Additional Fees in Private Hospitals

Legal Limits and Patient Rights:

In private hospitals, "additional fees," or as they are called in the legislation , "surcharges ," are one of the most common complaints from patients covered by the Social Security Institution (SGK). Many people pay the high bill that appears after the procedures are completed without knowing whether it is truly within legal limits or excessive

However, the Social Security and General Health Insurance Law No. 5510 clearly limits the amount of additional fees that private hospitals can charge patients covered by the Social Security Institution (SGK) and defines the concept of "additional fees".

In this article;

What is the difference (additional) fee in private hospitals?
What is the legal upper limit?
Which individuals and which health services are exempt from any additional fees?
What kind of documents should you request
If excessive additional fees are charged, complaints can be filed with the Social Security Institution (SGK), the Consumer Arbitration Board, and legal action can be taken.
Current monetary limits and precedents.

We will address this in detail and based on legislation.

1. What is the difference (additional) fee?

The term "additional fee" is used in legislation rather than "difference fee" . An additional fee is...

This is the amount additionally collected from the patient on top of the healthcare service fee paid by the Social Security Institution (SGK) to the private hospital
The Social Security Institution (SGK) pays the hospital the amount determined in the Health Application Communiqué (SUT) for examinations, tests, surgeries, etc.
Private hospitals may charge an additional fee (difference) up to a certain multiple of this amount, provided it does not exceed the legal limit .

There are two important distinctions here :

Co-payments (such as examination co-payments, prescription co-payments) – are regulated separately in the SGK (Social Security Institution) legislation; similar to the 20-30 TL amounts you pay at the pharmacy.
Additional fee (difference fee) – The amount that a private hospital charges the patient in addition to the SUT (Social Security Institution) fee.

Payments for services not covered by the Social Security Institution (SGK) (such as certain cosmetic procedures or check-up packages) are not considered additional charges; these are entirely subject to the free market system.

2. Legal Basis for the Difference Fee

The basic regulations regarding co-payments in private hospitals are as follows:

Article 73 of the Social Security and General Health Insurance Law No. 5510 (defines the scope of the additional fee)
Health Application Communiqué (SUT) and its annexes (regulate SUT fees and the list of individuals/services for which no additional fees can be charged)
Social Security Institution (SGK) – Private Healthcare Provider Contracts (2024 and 2025 contracts; additional fees, tables, penalty clauses, document procedures, etc.)
Law No. 6502 on Consumer Protection (treats the patient-private hospital relationship as a consumer transaction; defective service, unfair terms, Consumer Arbitration Board application, etc.)

This framework defines both the additional fees that a private hospital can charge and the avenues a patient can pursue for redress through the Social Security Institution (SGK) and consumer law in case of overcharging

3. How much can the difference in fees be in private hospitals?

3.1. Maximum Difference Fee That Can Be Charged from a Patient Covered by SGK (General Rule)

According to Article 73 of Law No. 5510 and related secondary legislation; private healthcare providers contracted with the Social Security Institution (SGK)generally:

For standard healthcare services , an additional fee of up to twice the amount paid by the Social Security Institution (SGK) according to the SUT (Healthcare Services Pricing Regulation) can be charged.

What does this mean?

Example:

the fee determined by SGK for the relevant procedure in SUT X TL ,
SGK X TL .
A private hospital can charge a maximum of 2X TL in additional fees from the patient
Therefore, the hospital's total revenue 3X TL(X from SGK, 2X from patients).

Therefore, "You are covered by the Social Security Institution, but private hospitals can charge whatever they want" is not legally correct. The undertakings signed do not eliminate this upper limit either.

3.2. Higher Ceilings for Exceptional Healthcare Services

certain “exceptional healthcare services,” legislation sets a higher ceiling for additional fees. In practice, for these procedures:

An additional fee of up to three times the SUT (Health Services Pricing Regulation) amount determined by SGK (Social Security Institution) can be charged.
Therefore, it is accepted that the hospital is allowed to receive an income of up to 4X in total, with X amount from the Social Security Institution (SGK) and a maximum of 3X from the patients.

