Portugal's Health Regulator Tells Private Clinics to Scrap Charges Patients Were Never Quoted, From a 29 Euro Ear Cleaning to a 69.60 Euro Scan

A patient insured with Médis went to an ear, nose and throat appointment at the Joaquim Chaves Saúde clinic in Moscavide, on Lisbon's northern edge, on 10 March 2025. The consultation cost her 19 euros. During it, the doctor cleaned out her ear, and at the desk she was asked for another 29 euros for the "aspiration". Nobody had told her it was extra. "As I was not warned that the treatment was paid separately, I will not pay for the treatment," she wrote in her complaint.

The Entidade Reguladora da Saúde (ERS, the health regulator) has now ordered the clinic's operator, Joaquim Chaves, Clínicas Médicas, S.A., to cancel that 29 euro invoice and to report back within five days of being notified. The order was approved on 17 April 2026.

It is one of six deliberations the ERS published on its website on 9 September, all about the same failure: patients charged for tests or procedures they were not told would cost extra. The decisions were approved between April and June 2026. Público reported on them on Sunday; this account is taken from the ERS decisions themselves.

The six cases

• UOC, Unidade de Oftalmologia de Coimbra. At a routine eye appointment on 20 May 2025, two extra tests were billed separately: 20 euros for a binocular vision assessment and 23 euros for specular biomicroscopy. "At no point was I told of this change of procedure, nor of the additional cost of these tests," the patient wrote. The ERS ordered the clinic, on 2 April 2026, to cancel both charges and refund the 43 euros.
• Hospital Lusíadas Paços de Ferreira. A woman seen in a gynaecology consultation on 31 December 2024 had a transvaginal ultrasound during it and was then asked for another 69.60 euros. The ERS proposed an order to cancel the invoice. Lusíadas Norte, S.A. refunded the money by bank transfer on 27 March 2026, which it said it did "under protest", so the final decision of 17 April is an instruction only.
• Intercir, Centro Cirúrgico de Coimbra. A patient was told an ear, nose and throat consultation would cost 35 euros. After it, on 28 August 2025, he was presented with a bill for 66 euros, adding a hearing test at 18.50 euros and a microscope examination at 12.50 euros. He paid only the 35. The ERS ordered the invoice partly cancelled on 30 April; the clinic then showed it had already issued a credit note, so the ERS withdrew the order and kept the instruction, while blaming the confusion on the clinic's own "negligence" in the inquiry.
• HPA, Hospital Particular de Almada. A beneficiary of the Instituto de Ação Social das Forças Armadas (IASFA, the armed forces' social services institute) paid 7 euros for an ear, nose and throat consultation on 21 February 2025, and was later phoned and asked for 15 euros more for an examination under the microscope. The hospital refunded the 15 euros on 23 April 2026. Instruction only, approved on 14 May.
• Trofa Saúde Hospital da Trofa, S.A. (the Trofa Saúde Ovar unit). One file covers three complaints. A patient quoted 1,030 euros for a dental implant was told when she paid that it covered only the first stage, and that the rest would be another 1,250 euros. Another was charged 115 euros after an allergy consultation, 85 euros of it for skin tests and 30 euros for the room; the hospital later issued a credit note for the full amount. In the third, a mother was told by phone in January 2026 that her daughter's wart treatment would cost less than 10 and less than 50 euros under ADSE (the civil servants' health scheme), then found at the desk that the hospital's ADSE agreement had ended on 1 January and was charged private prices of 433 euros; the hospital later credited back the difference. Instruction only, approved on 2 April.

What the regulator told them

Every provider received the same instruction. Patients must be told the truth about cost in advance, clearly and in a form they can understand, including the prices and estimates for their care and the rules of any agreement with an insurer or health scheme. The forecast has to cover "clinical acts, tests, consumables, medicines and room fees" that the patient can expect to pay. Providers must not give incomplete estimates; where they cannot price everything, they must say so and warn the patient that it affects the total. For long treatments, patients must be told the cost of the whole course, not just part of it.

The decisions rest on the Lei de Bases da Saúde (Health Framework Law), the patients' rights law, Lei n.º 15/2014 (Law 15/2014), and the consumer protection law, Lei n.º 24/96 (Law 24/96). Failing to comply with an ERS order or instruction is a misdemeanour punishable by a fine of 1,000 to 44,891.81 euros. In five of the files, the ERS also found that charging patients without telling them first breached their freedom to choose a provider, itself a misdemeanour, and that proceedings should be opened. The outcome of those proceedings has not been published.

The regulator had already warned the sector. In a supervision alert of 2 August 2025, addressed to private, social and cooperative providers, the ERS said it was still receiving "a significant volume of complaints" from patients who had been given no information, or wrong or incomplete information, about the financial side of their care.

If it happens to you

You can complain in the provider's complaints book (the red Livro de Reclamações in private clinics), in the electronic complaints book, or directly to the ERS online. Complaining is free and there is no deadline. The ERS says that after you complain, it is up to you whether to pay the amount you dispute, although the provider can go to court to collect it. Our guide Disputing a Hospital or Clinic Bill in Portugal sets out what a clinic must tell you before treatment, what your invoice must show, and each step of a complaint. The ERS call centre is on 309 309 309.

Last week we reported how the same regulator ruled on a patient who waited 14 months for his own medical file after being sent to his insurer for it. On the insurance side, see our guide to choosing private health insurance in Portugal.