Correctly Billing for Complementary Medicine in a Medical Practice

Table of contents

• Billing Complementary Medicine Correctly in a Medical Practice: An Overview
  • What Is and Isn't Considered Complementary Medicine
• What You Need for Billing
• Step 1: Determine the medical indication and treatment plan
• Step 2: Select the appropriate fee schedule for medical services
  • How HONÄR Is Structured
  • Individual item, analog grading, or none at all
  • What Health Insurance Contracts Cover—and What They Don't
  • Verification step before each invoice
• Step 3: Complementary Medicine and Health Insurance: Distinguishing Between Public Health Insurance (GKV), Private Health Insurance (PKV), and Self-Pay Patients
• Step 4: Correctly Prepare the Billing for Private Medical Services
  • The Workflow in Seven Steps
  • Sample Classification by Method
  • The Multiplier Effect: When It Works and When It Doesn't
  • Combination Rules and the Most Common Pitfalls
  • Pre-Shipment Checklist
• Step 5: Physician’s Fee Invoice in Austria: Required Information and Formal Pitfalls
• Step 6: Document and explain complementary medical treatments
• Common Errors in Billing for Complementary Medicine Services
• Conclusion: Legally compliant billing with a clear structure
• Frequently asked questions

Last updated: October 9, 2026

Billing Complementary Medicine Correctly in a Medical Practice: An Overview

Billing for complementary medicine correctly in a medical practice is where many practices lose time and money. The reason is rarely a lack of expertise. More often than not, there is a lack of a clear structure: Who pays? On what basis? And how is it documented? At Herbert Eder, we have been supporting users and therapists at precisely this intersection since 1994. In this guide, we’ll show you step by step how to Complementary Medicine Services Record, assign, and bill them in a legally compliant manner.

First, the most important distinction.

Complementary medicine is the complementary use of practices such as acupuncture, Traditional Chinese Medicine (TCM), or naturopathy in addition to conventional medicine. It does not replace conventional medicine, but rather complements it.

Alternative Medicine In contrast, this term refers to procedures used in place of conventional treatment. This distinction determines later on whether a service is eligible for reimbursement at all.

Important for billing: The price is not determined by the method alone. The decisive factors are the medical indication, the choice of fee schedule, and the patient's insurance status.

What Is and Isn't Considered Complementary Medicine

Not every treatment that patients request is automatically considered a medical service. That is the first hurdle.

Typical complementary treatments used in clinical practice include:

• Acupuncture and Traditional Chinese Medicine
• Naturopathic Treatments
• Organizational Therapy and Lifestyle Counseling
• Methods of information medicine, such as frequency therapy

Services that are purely energy-based or esoteric in nature and have no medical basis are not included. They also cannot be billed under a medical fee schedule.

The line is blurred, and this is exactly where most mistakes occur. A service is considered a billable medical service only if there is a medical indication and it is provided or ordered by a physician.

Anyone who wants to document a complementary medicine treatment must therefore first determine: Is this a medical service? If not, it does not belong on a medical bill.

What You Need for Billing

Before you send out your first invoice, there are four things you need. Without them, every billing process becomes a guessing game.

• A clear indication for each service
• The Appropriate Fee Schedule for medical services
• Insurance Status the patient's insurance status—that is, whether they have public, private, or self-pay coverage
• Complete documentation including information and consent

What many practices underestimate: These four points are interconnected. If the insurance status changes, the fee schedule changes. If the medical indication changes, the treatment plan changes. And without documentation, it will be impossible to prove later why a particular item was justified.

A common mistake is to wait until the end of the month to prepare the invoice. By then, details are missing, and the invoice becomes vulnerable to criticism.

Step 1: Determine the medical indication and treatment plan

The medical indication is the basis for every complementary service. It explains why a treatment is medically justified.

Without a medical indication, there is no justification for the bill. Period.

The treatment plan specifies:

• What diagnostic tests have been performed?
• What treatment method is planned
• How many sessions are scheduled
• What is the goal of the treatment?