Which procedures are considered exceptional are listed individually in the supplementary lists of the SUT (Health Services Pricing Regulation ). For normal procedures that are not within this scope, the general rule (2 times the amount) applies.

3.3. Services Not Funded by the Institution (Cosmetic procedures, check-ups, etc.)

There are some transactions that are not included in the SUT (Health Services Pricing Regulation) at all, and are "not financed by the institution" . For example:

Some surgeries are purely for cosmetic purposes,
Check-up packages,
Some hotel/comfort services.

In such procedures, since the Social Security Institution (SGK) does not already pay a fee, an additional fee limit does not apply. The price between the hospital and the patient can be freely determined; however, the consumer must be clearly and priorly informed, a contract that does not contain unfair terms must be made, and not violate the provisions of the Consumer Protection Law .

4. What is SUT (Health Application Circular)?

When discussing co-payments in private hospitals, one of the most frequently mentioned terms is SUT . SUT is an abbreviation for " Health Application Regulation ," and it is a fundamental document issued by the Social Security Institution (SGK) that details the conditions and costs of healthcare services provided to individuals covered by general health insurance .

The purpose of this circular is, in short, to determine the procedures and principles for the reimbursement of health services, travel, daily allowance, and accompanying person expenses financed by the institution for general health insurance holders and their dependents, and to announce the amounts to be paid by the Social Security Institution (SGK) for these services

4.1. Legal Basis of SUT

The SUT (Health Services Pricing Regulation) is not an administrative circular, but secondary legislation . According to the "basis" section of the regulation:

Law No. 5502 on the Social Security Institution,
Social Security and General Health Insurance Law No. 5510,
General Health Insurance Procedures Regulation

It has been prepared within the framework of the provisions.

Therefore, the SUT ( that concretizes the general framework of Law No. 5510 and regulates the details for its implementation . The Social Security Institution (SGK) determines which health services will be covered, under what conditions, and at what price, through the SUT and its supplementary lists.

4.2. What is the Purpose of SUT (Health Services Pricing Regulation)? (Importance from the Patient's Perspective)

From the patient's perspective, we can think of SUT (Social Security Institution's Tariff and Healthcare Service Guide) as "SGK's (Social Security Institution) price list and healthcare service guide ." With its circular and annexes:

Which health services will be covered by the Social Security Institution (SGK)?
These services include diagnostic and treatment methods.
The basic costs (SUT rates) that SGK (Social Security Institution) will pay for each examination, test, analysis, and surgery are :
Payment rules, referral chain, status of healthcare facilities at different levels

It is meticulously organized.

a procedure is not listed(Health Services Pricing List), as a rule, the SGK (Social Security Institution) does not cover the cost of that service. (For example, some procedures that are purely for aesthetic purposes.) Conversely, many surgeries, examinations, imaging procedures, and inpatient treatments are coded in the SUT, and a point/cost is assigned to each.

4.3. Relationship between SUT (Health Services Pricing Regulation) and Difference Fees in Private Hospitals

In private hospitals, the "difference fee" (additional fee)directly the SUT (Social Security Institution) fee . The scheme is simple:

The amount specified in the SUT (Health Services Pricing Regulation) for the relevant procedure is the basic amount that SGK (Social Security Institution) will pay to the hospital.
Private hospitals may request an additional fee (difference) from patients, up to a certain multiple of the SUT (Social Security Institution) fee, within the limits set by their contract and legislation .
Therefore, the answer to the question "how much can the difference in fees be in private hospitals?" of the SUT (Health Services Pricing Regulation) price and the limits in the SUT .

For example:

According to SUT (Social Security Institution's Tariff), if the cost of an operation is 2,000 TL;
SGK will cover this 2,000 TL on behalf of the hospital
Private hospitals can also charge additional fees up to the upper limit allowed by legislation (for example, twice or three times the SUT (Social Security Institution Tariff) fee).

