The Swiss Financial Market Supervisory Authority (FINMA) published an update on its supervision of supplementary health insurance, reporting progress since its 2020 findings on non-transparent and sometimes unjustifiably high invoices for additional benefits but identifying continuing implementation deficiencies in service provision. FINMA said further action is still needed to protect policyholders and it is examining additional measures for 2025. Following the Swiss Insurance Association’s industry framework on additional benefits, whose implementation period ended at the end of 2024, many insurers have strengthened contract definitions and the distinction of additional benefits and improved invoice transparency, and have developed largely mature assessment models to benchmark additional benefits against services that should already be covered by compulsory health insurance. Based on these assessments, insurers have in several cases negotiated lower prices where compensation appeared unreasonable, and FINMA links these efforts to broadly stable or falling prices for semi-private and private in-patient stays since 2020 and to stagnating or declining premiums for supplementary hospital insurance in many areas. However, FINMA found material gaps remain, including contracts that do not meet supervisory-law requirements on correctly distinguishing additional benefits and complying with insurers’ reference prices, as well as contracts extending beyond 2024 despite not meeting requirements. On-site reviews also found market prices often still significantly exceed internal reference prices, with persistently high doctors’ fees in some cases and instances of services billed twice via basic and supplementary insurance; one example cited a CHF 191 internal reference price for hospitality services versus a CHF 855 agreed hospital price. FINMA expects insurers to set contractual prices for agreed additional benefits based on their models, transparently document deviations, and reduce prices that deviate significantly from internal reference prices. FINMA said it will continue to refrain from authorising new supplementary hospital insurance products unless long-term compliance with its requirements can be ensured, and it will carry out further on-site supervisory reviews of selected insurers in 2025. If serious shortcomings persist, including on implementation timescales or sustained gaps between reference prices and agreed prices, FINMA indicated it may impose stricter and more far-reaching measures, including in some cases a temporary or permanent absence of contracts with service providers as an alternative in the interests of policyholders.

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