Correctly Billing for Information Medicine in Naturopathy

Table of contents

• Why Billing for Informational Medicine Requires Its Own Rules
• The Legal Basis: GebüH, GOÄ, and the Hufeland Directory
• Billing for Analog Evaluations: How to Select the Correct Code
• GebüH Billing Recommendations for Bioresonance and Frequency Therapy
  • Specific Analog Numbers for Bioresonance Therapy
  • The Significance of Point Values and the Requirement to Provide Justification
  • A template for the description of services on an invoice
• Fee Agreement Template for Alternative Practitioners: What to Clarify Before Treatment
  • The Difference Between a Naturopath and a Medical Doctor
  • A tried-and-true template for your fee agreement
  • Avoiding Common Mistakes When Negotiating Fees
• Documentation Requirements: How to Ensure Your Invoicing Is in Order
• Reimbursement for Privately Insured Patients: Handling Inquiries from Private Health Insurance Providers
• Common Billing Errors and How to Avoid Them
• Conclusion: A Clear Structure Leads to Legally Sound Billing
• Frequently asked questions

Last updated: September 9, 2026

Why Billing for Informational Medicine Requires Its Own Rules

Billing for Information Medicine In naturopathic practice, this leads directly into a gray area of German and Austrian fee regulations. Unlike traditional acupuncture or manual therapy, information medicine does not have its own list of services that you, as a practitioner, could easily access. The discrepancy between what you provide therapeutically and what fee schedules formally cover is the real challenge. (Source: Hufeland Index)

The good news: There are established ways to close this gap in a legally compliant manner. The bad news: Most billing errors do not stem from malicious intent, but rather from a lack of knowledge about the complex regulations. Those who understand the basics of fee schedules can accurately bill for medical information services while maintaining their patients’ trust. This guide by Herbert Eder shows you how to document your services transparently, code them correctly, and confidently address any inquiries from payers.

Because one thing is clear: Billing for information-based medicine always involves actively managing patients’ expectations regarding reimbursement. Only those who view billing as part of the treatment contract can operate in a financially sound and legally compliant manner over the long term.

The Legal Basis: GebüH, GOÄ, and the Hufeland Directory

The billing framework for naturopathic practices rests on three pillars, which you must clearly distinguish. The Fee Schedule for Naturopaths (GebüH) serves as the basis for naturopaths and lists traditional naturopathic services with fixed point values. For physicians, however, the GOÄ—the Fee Schedule for Physicians—applies, with its own billing codes and multiplier rates.

The third pillar is the Hufeland Directory, a supplementary fee schedule developed specifically for complementary medicine procedures. It contains over 1,600 billing items that are not covered—or are only inadequately covered—by the GOÄ and GebüH (hufelandgesellschaft.de). The Hufeland Directory often provides the right starting points, especially for medical informatics, because it includes procedures such as Bioresonance Therapy and explicitly lists frequency therapy.

The key point for your practice: The choice of billing basis depends on your professional group. Alternative practitioners primarily bill according to the GebüH, but may use analogous billing codes under certain conditions. Physicians are bound by the GOÄ but may use the Hufeland directory as a guide for analogous codes. You should firmly incorporate this distinction into your practice management to avoid billing errors from the outset.

Billing for Analog Evaluations: How to Select the Correct Code

Analogous billing means that, for a service that does not have its own fee code, you select a comparable item from an existing list of services. Billing for analogous services requires a systematic approach, because the selected code must correspond as closely as possible to the service provided in terms of type, cost, and time required.

A practical example: There is no direct billing code in the GebüH for bioresonance-based diagnostics. You should compare the service provided with the available billing codes and select the one that most closely matches the diagnostic procedure. It is essential that you document this choice and provide a rationale for it.

You should consider the following criteria when selecting a number:

• Therapeutic effort and duration of treatment
• Equipment Used and Technical Scope
• Comparability with the originally defined performance
• How Common Is This Type of Evaluation in Your Region?

