The Hellenic Competition Commission (HCC) published the Interim Report on the investigation it is conducting into the Provision of Private Health Services and Related Insurance Services, the text of which can be found here (in Greek). The executive summary of the Interim Report is also available here (in English).

The general conclusions for private health services that can be drawn from the Interim Report are that their structure shows a moderate degree of concentration, while the main trend observed is the acquisition of private clinics by investment schemes (funds), with the most important example being the series of concentration of private clinics under the control of CVC funds during the last five years.

Some of the participants in the HCC's inquiry express concerns about the concentration trends in the market, and in particular the parallel activity of large health service providers in the market for the provision of health insurance services (verticalization).

However, the majority of participants do not consider any company to be “dominant” in the market. However, the verticalization of the health sector with the health insurance sector (through mergers or various practices/partnerships) emerges as a particular issue.

Health providers point to the increased concentration in the market as the main sources of competition distortion, as well as cost containment mechanisms and rationalization of the state budget for health, such as the institutionalized diagnosis-related groups (DRGs) of the Greek National Health Service Organisation (“EOPPY”), something that requires further investigation. In addition, the majority of participants consider that there are regulatory barriers to enter and operate in the market as well as interventions in the activity of private health service providers by public bodies.

It is interesting to note the shift of the insured to private health service providers and the awareness of patients regarding the need to access quality health services. This in turn led to a shift to private insurance services and in search of satisfactory insurance plans, with further growth of the industry. On the other hand, some population groups were excluded from access to health services.

Regarding the health insurance sector, the main conclusion is that the sector is characterized by the existence of a relatively large number of players, while the observed concentrations are mainly of a horizontal nature (between competitors) and, in a sense, reflect the more general European trend of realignments in the insurance sector due to the high capital requirements of the EU legislation.

A mixed picture emerges in relation to the impact of mergers in the market, with horizontal mergers between insurance companies being viewed positively, but concerns are nonetheless being expressed regarding the consolidation of activities in the health and insurance markets.

Key parameters for choosing an insurance program are, among others, the amount of insurance premiums, the scope of coverage, the reputation of the provider as well as the network of cooperation with health providers it provides. It appears that there is sufficient differentiation of health insurance plans, while it is observed that consumers who have health insurance with one insurance company also maintain other insurance coverage from the same company. From the responses of the participants it appears that the bundling of health insurance plans with other insurance plans is a rather common commercial practice. 

Based on the HCC's inquiry so far, health providers appear to have more bargaining power than insurance companies. Some insurance companies consider groups such as “HHG”, “Iatriko”, “Eurokliniki”, “Bioiatriki”, “Affida” and “Iaso” to be indispensable commercial partners.

With regard to data and new technologies, the key assumption of the Interim Report is that an appropriate regulatory framework oriented towards the protection and access of health-related data will contribute to enhancing competition and the development of medical technology start-ups and incumbents, resulting directly in increased innovation and enriched quality of medical services.

The following conclusions also emerge from the HCC's inquiry:

Private clinics collect and process the personal data of their patients themselves and transmit the necessary data to insurance, private and non-public, and auditing bodies in compliance with the GDPR (written consent of the patients).

Health insurance service providers collect the data related to risk assessment when concluding the insurance contract (medical history and examinations), and then the data related to compensation assessment, i.e. medical diagnoses and hospitalization data, test results surgery records, hospital invoices, etc. The insurance companies receive from the clinics the individual medical data of each incident, as a rule, to the extent they are needed to assess whether the incident falls within the scope of insurance coverage and the individual information regarding the cost of hospitalization, etc.

Participating health service providers believe that, in order to better provide relevant services to patients, it is necessary for health service providers and health insurance providers to have access to patient history data as well as the complete medical record of patients, containing e.g. diseases, hospitalizations, medical examinations/test results -laboratory, x-ray tests-, medication, with the aim of providing the best possible services. However, for the most part, health providers do not see access to data as providing a particular competitive advantage.

In addition, it is estimated that increased access to citizens' health data by health insurance companies may lead to a distortion of competition and an increase in the market power of certain health insurance providers. Discrimination against categories of citizens and reduced access to health and insurance services is also not excluded. In this context, the initiative by “EAEE” (Hellenic Association of Insurance Companies) to create a Code of Ethics for the processing of personal data by insurance companies is of particular interest, in order to specify the general principles and obligations arising for insurance companies and to protect insured consumers.

The use of data pools for personal medical data by health or insurance companies is considered to have both positive and negative effects. The majority of both health care providers and health insurance providers surveyed have not identified practices of leveraging a company's power in neighboring markets through the use of big data and/or algorithms.

Finally, several interviewed health providers point out the need for mechanisms to facilitate innovation, as well as that the Hellenic Competition Commission could contribute to this by applying Article 37A of Law 3959/2011.

In parallel with the publication of the interim report, the HCC announces the start of a public consultation and invites all interested parties to express their views and comments on the Interim Report, by participating in the relevant conference-teleconference to be organized in September 2023, and/or submitting observations in writing, in the form of a memorandum, to the electronic address This email address is being protected from spambots. You need JavaScript enabled to view it. by August 25, 2023.

The conclusions that will emerge from the second public consultation will be incorporated into the Final Report. Also, for the preparation of the final report, a systematic effort will be made by the HCC to research (possibly through a poll) and record the opinions of consumers and consumer associations regarding the issues of concentration and competition in the examined markets, while cooperation with the Hellenic Consumers’ Ombudsman for the specific matter.

After the completion and processing of the data resulting from the public consultation, the Final Report will be published in December 2023.

Read more in the Sector Inquiry’s dedicated webpage here.