Pricing of healthcare services: who sets what the NFZ pays.

Before the National Health Fund (NFZ) pays for treatment, someone has to set its price. This was meant to be done by an independent agency calculating actual costs. In practice most prices are set by the payer itself, and the price misses the cost in both directions: sometimes the hospital loses money on the patient and sends them to the waiting list, sometimes a procedure becomes a source of profit.

Pricing treatment is genuinely difficult, and we do not accuse anyone of bad faith. We describe a process that was meant to be independent and based on costs, and for the most part is not. The consequences — waiting lists where too little is paid and excess where too much is paid — are borne by patients and taxpayers.

Four figures to start with

Who sets the price

Since 2015 the prices of services have been calculated by a separate institution — the Agency for Health Technology Assessment and Tariff System (AOTMiT). The separation was deliberate: one body calculates the cost, another pays, so that the buyer does not decide on its own how much it will pay. The agency collects cost data from facilities, calculates the tariff from them and announces it in a notice. The NFZ then transfers it into its orders and contracts¹ — in one of the recent changes this meant 11 orders and about 35,000 contract annexes, the NFZ explains.²

According to the Supreme Audit Office (NIK), this division worked mainly on paper.³ In 2015–2020 the independent tariff covered about 17% of the value of NFZ services, and tariff-setting plans were carried out in 32.6%. The remaining prices were set by the payer: since 2017 the President of the NFZ raised prices a dozen or so times — in the Office’s assessment without a reliable analysis of costs, and in some cases without the authority to do so, even changing tariffs set by the Agency. There was also no single standard of cost accounting for all hospitals, so even the data from which the tariff is built were calculated in different ways. These are the findings and assessment of the Office, not a court judgment.

Since the price is only loosely tied to the cost, it drifts away from it — in both directions. How the tariff turns into a transfer to the hospital is described in our text on how the NFZ pays hospitals.

Too low: the hospital pays extra for treatment

When a procedure is priced below its cost, the hospital loses money on every patient — so it admits fewer of them, and the waiting list grows. In 2018 the minister of health admitted that only about 20% of JGP groups (Diagnosis-Related Groups) had been correctly priced, and announced that the others would be recalculated. The trigger was an audit of several institutes, including the oncology institute: they were failing to balance their budgets not because of bad management but because of underpriced services, Rzeczpospolita reported.⁴

The underpriced procedures named at the time included cataract operations (a wait of more than a year and a half even in urgent cases), treatment of acute coronary syndromes and unstable angina, and planned unblocking of arteries. A price that is too low does not treat anyone; it only lengthens the waiting list. Someone covers the difference anyway — it comes back as hospital debt.

Too high: the procedure attracts facilities

The gap also works the other way. A procedure priced above its cost “pays” better than others, and facilities are more willing to perform it. The payer itself admits this: defending the changes in surgery in 2024, the NFZ and AOTMiT calculated that funding rises by PLN 1.18 billion (≈ €268 million) a year (about 20%) and that 77 of 83 groups have a higher price. In their statement they called this plainly profits for hospitals.⁵

In the same package the Association of Polish Surgeons (Towarzystwo Chirurgów Polskich) warned that some procedures had been cut below cost: colorectal resection by about 27%, some endoscopic procedures by about 50%.⁶ Both sides are right at the same time: the average increase hides local cuts. The price does not result from a hard measurement of cost, but from dispute and negotiation.

This is seen most clearly in an older example. From January 2014 the NFZ lowered the price of cataract operations — by about 30%, depending on the type of procedure. In the first two months of the year the number of procedures rose, while their total value fell:⁷

On average one procedure thus became about 22% cheaper (we calculate this from the value and number of procedures). Since more procedures were performed for less money after the cut, the earlier rate had a considerable margin above cost. This is our conclusion from comparing the figures, not a quotation from the source.

