Article L. 111-11 of the French Social Security Code stipulates that the Union nationale des caisses d’assurance maladie (French National Union of Health Insurance Funds – “UNCAM”) must annually submit to ministers and to the French Parliament, by June 15, proposals related to the evolution of expenses and income (the “expenses and income report”) for the following year and the necessary measures to achieve the balance provided in the annual health insurance expenditure budget.

Based on these provisions, the French health insurance published its 30 proposals for 2025 on Friday, July 19, aimed at achieving the double objective of improving the quality of the healthcare system and controlling expenses. 

Below is a summary of the main proposals concerning healthcare products, which could be included in the Social Security Financing Bill (“PLFSS”) for 2025 or in the next framework agreement between the LEEM (i.e. pharmaceutical companies union) and the CEPS (Economic Commitee for Health Products).

Requesting pharmaceutical companies to reimburse the additional distribution margin cost paid by the health insurance due to a discrepancy between the face price and the net price (proposal no. 22)

The “product paybacks” have been increasingly frequent (their amount has quadrupled since 2017).

However, the distribution margin paid to pharmacists and wholesalers is based on the face price excluding tax (“PFHT”) and not on the price net of product paybacks.

As a result, the application of product paybacks leads to an additional cost for the health insurance relating to the distribution margin. This additional cost was estimated at 152 million euros in 2022, an increase of 35% compared to 2021.

Thus, the health insurance proposes that:

  • pharmaceutical companies reimburse this additional cost unless they commit to a “rapid convergence (‘within a maximum horizon of 12 months’) of the face price towards the negotiated price”;
  • this provision be included in the next framework agreement between the LEEM and the CEPS expected in 2025.

Reducing waste of unused medical bandages, pharmaceutical products, and medical equipment (proposal no. 1)

To reduce waste of healthcare products, the health insurance proposes:

  • limiting the initial supply of bandages and other wound treatment products to 7 days of treatment upon discharge from the hospital or otherwise (bandages were explicitly targeted by the paybacks mechanism created by the Social Security Financing Act (“LFSS”) for 2024 – see our article on the subject); and
  • encouraging the reuse of unused healthcare products, for example, by allowing pharmacists to identify unopened products returned to the pharmacy and experimenting with their reuse modalities.

Improving the penetration of biosimilars by preventing pharmaceutical companies from using strategies to circumvent substitution of expensive molecules in pharmacies (proposal no. 28)

To achieve the target penetration rate of 80% for biosimilar pharmaceutical products, the health insurance proposes leveraging several mechanisms, for example:

  • encouraging the use of biosimilars by expanding substitution by pharmacists, which is currently allowed only for 2 molecules; and
  • strengthening incentive mechanisms aimed at professionals and certain healthcare establishments.

The health insurance’s proposal particularly targets strategies by pharmaceutical companies to circumvent substitution in pharmacies of expensive molecules in ophthalmology.

The health insurance also encourages that the future framework agreement between the LEEM and the CEPS establish a specific pricing policy for reference biological pharmaceutical products and biosimilars.

Experimenting with providing general practitioners with an AI tool to assist in interpreting electrocardiograms (proposal no. 24)

The health insurance recognizes the importance of using artificial intelligence (“AI”) systems in healthcare but believes that regulation and evaluation must be implemented to ensure their effectiveness and safety. It notes that no national evaluation process is currently in place for professional digital medical devices.

The health insurance thus proposes implementing:

  • an evaluation to demonstrate the utility and performance of these devices; and
  • specific ways of financing these devices, for example by evolving the current pricing model for acts.

In this context, the health insurance proposes launching an experiment to provide healthcare professionals with an AI tool to assist in interpreting electrocardiograms.


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