AmCham raised concerns regarding the HZZO public tender procedure for determining drug prices (2017). The main issues are:

• lack of transparency in the methodology for defining therapeutic groups, inconsistent with the EU Transparency Directive,
• short 3-month reference period for drug consumption data, which reduces relevance and increases risk of misuse,
• legal uncertainty in the appeals process, as deadlines for appeals and responses run in parallel, undermining effective legal protection.

AmCham recommends: annulment of the tender decision, a full review of procedures, extension of the reference period to at least 6–12 months, and establishment of expert working groups to revise methodology and amend the rulebook.