Waiting lists depend on more than the price

The cataract story has a sequel, which shows that a waiting list depends on more than the price of a single procedure. In 2015–2017 some patients waiting for cataract surgery went abroad — 93% of them to Czechia. The EU directive on cross-border healthcare allows this: the patient pays the foreign clinic, and the NFZ reimburses them up to the amount it would have paid for the same service in Poland.⁸ The reimbursement is therefore calculated according to the Polish price. In 2017 patients submitted 14,433 reimbursement claims for procedures in Czechia, worth more than PLN 30.9 million (≈ €7.01 million).⁹

The NFZ then increased the value of its cataract contracts, that is, the pool from which it buys procedures: by 4% in 2016 and by more than 30% in 2017. Between 2015 and 2017 the number of procedures in Poland rose by 73,192, and by the end of 2017 the waiting list was shorter by more than 40,000 people (compared with January 2015). Yet the trips abroad did not decline. The authors of the analysis point to one of the reasons: abroad the patient could pay extra for a better lens, while in Poland the price and the regulations in practice did not allow this.⁹ More money shortened the waiting list for one procedure, but it was the price, together with the regulations, that determined which lens a patient would get at home. The NFZ started funding the toric lens, which corrects astigmatism, only from July 2018.⁹

When the tariff chases wages rather than costs

There is one more track on which pricing comes loose from the cost of the procedure — because it serves a different purpose. The act on the minimum pay in healthcare, as worded in 2022, requires minimum salaries, calculated from the average wage in the economy, to be raised every year. So that hospitals have the money to pay them, the President of AOTMiT recommends raising prices every year. According to the 2026 recommendation, tariff increases to cover statutory pay will raise NFZ spending by about PLN 9.25 billion (≈ €2.1 billion) over 12 months: from 1 July the minimum for a specialist is PLN 12,910 (≈ €2,930), and for a doctor without a specialisation PLN 10,595 (≈ €2,400) gross.¹⁰

The rises themselves follow from the act — this is the law, not an abuse. The problem lies in the mechanism. Rising pay has to be covered from somewhere, so prices are raised. Higher prices go to hospitals and are mostly spent on the same pay. And because the minimum rises every year, the tariff rises every year too. Pricing stops answering the question of how much a procedure costs and starts answering the question of how much has to be added to salaries.

Politically this is convenient, because the rises do not require reaching into the state budget. But it blurs the only signal by which one could tell where we pay too little and where too much. That this is a stopgap is shown by the fate of an earlier solution: the so-called 16% mechanism of 2022 was phased out after a year.¹¹ The cost of the pay act is about one third of the NFZ plan — we show it in our overview of the NFZ budget.

Price can also reach pay by a shorter route: through the doctor’s contract with the hospital. Auditing 22 hospitals in 2011–2014, NIK described contracts in which pay was calculated as an hourly rate, as a commission on services paid for by the NFZ, or as both. The amount of the commission depended on how the NFZ priced the procedure and on the supply of specialists, and the hospital paid it regardless of its own costs. The Office called this “a kind of privatisation of NFZ contracts” and noted that even highly priced procedures did not guarantee the hospital a profit.¹²

This model also appeared later. In a 2019 call for offers, a clinical hospital in Lublin allowed a rate for an outpatient-clinic doctor of up to 60% of the value of the procedure under its NFZ contract, reduced by the cost of tests ordered.¹³ This is the ceiling in the call, not proof of how much anyone actually received or of how common the model is. Under such a contract every change in the price immediately changes the doctor’s pay, while the hospital still bears the rest of the cost of treatment. We describe contract models in our text on contract vs employment.

Can this be checked from outside

The price depends on the cost data of facilities. Can a citizen see them? Partly.

The reports and the rules for collecting data are described in the AOTMiT BIP,¹⁴ and the judgment on financial statements by Prawo.pl.¹⁵ To be fair: we found no position of NIK or of the Commissioner for Human Rights (RPO) that directly assessed the transparency of the AOTMiT cost data themselves. A more recent NIK report on the Agency concerns its finances, not the transparency of tariffs. The direction, however, is the same as in other texts on this site: public money can be traced to an aggregate amount, but not to an individual component.

