Saudi Arabia moves admitted private-insurance care to DRG payment in 2028. Each hospital's price will be negotiated on the case mix it proves in 2026 and 2027, so the coding done now sets revenue after the switch.
The Council of Health Insurance's DRG Implementation Guideline, version 1.0, published in 2026, makes DRG-based reimbursement mandatory for all admitted care under Saudi private health insurance from 1 January 2028. Payment becomes a base rate multiplied by a relative weight. CHI's Market Reference Price is expressly not a tariff: each hospital negotiates its own base rate with each payer, and the guideline tells it to argue from the case mix index its shadow-billing claims show in 2026 and 2027. A hospital that codes badly now enters that negotiation with an understated case mix. Implants, chemotherapy drugs and specialised devices stay outside the case price.
What a board member needs before the next meeting on this.
- There is no DRG tariff to model. CHI's Market Reference Price is a benchmark that the guideline says does not constitute a mandated tariff. Each hospital negotiates its own base rate with each payer, above or below the reference, so 2028 revenue is a contract outcome and not a published number.
- Shadow billing is the negotiating file. The guideline tells providers to use the case mix index from shadow billing to show payers how complex their patients are. Under-documented episodes group to lower-weight DRGs, so weak coding in 2026 and 2027 understates the evidence a hospital brings to its 2028 negotiation.
- Two coding rules are already firm. Error DRGs may not exceed 3% of episodes in any month, with a mandatory improvement plan after two consecutive months over, and an annual external coding audit by a CHI-approved vendor is mandatory from 1 January 2027. Most other readiness thresholds are marked as pending CHI confirmation.
- High-cost items stay outside the case price. Prostheses and implants, chemotherapy drugs, specialised devices, pre-admission emergency services and follow-up beyond 14 days are billed separately. Cardiology, orthopaedic and oncology revenue keeps its largest items outside the DRG; a medical-admission-heavy hospital does not have that cushion.
The Council of Health Insurance published version 1.0 of its DRG Implementation Guideline in 2026, approved by its Secretary General as the initial release for the shadow billing phase (CHI DRG Implementation Guideline v1.0). It sets three phases: market preparedness from 2022 to 2025, shadow billing in 2026 and 2027 with no reimbursement impact, and from 1 January 2028 the mandatory adoption of DRG-based reimbursement for all admitted care under private health insurance.
Inpatient and day-case episodes stop being paid line by line. Each episode is grouped into one of 803 AR-DRG v9.0 groups and paid as a base rate multiplied by that group's relative weight. For anyone valuing a Saudi private hospital, the admitted-care revenue line after 2027 no longer follows from its fee-for-service history.
The reference price is not a tariff
A reader expects the regulator to publish a price per case. CHI does publish a benchmark, the Market Reference Price, built from NPHIES claims data as a base price times each DRG's relative weight, and the guideline says twice that it does not constitute a mandated tariff.
Each hospital negotiates its own base rate with each payer, and the guideline lists what may move it above or below the reference: hospital size and service mix, quality indicators, location and operating cost, length of stay and readmissions, case mix, network strategy and volume commitments. Section 7.4 says CHI publishes the full relative-weight table on its website.
When we checked CHI's Clinical Classification Standards page on 30 September 2026, it linked the guideline, a DRG white paper and a diagnostic-packages note, and neither a weight table nor a reference price value.
Shadow billing is the negotiating file
During 2026 and 2027 every admitted claim sent through NPHIES carries two things: the fee-for-service claim that pays, and a DRG code produced by a CHI-certified grouper that does not. CHI extracts the case mix index, the error-DRG rate and the variance between DRG and fee-for-service payment from that data, and payers are told to use the same comparison to prepare for contracting.
The guideline tells providers to use their shadow-billing case mix index to demonstrate the complexity of their patients. It also says what happens when documentation is thin: the episode is under-assigned to a lower-complexity DRG and paid less than is clinically appropriate. On our reading, a hospital that codes poorly through 2027 walks into its 2028 base-rate negotiation with a case mix that understates its patients, and the payer holds the same data.
Get the instruments that touch your licence, assessed, as they are issued. See Regulatory Watch
Two rules are firm and most thresholds are not
Section 4.2.3 caps error DRGs at 3% of submitted episodes in any reporting month, and a provider over that line for two consecutive months must run a mandatory improvement plan covering coder training, documentation review and data quality fixes. The same section makes an annual external coding audit by a CHI-approved vendor mandatory from 1 January 2027, on top of quarterly internal audits.
The wider key performance indicators, including first-pass coding accuracy of at least 80%, sit in a table headed as proposed targets pending CHI confirmation, and the governance structure in section 10.2 reads "to be determined". The guideline commits to annual review, so a buyer should expect a second version before 2028.
The expensive items stay outside the case price
Prostheses and implants, chemotherapy drugs, specialised devices, pre-admission emergency room services and follow-up care beyond 14 days after discharge are excluded from the reference price and billed separately. On our reading, that protects the biggest line items in cardiology, orthopaedic and oncology admissions, where a stent, a joint or a chemotherapy regimen continues to be billed as today. A hospital whose admissions are mostly medical, such as respiratory, infectious or general medicine, has more of its revenue inside the case price and more exposure to the negotiated base rate.
Length of stay moves from revenue to cost
Room and board sit inside the reference price. Under fee-for-service another day in bed is another billed day; under a DRG it is cost against a fixed payment, subject to adjustment only where the stay falls outside the norm for that group.
The guideline says the trim points and adjustment formulas for those outliers will be published before full implementation in 2028. Until they are, any model of 2028 admitted-care revenue is missing a variable, and a hospital with long stays in its highest-volume DRGs carries a margin risk its fee-for-service accounts cannot show.
What to do on monday
Ask the hospital for its monthly shadow-billing output: case mix index, error-DRG rate against the 3% cap, and DRG-versus-fee-for-service variance by payer. Confirm which approved vendor will run the 2027 external audit and read the last internal audit. Split admitted-care revenue into what sits inside the case price and what stays outside it, and value the inside portion on a base-rate range, not on fee-for-service history. That work sits with our business valuation practice.
Four questions before valuing a Saudi private hospital
- What case mix index, error-DRG rate and DRG-versus-fee-for-service variance has the hospital's shadow billing produced each month, and who inside the business reviews it?
- Which CHI-approved vendor will carry out the 2027 external coding audit, and what did the last internal audit find?
- What share of admitted-care revenue sits in implants, chemotherapy drugs and specialised devices billed outside the DRG, and what share falls inside the case price?
- Where is average length of stay above the norm for the hospital's highest-volume DRGs, and what does that cost once a day in bed is no longer billed separately?
This brief covers one instrument. The UAE healthcare regulatory tracker carries the full set — DoH, DHA, EDE and the other emirates — with what each one changes and when it takes effect.
Subscribe
The UAE healthcare regulatory briefing
What changed, what it reprices, and the instrument to read. Every second Tuesday. No pitches.
One email a fortnight. Unsubscribe from any of them.