Therefore, in order for the patient to understand whether the additional fee requested is legal, they actually the SUT (Social Security Institution) price and the maximum additional fee for that procedure .

4.4. Why Should SUT (Health Services Pricing Regulation) Be Continuously Monitored?

The SUT ( Health Services Pricing Regulation ) is not a static text ; it is frequently updated through "Amendment Notices" published in the Official Gazette . The 2013 SUT text has been amended numerous times in years such as 2016, 2022, and 2025, with transaction fees, services exempt from additional charges, and technical details revised repeatedly.

Because:

Both private hospitals,
Both doctors,
And also patients who want to seek their rights,

the calculation on the most up-to-date SUT (Health Services Pricing Regulation) text . An amount that might appear as "excessive payment" according to an old SUT table may remain within legal limits according to the current regulation, or vice versa.

5. Individuals and Healthcare Services Exempt from Additional Fees

The legislation stipulates that no additional fees can be charged to certain individuals or for certain health services .

5.1. Groups of People Exempt from Additional Fees

According to SUT and SGK guidelines;

Those receiving honorary pensions,
War and duty-related invalids and those they are responsible for supporting,
Those receiving monthly payments as part of the fight against terrorism,
Certain general health insurance beneficiaries and their dependents covered under Articles 60/12, 60/13 and 60/14 of Law No. 5510

It is explicitly stated that no additional fees can be charged to groups such as these

Charging these individuals an additional fee is clearly against the law

5.2. Healthcare Services for Which No Additional Fee Can Be Charged

No additional fees may be charged for certain health services listed in SUT article 1.9.3 and its annexes (especially Annex-2/G ) . These are, in summary:

emergencies (for more information see: https://ferhatkule.av.tr/ozel-hastane-acil-servis-ucretleri-yasal-mi/)
Intensive care services,
Burn treatment,
Cancer treatments (chemotherapy, radiotherapy, radioisotope therapies, etc.),
Healthcare services provided to newborns,
Organ, tissue and stem cell transplants,
Surgical procedures for congenital anomalies,
Hemodialysis treatments,
Cardiovascular surgical procedures (excluding those covered under exceptional healthcare services),
Other procedures listed in Annexes 2/B, 2/C and 2/G (e.g., auditory implants, etc.).

Private hospitals contracted with the Social Security Institution (SGK) cannot charge an additional fee from SGK-insured patients for these procedures . If they do;

This means they are acting in violation of the additional fee policy .
They may face penalties from the Social Security Institution (SGK) as well as an obligation to return the product under consumer law .

5.3. Emergency Services and “Termination of Emergency” Form

Especially in emergency rooms, "the emergency is over, we can now charge an additional fee" is a frequent occurrence. According to the regulations:

During an emergency, no additional charges may be applied (except in the green zone).
Once the emergency situation ends, if the patient's hospitalization continues, they will be considered a regular ward patient and a difference fee may be charged according to the SUT (Health Services Pricing Regulation)
However, for this to happen, the patient/patient's relative must be given a written information form stating that "the emergency situation has ended," and this must be delivered against their signature.

Requesting high additional fees immediately after the emergency service process without this form being served may violate both the SUT (Health Services Pricing Regulation) and the SGK (Social Security Institution) agreements.

6. How are the co-payments calculated in private hospitals?

6.1. Calculation Logic Based on SUT Fee

The additional fee by applying a coefficient to the SUT (Social Security Institution) fee . In summary:

There is a point system and an amount associated with the relevant medical procedure in the SUT (Health Services Pricing Regulation) .
SGK pays this SUT (Healthcare Services Pricing Regulation) amount on behalf of the hospital.
The private hospital's SUT (Social Security Institution) fee;
- Up to twice the normal price for regular services .
- For exceptional healthcare services, of up to three times the standard rate
  may be charged.

Each hospital its own additional fee rate . This rate must be transparently displayed on a sign.