A treatment plan intended to supplement conventional treatment should explicitly state this. This protects you and keeps the patient informed.

In practice, this means: Write down the diagnosis, the procedure, and the planned number of sessions in a single sentence. That's enough to start with, and you can expand on it later.

The clearer the medical indication, the fewer questions there will be regarding reimbursement.

Step 2: Select the appropriate fee schedule for medical services

Doctors bill for their services according to the applicable fee schedule. Which one applies depends on the payer.

• For Private patients and Self-Pay Patients the following applies: Schedule of Fees for Physicians (HONÄR).
• For Patients with public health insurance the following apply: Contracts with Social Security Agencies.

Complementary medical services are generally not included in the health insurance contracts. Therefore, they are almost always billed privately or provided as a self-pay service.

That is the key point: The choice of fee schedule determines which items are even permissible. Not every complementary service has its own item code. Some are billed by analogy, while others are not billed at all.

How HONÄR Is Structured

The HONÄR is not a price list with fixed amounts, but rather a Rating System. Every service has a Score (the „assessment figure“). The actual amount is determined only after multiplying it by the Point Value and the Multiplier:

Fee = Evaluation Score × Point Value × Multiplier

This leads to three consequences that are frequently overlooked in practice:

1. The point value isn't set in stone. It is agreed upon between the contracting parties and is subject to change. An invoice issued using an outdated point value is vulnerable to challenge.
2. The multiplier is the lever. The standard rate is based on a specific factor; any increase beyond that must be justified. Without justification on the invoice, the increased factor is not valid.
3. The rating is fixed. It is non-negotiable. Anyone who chooses a higher position than their performance warrants risks rejection.

Individual item, analog grading, or none at all

There are three scenarios involving complementary medicine:

• Position available: The service is billed directly using the corresponding number. That's the simplest scenario.
• No specific position, but comparable performance: Then comes a Analog Evaluation in question. In this process, an item that is comparable in nature and scope is used as a reference and marked as “analogous” on the invoice. The justification must be included.
• Non-depictable service: In that case, it may not be billed through the HONÄR system. This includes purely energy-based or esoteric services with no medical connection.

What Health Insurance Contracts Cover—and What They Don't

The contracts with social insurance providers specify which medical services may be provided and billed at the insurer’s expense. Anything not listed there is not reimbursed. Therefore, the following almost always applies to complementary therapies: They are not included in the insurer’s list of covered services.

That does not mean that patients with public health insurance cannot receive complementary treatment. It means that the coverage then privately or as a self-pay service is billed—with the same formal requirements as for a private patient.

Verification step before each invoice

Before you record a transaction, clarify the following in this order:

1. Was the service provided or ordered by a physician? If not, it does not belong on a medical bill.
2. Is there a specific position in the selected order? If so, use those.
3. If not: Is an analogous assessment reasonable? If so, mark it as "analog" and explain why.
4. If not: Do not bill using this code. Instead, as a service provided solely on a self-pay basis, with clear information provided.

Before issuing each invoice, check whether the service provided can be reflected in the selected classification. If not, it must not be listed as a cash service.

Submit a request via our contact form →

Step 3: Complementary Medicine and Health Insurance: Distinguishing Between Public Health Insurance (GKV), Private Health Insurance (PKV), and Self-Pay Patients

The key question regarding complementary medicine and health insurance is: Does the health insurance provider, the private insurer, or the patient pay?

The answer depends on your insurance status, and the procedures vary significantly. The following overview will help you figure it out:

Cost Center	Basis	A Typical Approach in Complementary Medicine
Statutory Health Insurance	Contracts with Social Security Agencies	Usually not included; reimbursement may be available on a case-by-case basis
Private Health Insurance	Fee Schedule for Physicians	Reimbursement depends on the plan and the agreed-upon terms
Self-Pay Patients	Fee Schedule for Physicians	Direct private payment; full bill sent to the patient

The following applies to statutory health insurance: Complementary treatments are eligible for reimbursement only if they are provided for in the applicable regulations. This is rarely the case. Social insurance providers determine which medical services may be covered by the insurance plan. Anything not listed there will not be reimbursed.