Notes 15laws, data and statements we relied on

1. Rynek Zdrowia, “Zmiana grup i taryf w leczeniu szpitalnym — nowe zarządzenie NFZ” (“Change of groups and tariffs in hospital treatment — a new NFZ order”, in Polish), 2023 — new internal medicine tariffs from January 2023 and their annual cost. ↩

2. NFZ, “Rekomendacja AOTMiT i 35 tys. aneksów — jak wchodzą w życie nowe stawki” (“The AOTMiT recommendation and 35,000 annexes — how the new rates come into force”, in Polish). ↩

3. NIK, “Wyniki kontroli taryfikacji świadczeń opieki zdrowotnej w latach 2015–2020” (“Results of the audit of tariff-setting for healthcare services in 2015–2020”, in Polish). ↩

4. Rzeczpospolita, “Przez złą wycenę procedur szpitale nie mają za co leczyć” (“Because of poor pricing of procedures, hospitals have no money to treat patients”, in Polish), 2018. ↩

5. NFZ, “Stanowisko AOTMiT i NFZ w sprawie listu otwartego Towarzystwa Chirurgów Polskich” (“Statement of AOTMiT and the NFZ on the open letter of the Association of Polish Surgeons”, in Polish). ↩

6. Rynek Zdrowia, “Spór o wyceny w chirurgii — lekarze alarmują, NFZ i AOTMiT odpowiadają” (“Dispute over prices in surgery — doctors sound the alarm, the NFZ and AOTMiT respond”, in Polish), 2024. ↩

7. Rynek Zdrowia, “NFZ obniżył wycenę, a operacji usunięcia zaćmy przybyło” (“The NFZ lowered the price, and the number of cataract operations rose”, in Polish), 2014. ↩

8. “Ustawa o świadczeniach opieki zdrowotnej finansowanych ze środków publicznych” (Act on healthcare services financed from public funds, consolidated text Dz.U. 2025 item 1461, in Polish), Art. 42b(1) and Art. 42c(1)(1) — reimbursement equal to the amount of funding for the service applied in the NFZ’s settlements with providers. ↩

9. M. Chrobot et al., “Ocena wpływu dostępności do leczenia zaćmy w Polsce w świetle zmian instytucjonalnych” (“Assessment of the impact of access to cataract treatment in Poland in the light of institutional changes”, in Polish), OphthaTherapy 2020, no. 4, pp. 350–353 — the share of Czechia, reimbursement claims (table 3), contract value, number of procedures and waiting list, lenses. ↩ ↩² ↩³

10. Rzeczpospolita, “NFZ wyda miliardy na podwyżki w ochronie zdrowia — minister zatwierdziła wyceny” (“The NFZ will spend billions on pay rises in healthcare — the minister approved the prices”, in Polish), 2026. ↩

11. Prawo.pl, “Nowa wycena świadczeń — AOTMiT zbiera dane o wynagrodzeniach” (“New pricing of services — AOTMiT collects data on pay”, in Polish), 2023. ↩

12. NIK, “NIK o zatrudnieniu w służbie zdrowia” (“NIK on employment in the health service”, in Polish), 21.09.2015 — audit of 22 hospitals, 2011–2014 (to 30 June). ↩

13. 1st Military Clinical Hospital with Polyclinic in Lublin, “Szczegółowe warunki konkursu ofert na udzielanie świadczeń zdrowotnych” (“Detailed terms of the call for offers to provide healthcare services”, in Polish), ref. ZP/K/1/2019 — part 12 (laryngology), outpatient clinic work. ↩

14. AOTMiT, “Taryfikacja świadczeń — raporty i postępowania taryfikacyjne” (“Tariff-setting for services — reports and tariff-setting proceedings”, BIP, in Polish). ↩

15. Prawo.pl, “WSA — sprawozdania finansowe szpitala to także informacja publiczna” (“Regional Administrative Court: a hospital’s financial statements are also public information”, in Polish), 2025. ↩