External Company Doctor: Cost per Hour, Flat-Rate Packages and Billing Models Compared

Under § 3(1) of the Occupational Safety and Health Act (ASiG), employers are obliged to appoint a company doctor. For companies without their own occupational medical service, the cost question arises immediately: what does an external company doctor charge per hour, and which billing model suits the company's size? The hourly rate varies between €90 and €200 net depending on occupational medicine qualification, travel region and contract type — a range that quickly leads to unnecessary expenditure without a systematic comparison. Not included: occupational health surveillance examinations under the Occupational Health Care Ordinance (ArbMedVV) and travel costs, which can significantly increase the annual budget.

This article explains the common pricing models (hourly billing, annual flat rate, demand-based flat rate), sets out the minimum deployment times under DGUV Regulation 2 in hours per employee per year, and shows when an external appointment via a compliance platform such as CIVAC is more cost-effective than a direct individual contract with an occupational physician. The article concludes with concrete figures and a practical three-step approach to appointment.

The obligation to appoint a company doctor arises from § 3(1) ASiG in conjunction with DGUV Regulation 2 (Company Doctors and Occupational Safety Professionals). Both provisions apply to all businesses with at least one employee, regardless of industry or company size. The critical point is that there is no de minimis threshold: even a single employee subject to social insurance contributions triggers the appointment obligation.

DGUV Regulation 2 distinguishes two care models: standard care for businesses with up to 50 employees (alternatively the entrepreneur model or company doctor) and standard care for medium-sized and large businesses from 50 employees upwards, which prescribes a fixed deployment time framework. This framework directly determines how many hours are to be billed and therefore the total annual cost. Both care models must be documented in writing and must be capable of being evidenced to the employers' liability insurance association (Berufsgenossenschaft) or the trade supervisory authority upon request.

Failure to appoint a company doctor risks fines under § 25 ASiG in conjunction with § 9 OWiG, as well as personal liability of management in the event of harm. The appointment must be documented in writing and must evidence the agreed deployment times. Seamless documentation of the company doctor appointment is mandatory in the context of an internal audit or an employers' liability insurance association inspection.

For external company doctors, § 19 ASiG additionally applies: the employer remains responsible for proper performance, even when relying on an external service provider. The contract must therefore govern qualifications, deployment times, and documentation obligations. A service contract that specifies only the hourly rate but contains no description of services does not meet the requirements of the ASiG.

The market rate for external company doctors in Germany is between €90 and €200 per hour (net). The range is explained by several factors:

• Qualification: Specialist physicians in occupational medicine (specialist title under the specialist training regulations) are at the upper end of the scale; physicians with an additional occupational medicine designation (§ 4 ASiG) are typically in the mid-range.
• Region: In urban agglomerations such as Munich, Frankfurt or Hamburg, hourly rates of €150–200 are common; in regions with weaker economic structures, the average is €90–130.
• Travel costs: Many providers charge separate travel costs above a certain distance (€0.40–0.60 per km or travel time as billable working time).
• Scope of services: Inclusion of fitness-for-work examinations (e.g., VDU workstation G37) or occupational health surveillance examinations under the ArbMedVV increases the effective hourly rate.
• Framework contract vs. individual call-off: Framework contracts with fixed annual contingents are typically 10–15% below the list price for individual deployments.

A further influencing factor is the provider's business structure: sole practitioners often have lower overheads and offer lower hourly rates; larger occupational medical services are more expensive but offer deputisation arrangements, broader specialist expertise, and standardised documentation. For companies with high inspection risk, this structural added value can justify the higher hourly rate.

When requesting proposals, always ask for the net hourly rate, the scope of services included, and the precise arrangement for travel times, in order to achieve comparability. A request that asks only for the hourly rate does not yield a reliable price comparison.

DGUV Regulation 2 specifies, in Annex 2, business-specific deployment times for company doctors. These times are binding minimum values and are calculated by business size and hazard group. They form the arithmetic core of every cost calculation for occupational medical care.

