Maverick Advocaten requests NZa to take enforcement action against Zilveren Kruis for breach of healthcare procurement regulations

Diederik Schrijvershof and Annabel Kingma have submitted an enforcement request to the Dutch Healthcare Authority (“NZa”) on behalf of several general practitioners. The enforcement request relates to a breach in 2021 by Zilveren Kruis of the NZa Regulations on Transparency in Healthcare Purchasing under the Healthcare Insurance Act (the “Healthcare Procurement Regulations”). In breach of those Regulations, Zilveren Kruis failed to adequately respond in a timely manner to questions and comments from GPs about a contract that Zilveren Kruis uses in the GP care procurement process in 2022 and 2023.

NZa Healthcare Procurement Regulations

The NZa had previously fined DFZ, a division of Zilveren Kruis, for breach of the Healthcare Procurement Regulations: see here, here and here. The NZa has also issued several formal warnings for breaches of the Healthcare Procurement Regulations by insurers. It has warned, for instance, Zorg en Zekerheid, CZ, VGZ (twice) and DSW about breaches of the Healthcare Procurement Regulations. In 2019, the NZa announced (see here and here) that it would take stricter action against (repeated) breaches of the Healthcare Procurement Regulations. VGZ ignored two formal NZa warnings and in 2019 again breached the Healthcare Procurement Regulations to the detriment of healthcare providers. The NZa fined VGZ in 2020 and imposed a second fine on it at the end of 2021 for breach of the Healthcare Procurement Regulations.

For many years, Maverick Advocaten has advocated adequate mandatory rules (and the enforcement of those rules) for healthcare insurers in healthcare procurement and action against excessive purchasing power of health insurers. More information can be found here, here, here, here, here, here, here, here and here. More information on the rights of healthcare providers and the obligations of health insurers can be found at

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Contact details

Diederik Schrijvershof

T +31 20 238 20 03
M +31 6 81 364 318

Annabel Kingma

T +31 20 238 20 07
M +31 6 15 366 257