6.2. SGK Additional Fee Calculation Screen

The Social Security Institution (SGK) has published an "Additional Fee Calculation" screen so that citizens can check whether they have been overcharged . By entering transaction and institution information, it is possible to see the maximum legally permissible additional fee .

Practically:

The procedure codes written on the invoice and the "document showing the services provided to the patient and the additional charges",
When you access the SGK additional fee screen,
the difference you paid exceeds the limit .

6.3. Example Calculation

Let's say:

the SUT (Social Security Institution) fee for a cardiology specialist examination 400 TL .
The additional fee announced by the hospital is 200% (i.e., double).

In this situation:

SGK pays the hospital 400 TL .
The hospital can charge the patient a maximum additional fee of 800 TL
The total service fee cannot exceed 400 + 800 = 1,200 TL

If the document you received from the hospital states that;

"Examination fee is 1,500 TL"
And if the entire fee has been charged to you,

For a private hospital contracted with SGK ( Social Security Institution), it is necessary to check whether the legal ceiling has been exceeded.

7. What documents should you request from the hospital?

In disputes over excessive co-payments, the most critical evidence . According to SGK (Social Security Institution) contracts, private hospitals:

To prepare and deliver a document detailing all services provided to the patient and any additional charges, against signature
Display a sign showing the additional fee rate in a visible location .
If the emergency situation has ended, this must be reported in writing using the "emergency situation termination information form"

It is necessary.

Therefore, here are the essential documents you must request from the hospital:

Detailed Invoice
- Transaction codes (SUT codes),
- The fee for each transaction,
- Additional charges should be displayed separately.
"Document Showing the Services Provided to the Patient and the Additional Fee"
- This is a document explicitly stipulated in the SGK (Social Security Institution) contract and is mandatory to provide.
Emergency Situation Termination Form (if any)
- Transition from the emergency room to hospitalization is critically important.
Payment Documents
- Credit card slips,
- Bank statement,
- If you paid in cash, be sure to provide a receipt.

Without these documents, both filing a complaint with the Social Security Institution (SGK) and the Consumer Arbitration Board/Court process become considerably more difficult.

8. What happens if the difference in price exceeds the legal limits?

8.1. Sanctions Imposed by the Social Security Institution on Hospitals

Social Security Institution (SGK) – Private Hospital contracts stipulate very severe penalties for charging excessive additional fees

From the patient/patient's relative If it is determined that additional fees have been charged in violation of institutional regulations,
- For each patient, a penalty equal to 5 times the amount of the additional fee charged/overcharged will be applied
an additional fee to someone an additional fee, a penalty five times will be applied.
If an additional fee is charged for healthcare services that should not require one , a penalty equal to five times the additional fee charged will be applied for each patient .
However, if the hospital fully refunds the difference in fee charged/excess fee to the patient within 10 business days of the diagnosis , the penalty amount will only be determined equal to the additional fee charged (not 5 times).

Moreover;

If the additional fee rate is not written on the sign at all or is written incorrectly,
The 2024 agreement includes provisions for additional penalties amounting to tens of thousands of liras

8.2. Patient's Right to File a Complaint with the Social Security Institution (SGK)

If a citizen believes they have been charged an excessive fee , they can file a complaint directly with the Social Security Institution (SGK ). To this end:

relevant Provincial Social Security Directorate;

Applicants can submit their application with the invoice, additional charge receipt, payment slips, and, if possible, emergency application forms.
The Social Security Institution (SGK) will review the file; if any violations of the contract and SUT (Health Services Pricing Regulation) provisions are found,
- Both the hospital and the hospital are fined
- also opens the way for the patient to receive a refund of the excess additional fee charged .

8.3. Consumer Law Aspect: Consumer Arbitration Board, Consumer Court, Mediation

The relationship between a private hospital and a patient a consumer transaction . Therefore;

Excess refund,
Defective service,
Claims such as unfair contract terms can be filed with the Consumer Arbitration Board or the Consumer Court

8.3.1. Monetary Limit of Consumer Arbitration Boards for the Year 2025

According to the Ministry of Trade's announcement dated 20.12.2024 and the related Communiqué:

For the year 2025, applications to the Provincial/District Consumer Arbitration Board are mandatory for consumer disputes with a value below 149,000 TL
In disputes of 149,000 TL and above:
- Applications cannot be made directly to the Consumer Arbitration Board;
- The first stage of litigation is mediation , followed by the Consumer Court .