For businesses with more than 50 employees, standard care applies with the following benchmarks (basic care — company doctor):

• Hazard group I (low hazard, e.g. purely office-based businesses): 0.5 hrs per employee per year
• Hazard group II (medium hazard, e.g. retail, service industry with physical demands): 1.0 hr per employee per year
• Hazard group III (high hazard, e.g. manufacturing, chemicals, construction): 1.5–2.5 hrs per employee per year

For a mid-sized company with 200 employees in hazard group II, this results in an annual minimum contingent of 200 hours for basic care alone. Business-specific care (e.g. following accidents, reintegration, specific hazard situations) is additional and cannot be quantified as a flat rate.

In practice, basic care times are split between the company doctor and the health and safety officer. The percentage split is to be determined within the business; a common benchmark is 40% company doctor and 60% safety officer in industrial businesses. In office-based businesses, the company doctor proportion may be lower, as safety inspections are less time-intensive.

Note: For businesses with fewer than 10 employees, the employers' liability insurance associations offer the entrepreneur model, which under certain conditions dispenses with a continuous company doctor contract. However, if hazard potential is present, the appointment obligation remains unaffected. The entrepreneur model requires specific training and registration with the relevant employers' liability insurance association.

External company doctors bill according to three basic models:

1. Hourly billing: The company doctor invoices for actual hours worked. Advantage: no advance payment, transparency on individual services. Disadvantage: no cost ceiling, difficult annual budget planning.
2. Annual flat rate (contingent contract): Agreed hours contingent on an annual basis, payable in monthly instalments. Most common contract type for businesses with 20 or more employees. Offers planning certainty and typically reduces the effective hourly rate by 10–15%.
3. Demand-based flat rate: Base package (e.g. annual inspection visit + telephone helpline) combined with call-off as needed. Suitable for businesses with fewer than 20 employees and low hazard exposure.

Some providers also offer per-capita models: a fixed amount per employee per year (typically €30–80/employee/year depending on hazard group). This approach is suitable for businesses with a stable workforce and enables direct comparison between offers from different service providers.

Recommendation: For businesses with highly variable headcounts (seasonal businesses, project-based businesses), hourly billing with a framework contract is often the more economical choice. For businesses with a stable workforce of 50 or more employees, the annual flat rate provides more reliable cost planning.

Concrete cost examples help to contextualise the figures:

These figures are based on an average net hourly rate of €120 and exclude travel costs, special examinations under the ArbMedVV, and business-specific additional care. In practice, total budgets for mid-sized businesses range between €5,000 and €50,000 per year.

Note: Occupational health surveillance examinations under the ArbMedVV annex (e.g. G25 for driving, controlling and monitoring activities; G37 for VDU work) are frequently invoiced separately and can significantly increase the total annual amount. For a company with 100 employees, of whom 80 perform VDU work and are entitled to G37 surveillance, additional costs of approximately €4,000–8,000 per year arise, depending on the agreed examination frequency (every two to three years).

A structured comparison of proposals should therefore always explicitly list all service components and itemise surveillance examinations with specific per-case flat rates. A proposal without this information is not suitable for reliable budget planning.

Many cost comparisons fail due to incomplete proposal components. The following items are frequently underestimated or overlooked:

• Travel costs and travel time: Some providers bill travel time as remunerable working time at the full hourly rate; others charge a flat rate beyond 30 km. Difference in the annual budget: up to 20%.
• Fitness-for-work and surveillance examinations: Under the ArbMedVV (Occupational Health Care Ordinance), certain examinations are mandatory (mandatory surveillance) or must be made available at the employee's request (offer-based surveillance). These services are frequently billed per hour or as a per-case flat rate.
• Documentation effort: The preparation of risk assessments, expert opinions, and reports is not always included in the hours contingent and is billed separately.
• Emergency on-call availability: Some companies require telephone availability of the company doctor outside inspection hours; this is charged as an on-call flat rate.
• Index clauses: Contracts with terms of more than two years frequently contain price adjustment clauses linked to the consumer price index or collective bargaining agreements.
• Annual report preparation: The company doctor is required under § 9 ASiG to submit an annual written report. This effort is not included in some proposals' contingents and is billed separately.