For those with private insurance, it depends on the plan. Some plans cover acupuncture or naturopathy, while others do not. Be sure to clarify this before treatment, not after.

Self-pay patients pay the full bill themselves. Providing clear information is especially important in this case.

Step 4: Correctly Prepare the Billing for Private Medical Services

The "Private Medical Services Billing" feature is at the heart of complementary billing. You create an invoice that complies with the fee schedule for physicians.

The Workflow in Seven Steps

Following a consistent procedure prevents most errors. Work through the steps in this order:

1. Record performance: List each service provided individually—do not group them together; instead, record them during or immediately after the treatment.
2. Assign position: Find the appropriate code in the fee schedule. For analogous billing, select the comparable item and mark it as analogous.
3. Check combination rules: Some items cannot be billed together. Check whether services are mutually exclusive or can be billed only once per session.
4. Set the factor: Standard rate or justified adjustment factor. The justification should be included on the invoice, not in the file.
5. Create an invoice: Clearly list the items, date, rating, score, factor, and fee.
6. Check required information: Name and address of the practice, name and address of the patient, date of service, items billed, fee per item and total, and adjustment factor with justification.
7. Proofread before shipping: Taking a second look at the date, positions, and factor helps prevent the most common follow-up questions.

Sample Classification by Method

The following mappings are illustrative and serve as a conceptual framework. Before preparing any invoice, check the current fee schedule and the applicable combination rules—the specific codes and valuation figures are subject to change.

• Acupuncture: This can generally be coded under a separate code or a comparable service in the field of physical medicine. Be sure to note whether the session is scheduled as a single service or as part of a series.
• Traditional Chinese Medicine (TCM): Often consists of several individual services—medical history, pulse and tongue diagnosis, and acupuncture. These are recorded separately, provided that the regulations so require.
• Naturopathic Treatments: Often involves a significant amount of counseling and medical history-taking. The counseling session and the actual procedure must be recorded separately.
• Organizational Therapy and Lifestyle Counseling: This can generally be reflected in consulting roles. The effort involved determines the factor.
• Methods of Information Medicine: Special caution is required here. Check whether the medical service in question is even billable. If not, it does not belong in the fee schedule.

The Multiplier Effect: When It Works and When It Doesn't

The markup is a frequent point of contention. It may only be increased if the effort involved justifies it, and the rationale must be included on the invoice.

Common reasons for having an elevated factor:

• Increased time required compared to the standard procedure, such as when taking a detailed medical history or providing multiple individual services during a single session.
• Increased Difficulty the procedure, for example, in cases involving specific anatomical or diagnostic conditions.
• Aggravating Circumstances, for example, when the patient has limited communication abilities.

What constitutes an elevated factor not says: „That’s always the way it is with us.“ Generalizations are not accepted during the review.

Combination Rules and the Most Common Pitfalls

• Avoid duplicate entries: A service that is included in another service may not be billed separately.
• Note the session context: Some items can be billed only once per session, even if the service was provided multiple times.
• Separating Diagnosis and Treatment: Both must be recorded separately because they are billed separately.
• Check series and flat rates: Some regulations provide for series or flat-rate items. If you bill for individual services even though a series is specified, your claim will be rejected.

What many practices do wrong: They copy items from old invoices without checking the current fee schedule. This is risky—point values, items, and combination rules can change.

Pre-Shipment Checklist

• Each item is listed individually and dated.
• Each item can be mapped to the selected order or is marked as analogous and the reason is provided.
• Combination rules have been checked.
• The adjustment factor is justified if it exceeds the standard rate.
• All required information is included.
• Point totals and ratings are current.
• The invoice has been proofread.

Step 5: Physician’s Fee Invoice in Austria: Required Information and Formal Pitfalls

A fee invoice must include certain required information (Requirements for an Invoice). If one is missing, the reimbursement may be denied.