Therefore, the extra fee charged by the private hospital;

For example, 50,000 TL → application to THH (Turkish Consumer Arbitration Board),
For example, 200,000 TL → First, mediation would be involved, then a consumer court process.

8.3.2. Precedent-Setting Arbitration Panel Decisions

In recent years, numerous Consumer Arbitration Board decisions reported in the press have provided examples of private hospitals refunding additional fees that exceeded the legal limit

In 2025, a significant portion of the 24,000 TL fee charged by a private hospital in Kahramanmaraş was returned by an arbitration committee decision because it exceeded the legal limit
In 2025, in Kayseri, in the case of a patient who paid a total of 57,550 TL for angiography treatment, the arbitration committee that the legally mandated fee charged by the hospital was 24,468 TL , and that the 33,468 TL collected was excessive , thus ordering the hospital to refund this amount.

These decisions show that you are not alone in the matter of the difference in fees , and that refunds can be obtained if the appropriate documentation is submitted

8.4. The Perspective of the Supreme Court's General Assembly of Civil Law

The Supreme Court's General Assembly of Civil Law's decision dated November 22, 2018, 2017/636 E., 2018/1762 K. , contains important findings in the case concerning the illegality of the difference fee charged to patients covered by the Social Security Institution (SGK):

In summary:

The agreement signed between SGK (Social Security Institution) and the private hospital Healthcare Service Procurement Contract,
- This constitutes a contract for the benefit of a third party, in exchange for the rights of patients insured by the Social Security Institution (SGK)
The private hospital is aware of and accepts when providing services.
If the patient is overcharged in violation of these limits,
- Not just against the Social Security Institution,
- also accepted that one can be directly liable to the patient .

The decision is for the patient;

This provides a strong basis against the hospital's defense that "I am not a party to that contract, it does not bind me."

9. What should you do if you think you have overpaid?

8.1. Step 1 – Collect and Store Documents

Detailed invoice,
"Document showing service and surcharge"
Emergency forms,
Payment receipts, credit card slips,
If available, written information and consent forms obtained from the hospital,

it all intact and complete.

9.2. Step 2 – Check from the SGK Additional Fee Calculation Screen

From the SGK's additional fee calculation screen;

The name of the hospital,
The type/code of the operation performed,
Date of the transaction

By entering information such as this, the maximum difference that can be charged .

If there is a significant difference between the "maximum additional charge" displayed on the screen and the amount you paid, the likelihood of overpayment increases.

9.3. Step 3 – First, Submit a Written Application to the Hospital

Many legal experts and patient rights studies recommend that a written application be submitted to the hospital first

Addressed to the hospital's patient rights unit or chief physician,
Requesting an explanation and refund for any additional fees you believe were overcharged
Submit a dated, signed application with all supporting documents attached.

Hospitals often opt for refunds at this stage to avoid issues with the Social Security Institution (SGK)

9.4. Step 4 – Filing a Complaint with SGK (Social Security Institution)

If the hospital does not issue a refund or provide a satisfactory response,

To the Provincial Directorate of Social Security
Submit your application with the invoice, additional charge slip, and other required documents.

SGK (Social Security Institution);

The hospital requests a defense statement
If necessary, it checks for breaches of contract terms and whether the ceiling has been exceeded
If it is determined that an overcharge has occurred, the hospital will be fined, and refund process will be initiated for the patient.

9.5. Step 5 – Consumer Arbitration Board / Consumer Court

the overpayment received is less than 149,000 TL (for the year 2025):

Consumer Arbitration Board .
The application;
- Personally,
- Through a lawyer,
- Alternatively, you can do it through TÜBİS (Consumer Information System) via e-Government.

