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Analyses

 

Amendments to the Health Care Act establish strict regulation for dual practice

31 July 2025 | Policy Analysis

Context

In May 2025, the Act on Amendments to the Health Care Act entered into force. The Health Care Act is one of the fundamental laws regulating the healthcare system in Slovenia. The amendments introduced relate to several issues, including the non-profitability of providers of public healthcare services, changes to the regulation of concessions (the mechanism though which private providers become part of the public healthcare network), regional management of healthcare services provision, rights of healthcare workers to work for other healthcare providers, redefinition of the selection and work standards for managers in public healthcare organizations, and regulation of prices of healthcare services also for services provided in the open market.

Many stakeholders expressed opposition to several provisions, in particular those related to the prohibition (even for private providers) of profits from providing public health services and the regulation of prices of healthcare services provided in the open market. However, the public discussion around the Amendments to the Health Care Act focused mostly on the intention of the government to provide a clear separation of careers for healthcare workers by limiting the possibility for public employees to also work for private providers. 

Impetus and main purpose of the reform

The government argues that there is a conflict of interest when doctors work both in the public healthcare system and in the open market, due to out-of-pocket payments and considerably higher prices in the latter case. A distinction must be made between private providers and the provision of healthcare services in the open market, as is typical of a traditional Bismarckian healthcare system like the Slovenian one. A private provider of healthcare services may have a concession and therefore a contract with the statutory health insurance to provide publicly covered and financed health services. Private providers may also provide private services in the open market. These are typically paid out-of-pocket or through private insurance, and at prices that are not regulated like those for the provision of publicly covered services.

The introduction to the new act states that with the incentive of better payment in private settings, doctors more and more opt to work both in the public and private contexts, while favouring services provided in the open market. Consequently, health workforce resources are taken away from the publicly financed healthcare network, reducing productivity, prolonging waiting times, and exacerbating the gap in timeliness between the services provided within and outside of the public healthcare network.

Content of the reform

The Amendments to the Health Care Act introduce stringent restrictions that only exceptionally allow employees with public healthcare providers to also work with other providers for the provision of services in the open market. Additional limitations have also been introduced in terms of the legal nature of the contracts between healthcare workers and provider organizations, and consist of limiting the tax advantages that some forms of collaborations allowed.

Concerns about the reform

The main concern, expressed (among others) by the Medical Chamber of Slovenia, is that introducing additional limitations to the possibility of healthcare workers, and doctors in particular, to work for several providers may have the unwanted effect of reducing the number of doctors in the public healthcare network. This would come as a consequence of a significant number of doctors opting to work fully on the open market, as opposed to fully committing to the public sector. FIDES, the doctors’ and dentists’ trade union, filed a request in June for review with the constitutional court.

References

Government of the Republic of Slovenia, 2025. Predlog – EVA 2024-2711-0060 Prva obravnava – Zakon o spremembah in dopolnitvah zakona o zdravstveni dejavnosti [Proposal - EVA 2024-2711-0060 First reading – Act on Amendments to the Health Care Act] Available at https://imss.dz-rs.si/IMiS/ImisAdmin.nsf/ImisnetAgent?OpenAgent&2&DZ-MSS-01/e213aa047ad047f067287fd441b47ca9b0ce8b74a32eaad40b5910ed30aa506d

Medical Chamber of Slovenia, 2025. Pripombe na Zakon o spremembah in dopolnitvah Zakona o zdravstveni dejavnosti [Comments on the Act on Amendments to the Health Care Act]. Available at https://imss.dz-rs.si/IMiS/ImisAdmin.nsf/ImisnetAgent?OpenAgent&2&DZ-MSS-01/f973809306163890080c142a7936b4f13f6f17f15b2a6b8f0e50a4938c49de39

Fides vložil ustavno presojo: “To je edina pot, da zaščitimo pravico do zdravljenja” [Fides files constitutional review: “This is the only way to protect the right to medical treatment”], rtvslo.si. Available at https://www.rtvslo.si/zdravje/fides-vlozil-ustavno-presojo-to-je-edina-pot-da-zascitimo-pravico-do-zdravljenja/748767

Ministry of Health, 2025. Zakon o zdravstveni dejavnosti [Health Care Act] Available at https://www.gov.si/zbirke/projekti-in-programi/prenova-zdravstvenega-sistema/zakon-o-zdravstveni-dejavnosti

Zakon o spremembah in dopolnitvah Zakona o zdravstveni dejavnosti (ZZDej-N) [Act on Amendments to the Health Care Act], Official Gazzette of the Republic of Slovenia no. 32/25. Available at https://www.uradni-list.si/glasilo-uradni-list-rs/vsebina/2025-01-1283

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