• Name and Address of the Practice
• Patient's Name and Address
• Date of Service Provision
• Services Rendered by Item
• The fee per item and the total
• The multiplier, with an explanation

Formal pitfalls are the second most common cause of inquiries. An incorrect date, a missing item, an unjustified factor—and the invoice gets sent back.

The fee statement is not a receipt. It is a private invoice. Please handle it with due care.

Step 6: Document and explain complementary medical treatments

Documenting a complementary medicine treatment means recording everything that justifies the service.

These include:

• Informing the patient about the benefits and limitations
• Written Consent
• The Course of Treatment
• The billing items

It is mandatory to provide this information. The patient must understand that this is a supplemental service that is not automatically reimbursed. This applies especially to patients who pay out of pocket.

Without consent, there is no legal basis. Without documentation, there is no proof.

Common Errors in Billing for Complementary Medicine Services

Most billing errors are recurring. If you know what they are, you can avoid them.

Error	Episode	Here's How to Avoid It
Lack of medical indication	Invoice cannot be justified	Document the indication in advance
Incorrect Fee Schedule	Position not allowed	Determine the insurance provider during the initial contact
Health Insurance Benefit Without Basis	Invoicing Error Possible	Bill only for what is specified
Unjustified Multiplier	Invoice is rejected	Provide a written justification for the expense
Lack of Information	Consent is invalid	Document the information provided in writing

Another mistake: the failure to distinguish between diagnosis and treatment. Both must be recorded separately because they are billed separately.

And one last thing: settling accounts too late. The longer the time that has passed, the less accurate your memory becomes.

Conclusion: Legally compliant billing with a clear structure

Billing for complementary medicine correctly in a doctor's office is not rocket science; it's simply a matter of structure.

Determine the medical indication, select the correct fee schedule, distinguish between the different payers, and keep complete records. Then every invoice will hold up.

At Herbert Eder, we have been supporting users and therapists who wish to use complementary therapies responsibly since 1994. Our seminars and expert articles clearly outline the possibilities and limitations. This provides you with sound knowledge to guide your individual approach, both in practice and in billing.

Frequently asked questions

Does health insurance cover complementary medicine?

Generally not. Services such as acupuncture, naturopathy, or traditional Chinese medicine are usually not included in the list of benefits covered by statutory health insurance. Some health insurance plans voluntarily reimburse certain procedures as part of their statutory benefits. Those with private insurance should check their policy to see if complementary medicine treatments are included. Clarify eligibility for reimbursement with the insurance provider before beginning treatment and document the information provided.

How is complementary medicine treatment billed as a private service?

As a private service, the treatment is billed according to the Fee Schedule for Physicians (HONÄR). You determine the medical indication, select the appropriate service items, multiply the point value by the adjustment factor, and provide written justification for any deviations from the standard maximum rate. Before treatment begins, it is advisable to enter into an agreement with the patient that specifies the nature, scope, and estimated costs of the treatment. Without this agreement, you risk a dispute over the bill.

What should an invoice for complementary medicine services include?

A fee statement must be clear and unambiguous: it must include the name and address of the practice, the name and address of the patient, the invoice date and invoice number, the treatment period, the services provided with dates, the applicable HONÄR codes with their respective surcharge rates, and the total amount. For self-paying patients, the invoice must include a note stating that the health insurance provider will not reimburse the costs. Keep a copy on file and note the date the invoice was sent.

How should complementary medicine services be documented?

Document every complementary medicine treatment in a way that ensures it remains traceable: medical history, diagnosis, medical indication, chosen treatment method, course of treatment, and information regarding benefits and limitations. The patient must confirm consent in writing. This documentation will later support the invoice, substantiate the medical necessity, and protect you in the event of inquiries from the health insurance provider or the patient. Retain the records in accordance with the retention periods specified by professional regulations.

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Billing for complementary services remains challenging because payers, fee schedules, and regulations are constantly changing. If you want to rely on a trustworthy framework, Herbert Eder is the right choice: with structured training programs, personalized on-the-job support, and practical, expert articles. This way, you’ll maintain a clear overview of indications, fee schedules, and documentation. Get started with Herbert Eder and put your billing on a legally sound footing.