommendations to stakeholders.

Changes in the Belgian cervical cancer screening program from January 2025

In December 2024, the Belgian National Institute for Health and Disability Insurance (INAMI-RIZIV) announced changes in the cervical cancer screening program starting from January 1, 2025. The key change is that in people aged 30 to 64 years, an HPV (Human Papillomavirus) test will be the primary for cervical cancer screening instead of a cytological examination. For this age group, HPV tests will be reimbursed every five years.

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