A practical tip: ask prospective providers for a sample invoice for a fictitious business of your size and hazard group. This quickly reveals which items a provider routinely omits. Review proposals using a checklist of at least seven service parameters before signing. Frequently asked questions about company doctor appointments can be found on the CIVAC FAQ page.

Alongside the classic direct contract with an individual occupational physician or an occupational medical service, platform-based models now exist in which the appointment, documentation and reporting line are coordinated via a compliance platform. This approach is particularly relevant for mid-sized companies that need to fill several mandatory officer roles externally at the same time.

The structural difference:

For companies that need to fill additional mandatory officer roles (health and safety officer, data protection officer, fire safety officer) externally in addition to the company doctor, the platform model significantly reduces the administrative burden, since contracts, letters of appointment and reports are managed centrally. Instead of three separate service provider relationships, each with its own email-based reporting, the compliance reporting line runs through a single workspace. This saves coordination time and reduces the risk of deadlines or reporting obligations being lost in interface communications.

Companies with 20 or more employees that do not operate their own occupational medical service will generally find an external company doctor more cost-effective than internal employment. An employed specialist physician in occupational medicine, including the employer's social insurance contributions, continuing professional development costs and ancillary costs, typically costs €90,000 to €150,000 per year. This investment only becomes cost-effective from a company size of approximately 700 to 1,000 employees with full-time care requirements.

Up to that threshold, the advantages of the external model predominate:

• Variable costs: payment only for services actually rendered or contractually fixed, without the fixed cost block of salary and social insurance contributions.
• No cover risk: holiday, illness or resignation of the company doctor lies with the service provider; they ensure continuity of care.
• Broad expertise: external services deploy specialist physicians depending on the issue (e.g. toxicologists for hazardous substance businesses, occupational psychologists for psychosocial risks).
• Immediate appointability: no recruitment process, no probationary period; a platform model such as CIVAC enables appointment within two business days.

The tax treatment is clear: costs for external occupational medical care are fully deductible as business expenses under § 4(4) EStG. Contracts should contain a clear description of services to enable the business expense character to be straightforwardly evidenced to the tax authorities. A mixture of basic care costs and surveillance examination costs should be shown separately in the accounts.

For businesses with multiple sites, it is worth considering whether a supra-regional service with branch offices reduces travel costs compared over the year. For combined care with a health and safety officer, some providers offer combined packages that bundle both obligations from a single source.

Those who have not yet fulfilled the appointment obligation under § 3 ASiG or wish to review their existing contract should proceed in three steps: first, determine the business's hazard group under DGUV V2 Annex 2; second, compare at least three proposals using an identical list of services; and third, document the appointment in writing and file the letter of appointment with the agreed deployment times in an audit-proof manner. This three-step process sounds demanding, but can in practice be completed within a few days with the right templates and a structured selection process.

CIVAC offers an external company doctor as Officer-as-a-Service: a certified occupational physician is formally appointed within two business days, the letter of appointment is filed digitally, and the ongoing reporting line is maintained in the CIVAC workspace. Letter of appointment — signed, filed, demonstrable. CIVAC's SLA of two business days for appointment, letter and deployment planning replaces the classically six-week appointment process.

Those wishing to staff the company doctor function internally can use the CIVAC workspace as a tool licence for their own appointee: 490 ready-to-use audit templates, a structured documentation module, and AI-assisted questions with source references are available from day one. The workspace is not a generic GRC tool, but is specifically designed for the 25 German mandatory officer roles. Licence the workspace for your internal officers, or appoint our officers.

Turn reading into a mandate: write to info@civac.de or use the contact form at civac.de. The first conversation clarifies business size, hazard group and the appropriate billing model — without obligation, without a long wait.