You must clearly identify the selected analogous code on the invoice by adding the word „analogous.“ If this designation is missing, you risk encountering significant problems when private health insurers review your invoice. A carefully justified analogous assessment ensures transparency and prevents follow-up inquiries.

GebüH Billing Recommendations for Bioresonance and Frequency Therapy

The biggest weakness of many billing guides is their vague recommendation to „select an appropriate analogous code“ without providing any specifics. In practice, however, clear guidelines are needed. The following recommendations are based on the GebüH classification system. While they do not replace an individual assessment in each specific case, they do provide a solid starting point.

Specific Analog Numbers for Bioresonance Therapy

Bioresonance therapy is a procedure that encompasses various components depending on the method used. The GebüH does not provide for a flat-rate billing category for „bioresonance therapy.“ Instead, it is recommended to break down the procedure into the following steps, which are standard practice:

1. Testing and fine-tuning individual frequencies: The number 18 (Allergen and Drug Testing) or 19 (Testing for contaminants, e.g., heavy metals) from the GebüH. These items most closely reflect the diagnostic effort involved in determining frequencies. Item 18 is intended for testing substances, which can be applied by analogy when identifying individual reaction patterns to frequencies.
2. The actual therapeutic application: For the treatment itself, the code 8 (Reflexology) or 17 (Treatment using electrical, magnetic, or mechanical stimuli) is cited by analogy. Paragraph 17 is often the first choice here, as it covers device-based procedures. The key justification is that bioresonance constitutes an electromagnetic stimulus that is used for therapeutic purposes.
3. The final consultation and documentation of the patient's progress: The time required for the discussion following the meeting can be specified using the code 43 (Consultation) or, in the case of a more detailed discussion of the treatment plan, regarding the item 44 (Discussion of the Treatment Plan) be displayed.

The Significance of Point Values and the Requirement to Provide Justification

Each GebüH code has a fixed point value. However, a higher point value is not a reason to choose an inappropriate code. The choice must always be justified based on the services actually provided. Therefore, in your invoice, you should not only list the code and the text, but also include a brief, precise note such as „similar to GebüH 17: bioresonance therapy for regulating energy metabolism.“.

A template for the description of services on an invoice

A clear, transparent billing item for a bioresonance session might look like this:

Item 1: GebüH 17 analog – Bioresonance Therapy (Frequency therapy) for treating an existing energy deficiency; duration: 30 minutes, including use of the therapy device.
Item 2: GebüH 18 analog – Testing of 12 individual frequencies to determine the therapeutically effective treatment parameters.

This breakdown provides transparency regarding the services provided to the patient and the private health insurance company. It shows that it was not „simply a matter of connecting a device,“ but rather that a specific diagnostic and therapeutic service was provided. This transparency is key to ensuring a smooth reimbursement process.

Fee Agreement Template for Alternative Practitioners: What to Clarify Before Treatment

Most articles explain the theory behind fee agreements but leave readers wondering, „How do I actually word this?“ A legally sound fee agreement is more than just a formality—it protects you from losing fees and from disputes with patients. It is crucial that it before The agreement sets forth the start of treatment and clearly and unambiguously addresses all relevant points.

The Difference Between a Naturopath and a Medical Doctor

The GebüH applies to alternative practitioners. A fee agreement is required if you wish to apply a multiplier higher than the standard 1.0x rate. Without such an agreement, you may only charge the base rate. For physicians who bill according to the GOÄ, the provisions of § 2 GOÄ apply (bundesaerztekammer.de). Here, too, a written agreement prior to treatment is required to justify a higher multiplier (up to 3.5 times). The agreement must refer to specific services and may not apply across the board to all services.

A tried-and-true template for your fee agreement

You can use the following template as a basis for your own agreements. It has been deliberately worded to meet the requirements for transparency and legal certainty.

