DigiHealthAccess

Reimbursement 101

Understanding how digital therapeutics get reimbursed

Regulatory approval gets a product onto the market; reimbursement and market access decide whether it reaches patients at scale. This page walks through the DiGA pathway as the role-model timeline, defines the core concepts and regulatory frameworks, and shows the commercial models that co-exist across global markets.

The role model

Germany's DiGA pathway, step by step

Germany built the world's first national reimbursement route for digital therapeutics. Its milestones are the reference other markets measure themselves against — from the enabling law to today's shift toward outcome-linked pricing.

Nov–Dec 2019Enabling law

The Digital Healthcare Act (DVG) enters into force

On 19 December 2019 the DVG created the “app on prescription” — the first time a G7 health system gave its statutory-insured population (~73 million people) a legal entitlement to prescribed, reimbursed software.

April 2020

The DiGA Ordinance (DiGAV) & the BfArM fast-track open

Implementing rules define the “fast-track”: BfArM assesses a complete application within three months, checking safety, data protection, interoperability and a “positive healthcare effect.”

October 2020First listings

The first DiGA go live in the directory

velibra (anxiety, permanent), Kalmeda (tinnitus, provisional) and somnio (insomnia) become the first apps physicians and psychotherapists can prescribe and statutory insurers reimburse.

2021

Price negotiations begin

Manufacturers set their own price for the first 12 months; after that a negotiated rate with the GKV-Spitzenverband (national association of statutory insurers) kicks in — the first negotiated DiGA prices land.

2022–2023

Provisional listings convert to permanent

Apps that entered on a trial listing complete their evidence and convert to permanent listing — while debate grows over pricing guardrails and real-world uptake.

2024DigiG

The Digital Act (DigiG) upgrades the framework

Streamlines activation codes, opens the pathway to higher-risk (class IIb) applications, and lays the ground for mandatory success measurement.

From Jul 2026Outcome-based

Success measurement & outcome-linked pricing

Mandatory performance reporting and pricing tied to demonstrated benefit begin — the market shifts from simply “listed” to “proven,” with price caps and performance clauses tightening.

The vocabulary

DTx, DMD, SaMD — and how they relate

These terms overlap but aren't synonyms. Broadly: SaMD is the regulatory category, DTx is a clinical sub-type of it, and DMD is a reimbursement bucket used in France. Getting them straight matters because approval and payment run on different tracks.

DTx

Digital Therapeutics

Software that delivers an evidence-based therapeutic intervention to prevent, manage or treat a medical disorder — clinically validated, and often prescribed (a “prescription digital therapeutic,” PDT). The software itself is the treatment.

Examples: deprexis (depression), somnio (insomnia), CureApp HT (hypertension).

DMD

Dispositif Médical Numérique

France's term for a “digital medical device” — a reimbursement bucket rather than a clinical definition. It spans both DTx and medical telemonitoring solutions eligible under the PECAN early-access and LPPR/LATM permanent pathways.

Scope: DTx + remote patient monitoring; the label that routes a product into French reimbursement.

SaMD

Software as a Medical Device

The regulatory umbrella (IMDRF definition): software intended for a medical purpose that performs that purpose without being part of a hardware device. All DTx are SaMD, but not all SaMD are DTx — diagnostics and clinical-decision tools are SaMD too.

Relationship: SaMD ⊇ DTx. Regulators classify SaMD by risk.

RPM / DiPA

Adjacent categories

Remote patient monitoring (RPM) uses connected devices/software to track patients between visits; it's often reimbursed through billing codes rather than a DTx pathway. Germany's DiPA is a separate “digital care application” track for long-term care.

Why it matters: the same app can qualify under different rules depending on claim & setting.

Regulatory approval vs. reimbursement — two different gates

A product must first clear regulatory requirements to be legally marketed, then separately win reimbursement to be paid for. The main regulatory frameworks:

  • EU — MDR (Regulation 2017/745): CE-marks software as a medical device by risk class (I, IIa, IIb, III). Most DTx are class IIa/IIb. CE-marking is the entry ticket for European reimbursement schemes (DiGA, PECAN, mHealthBELGIUM, MiGeL).
  • USA — FDA: clearance via 510(k) (substantial equivalence), De Novo (novel low-to-moderate risk), or PMA (high risk). Digital mental-health treatment devices are classified under 21 CFR 882.5801.
  • Global — IMDRF SaMD framework: an internationally harmonised way to categorise SaMD by the seriousness of the condition and the significance of the information it provides.
  • Japan / Korea / others: DTx clear the national device regulator (PMDA in Japan, MFDS in Korea) before a separate body sets the reimbursement price (Chuikyo/NHI in Japan, HIRA in Korea).

The full picture

Digital Health, eHealth, mHealth, Health Apps, DTx, DiGA, DiPA & RPM

Eight terms that are often used interchangeably in practice — but don't mean the same thing. This containment diagram builds from the bottom up: what's contained in what, and at which level a proof-of-effectiveness requirement kicks in.

Digital Health
eHealth
mHealth
Health Apps
Telemedicine & RPMReimbursable RPM
DiPA 🇩🇪 DEDigital Care Apps
DiGA 🇩🇪 DEReimbursed DTx
DTxThe software is the treatment
Regulation threshold

From here on: a medical or care-related purpose applies — meaning approval and proof of benefit are required. Three separate pathways lead across this line.

