Drug Data and Databases
August 3, 2026
6 minutes

Reference price group

A reference price group (Festbetragsgruppe) is the set of comparable medicines the German Gemeinsame Bundesausschuss forms under §35 SGB V so that a single Festbetrag can be set for all of them. Membership decides which products compete on the same reimbursement ceiling. On pharmazie.com the group is carried per PZN in the Preisvergleich block, so professionals see the peer set behind an amount.

Table of contents
    TL;DR
    • A reference price group (Festbetragsgruppe) is the group of comparable medicines the G-BA forms under §35 SGB V so one Festbetrag applies to all members.
    • The group comes first, the amount second: grouping decides which products compete on the same reimbursement ceiling.
    • Three Gruppenstufen: Stufe 1 same active ingredient, Stufe 2 pharmacologically-therapeutically comparable, Stufe 3 comparable therapeutic effect including combinations.
    • The G-BA forms the group (Anlage IX) and sets the Vergleichsgrößen (Anlage X); the GKV-Spitzenverband then sets the amount.
    • Patent-protected products with a novel mode of action or a therapeutic improvement are exempt from Stufe 2 and 3 groups (§35 Abs. 1 Satz 6).
    • On pharmazie.com the group and per-member Festbetrag are carried per PZN in the Preisvergleich block via ABDA article master data.

    Reference price group (Festbetragsgruppe) is the group of comparable medicines that the Gemeinsame Bundesausschuss (G-BA) forms under §35 SGB V so that one single Festbetrag can be set for the whole group. The group is the object; the Festbetrag is the amount attached to it.

    The distinction matters because the two are routinely conflated. The Festbetrag is a number, the reimbursement ceiling the statutory health insurance pays. The reference price group is the question that comes first: which products count as comparable enough to share that ceiling. Grouping decides the field of competitors. Once a product sits inside a group, its price is measured against every other member, and any amount above the group Festbetrag becomes an Aufzahlung the insured person pays. That is why the boundary of a group is contested far more often than the arithmetic of the amount.

    What are the three reference price group levels?

    §35 Abs. 1 Satz 2 SGB V defines three levels of comparability, the Gruppenstufen. The level fixes how wide the group is and how much clinical judgement went into drawing its edge. Wider comparability captures more products, including patent-protected ones, but is harder to defend.

    StufeLegal wording (§35 Abs. 1 Satz 2)Basis of comparabilityEffect on competition and substitution
    Stufe 1Arzneimittel mit denselben WirkstoffenIdentical active ingredient (wirkstoffgleich).The tightest group. Products are interchangeable at the counter, so price competition is direct and pharmacy aut-idem substitution operates inside it.
    Stufe 2pharmakologisch-therapeutisch vergleichbaren Wirkstoffen, insbesondere mit chemisch verwandten StoffenDifferent active ingredients from a comparable pharmacological class, especially chemically related ones.Broader. Members are not freely interchangeable at the counter, but they compete on the same ceiling. This is the level at which patent-protected products can be captured.
    Stufe 3therapeutisch vergleichbarer Wirkung, insbesondere ArzneimittelkombinationenDifferent mechanisms with a comparable therapeutic effect, explicitly including combination products.The widest. Competition is on therapeutic outcome rather than substance identity; direct substitution generally does not apply.

    Stufe 2 and Stufe 3 carry a statutory guardrail (§35 Abs. 1 Satz 5): the grouping must not restrict therapeutically necessary prescribing options, and medically required alternatives have to remain available. Reserve antibiotics may be left out of grouping, and age-appropriate paediatric forms and strengths stay out under §35 Abs. 1a SGB V.

    How is a reference price group formed and maintained?

    Two bodies act in sequence, and the group is where the first one does its work. The G-BA never sets the amount; the GKV-Spitzenverband never draws the group.

    1. The G-BA forms the group. Under §35 Abs. 1 SGB V it determines in its guidelines für welche Gruppen von Arzneimitteln Festbeträge festgesetzt werden können. The resolved groups are published in Anlage IX of the Arzneimittel-Richtlinie.
    2. The G-BA sets the comparison metrics. It calculates the rechnerischen mittleren Tages- oder Einzeldosen or other suitable Vergleichsgrößen that make products of different strengths and pack sizes comparable within the group. These sit in Anlage X.
    3. The GKV-Spitzenverband sets the amount. Under §35 Abs. 3 SGB V it fixes one Festbetrag for the group the G-BA has defined. How that number is derived is covered in the Festbetrag entry.
    4. The group is maintained. Festbeträge are reviewed at least once a year (§35 Abs. 5), and the group and its Vergleichsgrößen are adjusted when new products enter, patents lapse, or the market shifts.

    Membership also drives what happens downstream in dispensing and procurement. Within a wirkstoffgleiche group the cheapest available packs are what a pharmacy is steered toward, which is the same economic logic that the four-cheapest rule and Rabattverträge exploit. The group defines the peer set; those rules pick winners inside it.

    Can a product be excluded from a reference price group?

    Yes, and the carve-out is the most consequential membership rule for manufacturers. §35 Abs. 1 Satz 6 SGB V exempts from Stufe 2 and Stufe 3 groups those Arzneimittel mit patentgeschützten Wirkstoffen, deren Wirkungsweise neuartig ist oder die eine therapeutische Verbesserung, auch wegen geringerer Nebenwirkungen, bedeuten. A substance stays neuartig for as long as the first substance marketed in its group remains patent-protected (Satz 7). A patent-protected but therapeutically unremarkable analogue preparation gets no such shelter and can be grouped.

    There is a second route into a group that runs through AMNOG. Under §35a Abs. 4 SGB V, where the benefit assessment finds no therapeutic improvement, the medicine is assigned in the G-BA resolution to the Festbetragsgruppe of pharmacologically-therapeutically comparable products, a Stufe 2 group. A separate legal challenge against that assignment is inadmissible under §35a Abs. 8 SGB V.

    Where do professionals see the reference price group on pharmazie.com?

    pharmazie.com does not create the grouping, it consolidates the licensed data that reflects it. The group and the amount that applies to each member reach the platform through the licensed ABDA article master data, keyed to the PZN.

    • Field: Preisvergleich/Festbetragsgruppe in the comparison block, with the Festbetrag shown per member article
    • Granularity: per PZN
    • Source: ABDA article master data (ABDATA Pharma-Daten-Service)
    • Updated: daily, with a source and date stamp on every detail page
    • Access: web app, REST API, data export

    One honest limitation: the platform shows which group an article belongs to and the amount that applies, not why the G-BA drew the group boundary where it did. The reasoning behind a grouping and the exact scope of each Stufe live in the G-BA decision documents and Anlage IX/X of the Arzneimittel-Richtlinie. To apply the group, the data field is enough; to argue about a group's cut, the G-BA source is where you go.

    Sources

    Author Image
    Ursula Tschorn
    Ursula Tschorn is CEO of DACON Datenbank Consulting GmbH and has been building pharmaceutical information infrastructure since 1989. She writes on drug data standards, pricing regulation and market access in the DACH region.

    FAQ

    What is a reference price group under §35 SGB V?
    What are the three reference price group levels?
    Who forms a reference price group?
    What is the difference between a Festbetrag and a reference price group?
    Can a product be excluded from a reference price group?
    How does aut-idem substitution relate to a reference price group?

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