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Fee Agreement for Naturopathic Services

Between

Treating Physician: [Name, Address, Job Title]

and

Patient: [Name, Address, Date of Birth]

The following agreement is made regarding the treatment beginning on [date]: (Source: Schedule of Fees for Physicians (GOÄ))

1. Subject of the Treatment

Treatment using methods of information medicine—specifically [e.g., bioresonance therapy, frequency therapy, magnetic field therapy]—is planned. The medical necessity of the treatment was discussed in advance and is acknowledged by the patient.

2. Fee Agreement

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The fee for the services rendered is calculated based on the fee schedule for alternative practitioners (GebüH). A multiplier of [e.g., 2.5 times] is agreed upon for the following services provided as part of the treatment:

• [Code and description of the service, e.g., GebüH 17, analogous to: bioresonance therapy]
• [Item Number and Description of Service]

3. Rationale for the Increased Rate of Increase

The higher rate is agreed upon because the treatment requires an above-average amount of time and necessitates special technical equipment as well as specific professional qualifications on the part of the practitioner.

4. Note on Reimbursement

The patient is aware that reimbursement of costs by his or her private health insurance provider or subsidy agency depends on their respective terms and conditions. The treating physician cannot guarantee reimbursement.

5. Final Provisions

This agreement is entered into before treatment begins. The patient is advised to review the agreement carefully before signing it.

City, Date: __________________

Treating Physician's Signature: __________________

Patient's Signature: __________________

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Avoiding Common Mistakes When Negotiating Fees

A common mistake is using vague phrases such as „for all services in the course of treatment.“ This is legally vulnerable, as the agreement must be specific to each service. Therefore, always specify exactly which services will be billed and at what rate. Another mistake is failing to provide a justification for the increased rate. Without a clear justification, the patient may refuse to pay, or the insurance company may reduce the amount. The justification must be tailored specifically to the treatment—a general phrase such as „due to particular difficulty“ is not sufficient.

Documentation Requirements: How to Ensure Your Invoicing Is in Order

Documentation requirements in naturopathic practice are the invisible backbone of every accurate billing process. Complete documentation is not only required by professional regulations, but also actively protects you against claims for reimbursement and makes it easier to respond to inquiries from payers. Anything that is not documented is considered not to have been provided.

Comprehensive documentation should include the patient’s medical history and findings, the planned and administered therapy, the devices and frequencies used, and the duration of treatment. Also, make a note of the informational discussions you have had and the agreements that were reached. This information forms the basis for your billing and serves as evidence in case of dispute.

The integration of documentation and billing should be firmly established in your practice management system. Every billing item must be clearly traceable to a documented treatment step. This consistency not only makes the audit process easier but also increases insurers’ willingness to reimburse your bills promptly and in full.

Reimbursement for Privately Insured Patients: Handling Inquiries from Private Health Insurance Providers

Reimbursement for private patients is the area where many naturopathic practices waste time and get frustrated. It’s not uncommon for private health insurers to raise questions about items related to informational medicine, since claims processors are often unfamiliar with the specific procedures. How professionally you handle these inquiries determines whether your services will be eligible for reimbursement.

Prepare for common follow-up questions by making your invoices easy to understand from the start. Each line item should describe the service in language that even a layperson can understand. Avoid purely technical terms without an explanatory note. The insurance company also needs a clear explanation of why the treatment was medically necessary and which code you used for billing purposes.

If you have any questions, please remain objective and cooperative. You may provide the treatment records in anonymized form, provided the patient has given his or her consent. Persistent refusals to reimburse can often be resolved through a personal conversation with the responsible claims adjuster, during which you can explain the unique aspects of information medicine. The terms and conditions of private health insurance (PKV) provide the framework within which you can present your case.

Common Billing Errors and How to Avoid Them

The most common billing errors in naturopathic practices follow a recurring pattern: a lack of care when selecting billing codes and insufficient documentation. By recognizing these errors, you can actively avoid them and build a solid foundation for your billing.