The app-based part of mHealthFitness · Meditation · Nutrition · Cycle tracking
Care delivered via mobile devices, not just appsSMS reminders · Wearables · Sensors
ICT infrastructure for healthcare delivery (WHO)ePA (e-record) · e-prescriptions · hospital IT · TI network
Any digital technology used in healthcareAI diagnostics · Wearables · Data platforms

Illustrative overview — not legal or reimbursement advice.

DigiHealthAccess
Umbrella term — no approval requirement of its own Regulated category — proof of effectiveness required Own reimbursement pathway in Germany

🇩🇪 DiGA and DiPA are Germany-only reimbursement pathways, with no equivalent elsewhere.

Umbrella terms with no proof requirement of their own

Digital Health

Umbrella term

The umbrella term for any digital technology in healthcare — fully encompasses eHealth, and with it mHealth, health apps and DTx.

ProofNone — not a legal term.
AI diagnostic supportWearables & sensorsHealth data platforms

eHealth

Umbrella term

ICT infrastructure for healthcare delivery (WHO definition). mHealth is a sub-category of it, per WHO.

ProofNone — infrastructure follows its own rules (e.g. gematik certification).
ePAHospital ITE-prescriptionsTelemedicine

mHealth

Umbrella term

Healthcare delivered via mobile devices — explicitly more than just apps, per WHO.

ProofNone — describes the channel, not the effect.
SMS remindersWearablesTelemonitoring hardware

Health Apps

Umbrella term

The app-based part of mHealth — ranging from free wellness tools to regulated DTx.

ProofNone, as long as no medical purpose is claimed.
Fitness trackingMeditationNutrition diaryCycle tracker
Regulated categories with a proof requirement

DTx

Regulated

The regulated, evidence-based part of health apps: the software itself is the treatment, not just something accompanying it.

ProofClinical evidence (RCTs) and approval as a medical device (SaMD).
Clinical evidence (RCTs)Approved as SaMDPrescribable

DiGA 🇩🇪 DE

Regulated + reimbursed

Germany's national DTx pathway: listed by BfArM, prescribable, and reimbursed by statutory health insurance (GKV).

ProofPositive healthcare effect required under § 139e SGB V and the DiGAV; entitlement under § 33a SGB V.
BfArM fast-trackDiGA directoryGKV reimbursementePA & Health-ID integration

DiPA 🇩🇪 DE

Long-term-care pathway

Germany's app pathway for long-term care — separate from DiGA, requiring proof of care-related rather than therapeutic benefit.

ProofCare-related benefit required under §§ 40a and 78a SGB XI and the DiPAV.
BfArM directorySubsidised by the care insurer§ 40a SGB XI

Telemedicine & RPM

Regulated + billable

Remote treatment and monitoring: the technology transmits the physician's service, it doesn't replace it — so this isn't DTx, even when the patient-facing part is an app.

ProofA physician service billed via Germany's EBM fee schedule 🇩🇪 DE; devices classed as medical devices, some as durable medical equipment. Heart-failure telemonitoring has been an EBM-billable service since 2022 (G-BA decision, 2020).
Video consultationHeart-failure telemonitoringEBM billingDurable medical equipment registry
The one distinction that matters

What separates these terms isn't the technology — it's the proof-of-effectiveness and approval requirement. The four outer levels are umbrella terms nobody has to prove. Past the regulation threshold, three separate pathways apply, depending on who's treating: the physician (telemedicine and RPM, via EBM), long-term care (DiPA, SGB XI), or the software itself (DTx, and — when reimbursed — DiGA, under SGB V).

Note: products in our database can be flagged as discontinued once the vendor has shut down or the offering is no longer available — discontinued products are excluded from the reimbursement counts on the National Checklists page.

How it gets paid for

Four commercial models — and how they co-exist

Market access isn't a single switch. Products move along a spectrum from narrow, self-funded access to broad, statutory entitlement — and within any one country several of these models operate at once. A product often climbs the ladder as its evidence matures.

Self-pay
Pilot / evaluation
Selective / regional
Universal reimbursement
Narrower access · lower evidence barBroader access · higher evidence bar
💳

Self-pay

The patient (or employer) pays out of pocket. Fast to launch, no payer negotiation — but access depends on ability to pay.

Who pays: patient / employer · Evidence bar: low–moderate
Korea — Somzz (in practice)Wellness & DTC apps
🧪

Pilot / evaluation

Time-limited, evidence-generating access, often publicly funded. Designed to test value before a permanent decision.

Who pays: health system (temporary) · Evidence bar: generating it
France — PECAN early accessUK ICB pilotsFinland experiment
🤝

Selective / regional

Specific insurers, employers or regions contract for a product — coverage depends on which plan or area the patient belongs to.

Who pays: named insurer / employer / region · Evidence bar: moderate
Germany — SelektivverträgeUS employer channelBelgium regional
🏛

Universal reimbursement

A national entitlement: any eligible patient can get the product, funded by the statutory system regardless of their insurer.

Who pays: statutory system (nationwide) · Evidence bar: high
Germany — DiGAJapan — NHIFrance — LPPR
They co-exist. The same market usually runs several models at once — e.g. Germany has universal DiGA reimbursement and selective insurer contracts and a self-pay tier; the UK mixes national NICE-backed funding with regional pilots. A single product also tends to move up the ladder as evidence accumulates: self-pay → pilot → selective → universal.