For disputes of 149,000 TL and above:

First, mandatory mediation as a prerequisite for filing a lawsuit.
If an agreement cannot be reached, the Consumer Court (or the Civil Court of First Instance if there is no Consumer Court).

The decisions of the arbitration panel;

within the legal time limit .
If not carried out properly, enforcement proceedings may be initiated.

9.6. Step 6 – Statute of Limitations and Evidence Strategy

Requests for refunds of difference in fees are generally a request for a return of "defective service" or an unfairly charged fee . In legal doctrine and practice;

The two-year statute of limitations period in Article 16 of the Turkish Consumer Protection Law ,
In some cases , longer periods may be discussed within the framework of tort/unjust enrichment provisions .

In practice, within two years of the service date is in the patient's best interest, both in terms of the freshness of the evidence and consumer litigation.

10. Difference Fees and Patient Rights in Private Hospitals – Summary and Evaluation

In light of the above information, here are the main points to remember regarding co-payments at private hospitals :

General ceiling:
- Private hospitals that have a contract with SGK (Social Security Institution),
- For normal healthcare services, the SUT (Social Security Institution) fee is a maximum of twice the standard rate.
- For exceptional healthcare services, three times the standard rate may be charged.
There are certain people and services for which charging extra is strictly prohibited:
- Individuals receiving honorary pensions, war/duty disability benefits, etc.,
- No additional fees may be charged for emergencies (excluding green zones), intensive care, burns, cancer treatments, newborns, organ transplants, hemodialysis, surgeries for congenital anomalies, and procedures listed in the relevant SUT (Health Services Pricing List) documents
In emergency departments, no additional fees can be charged until the emergency situation ends.
- To request a difference in payment after the emergency situation ends, a written and signed "Emergency Situation Termination Information Form" must be provided
The hospital is required to display the additional fee rate on a sign.
- There are serious penalties for incorrect signage or for no signage at all.
When an extra fee is charged;
- The hospital risks a penalty of up to five times the amount overcharged .
- The penalty amount may be reduced if the return is made within 10 business days.
Ways for patients to seek redress:
- First, a written application to the hospital,
- Then a complaint was filed with the Social Security Institution (SGK)
- Depending on the amount of the dispute the Consumer Arbitration Board (under 149,000 TL) or the Consumer Court (149,000 TL and above), and mandatory mediation as a prerequisite for filing a lawsuit.
The decisions of the Supreme Court and arbitration panels tend to favor the protection of the patient.
- The Supreme Court of Appeals has emphasized that SGK (Social Security Institution) contracts contracts for the benefit of a third party , thus granting patients a direct right to claim compensation .
- THH rulings have ordered the refund of excess fees charged in numerous cases .

11. Frequently Asked Questions

Question 1: Can a private hospital charge any additional fees it wishes from a patient covered by the Turkish Social Security Institution (SGK)?

No. Private hospitals contracted with SGK (Social Security Institution);

For normal procedures, the SUT fee is a maximum of twice the standard rate.
For exceptional cases, three times the may be charged.
Anything exceeding this limit is against the law and may be subject to recourse/complaint.

Question 2: They charged me an extra fee in the emergency room; is this legal?

During an emergency, no additional fees may be charged (except for green zone examinations).

If the emergency situation has ended and your consent is required for admission to the service,
The "Information form regarding the end of the state of emergency" must be handed over against a signature.

Charging additional fees during the emergency process without these conditions being met often constitutes a violation

Question 3: A private hospital asked me for an additional fee for my newborn baby. Do I have to pay it?

Healthcare services provided to newbornsare among the healthcare services for which no additional fees can be charged. Therefore, a difference fee should not be charged for services provided within the scope of the SUT (Healthcare Services Pricing Regulation) to a newborn baby of a patient covered by SGK (Social Security Institution) in a private hospital.

Question 4: The hospital quoted a low estimated fee upon admission; however, they charged a much higher difference upon discharge. What can I do?