The following overview lists the critical issues and their solutions:

Billing Error	Correct Procedure	Impact
Missing „analog“ label“	Always clearly label analog digits	Avoids claims for recourse
Retroactive Fee Agreement	Sign the agreement before treatment begins	Guarantees the agreed-upon rate of increase
Unclear Statement of Work	Choose clear and understandable wording	Speeds up reimbursement
Incomplete documentation	Make every position fillable	Provides protection during invoice verification

Another common mistake is billing entire treatment series as a single, undifferentiated lump sum. Insurance companies often reject such collective invoices because they cannot verify the medical necessity of the individual sessions. Bill each session individually and document the respective progress of the therapy. This transparency directly pays off when it comes to reimbursement eligibility.

Choosing an unreasonably high markup rate without medical justification is also problematic. An increased rate is justified only if special circumstances of the treatment warrant it, such as an unusually high time commitment or a particular difficulty. You must state this justification on the invoice; otherwise, the insurance company will reduce the amount to the base rate.

Conclusion: A Clear Structure Leads to Legally Sound Billing

Billing for information medicine in a naturopathic practice is challenging, but it can be managed effectively with the right structure. Three key factors are crucial: the correct selection of the billing basis from the GebüH, GOÄ, and Hufeland Index, thorough documentation of all services, and transparent communication with patients regarding costs and reimbursement.

Those who master these fundamentals not only avoid billing errors but also position their practice as a reliable partner for patients and insurance companies. Investing in a well-organized billing system pays off in the form of fewer follow-up inquiries, faster reimbursements, and greater legal certainty. In his training courses and seminars, Herbert Eder imparts precisely this in-depth knowledge, which goes beyond the mere application of frequency therapy and views billing as an integral part of a responsible practice.

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Legally compliant billing for information medicine requires a solid understanding of fee schedules and consistent documentation. Since 1994, Herbert Eder has offered in-depth expertise in frequency therapy and information medicine to enable interested individuals and professionals to apply these methods responsibly and in a practical manner. Through a unique combination of personalized practical guidance, structured training programs, and scientifically grounded professional articles, he explains complex concepts in an accessible way. His approach is characterized by a precise assessment of the possibilities and limitations, providing users and therapists with well-founded knowledge for individual guidance. Learn more about the training programs available and get started with a clearly structured, legally compliant billing practice.

Frequently asked questions

Is there a specific fee schedule for alternative practitioners (GebüH) in the field of informational medicine?

There is no separate fee schedule for information medicine. Billing is based on the Fee Schedule for Alternative Practitioners (GebüH). Since bioresonance and frequency therapy are not listed there as separate codes, use the analogous assessment method: Select a service from the GebüH that is comparable in content and document the discrepancy in writing. A careful justification for the code selection is crucial to ensure that the invoice withstands scrutiny by patients or insurance companies.

How does billing for information medicine differ from that of traditional naturopathic treatments?

Traditional naturopathic treatments such as acupuncture or manual therapy often have their own, clearly defined codes in the GebüH. Information-based medical procedures such as bioresonance do not have specific billing codes. Therefore, you must rely on analogous classifications. In addition, the documentation requirements are more stringent: You must provide a detailed justification for the medical necessity and the selected analogous code. An individual fee agreement with the patient establishes transparency and legal certainty for both parties in advance.

How are information medicine services properly documented in practice?

Proper documentation consists of four elements. First, the patient’s medical history and the reason for treatment. Second, a detailed description of the method used—such as bioresonance or frequency therapy—including the devices and settings employed. Third, the selected billing code from the GebüH, along with the rationale for the analogous assessment. Fourth, the course of treatment and the outcome. This documentation must be completed promptly after the session and be understandable to the patient. It serves as the basis for billing and for any inquiries from private health insurance providers.

Can patients submit claims for information medicine services to private health insurance companies?

In general, patients can submit bills for informational medicine to their private health insurance (PKV). Whether the costs are reimbursed depends on the individual plan. Many private health insurance companies scrutinize bills with “analog” codes particularly closely. A clear invoice that explains the selected codes and the medical necessity increases the likelihood of reimbursement. Recommend that patients review their insurance terms and conditions before beginning treatment. A written fee agreement provides clarity regarding the costs, regardless of whether the insurance company later reimburses them.