# Brazilian medical payment regulation and sanctions

> Live situation record from CLSTR: https://clstr.news/situations/brazilian-medical-payment-regulation-and-sanctions
> Updated: 2026-10-09T22:20:54.000Z. Sources: 8. Developments: 2.

In the Brazilian judicial system, medical experts are compensated through fees per report rather than fixed salaries. Under the Civil Procedure Code, judges appoint specialists for specific cases, with remuneration determined by task complexity and the responsible party. In cases involving free legal aid, fees are governed by public budgets or National Council of Justice resolutions.

To address payment issues, Bill 3022/26 is under analysis in the Brazilian Chamber of Deputies. The proposed legislation would authorize Regional Medical Councils (CRMs) to impose administrative sanctions on hospitals, health insurance operators, and other entities that delay or fail to pay doctors' salaries and fees. 

Under the bill, infractions include missed payments or 'reiterated delays' occurring three or more times in a 12-month period. Potential penalties range from written warnings and fines—varying from R$ 902 to R$ 721,600—to the suspension or permanent cancellation of registration for severe or repeated offenses. The bill specifies that entities cannot justify non-payment by citing delayed reimbursements from the government or insurers.

## Claims

- Deputies Eduardo da Fonte and Lula da Fonte are the authors of Bill 3022/26. (corroborated by 5 sources)
- The proposed legislation applies to hospitals, health insurance operators, philanthropic entities, cooperatives, and social organizations. (corroborated by 5 sources)
- Infractions include failure to pay after the due date and 'reiterated delay', defined as three or more delays within a 12-month period. (corroborated by 5 sources)
- Possible punishments include written warnings, fines ranging from 1 to 100 times the annual fee, registration suspension for up to one year, and permanent registration cancellation. (corroborated by 5 sources)
- Fines vary by company size, ranging from R$ 902 for small clinics to R$ 721,600 for large hospitals or health operators. (corroborated by 5 sources)
- Companies cannot use the lack of reimbursement from the government or health insurance providers as a justification for non-payment to doctors. (corroborated by 5 sources)
- The authors warn that current CFM regulations lack specific legal backing, which could lead to legal disputes regarding the most severe sanctions. (corroborated by 5 sources)
- Bill 3022/26 authorizes Regional Medical Councils (CRMs) to apply administrative sanctions to companies that delay or fail to pay doctors. (corroborated by 4 sources)

## Timeline

### 2026-10-09: Brazil Bill 3022/26 proposes sanctions for delayed medical payments

Brazil's Bill 3022/26 proposes allowing Regional Medical Councils to fine or suspend companies that delay or fail to pay doctors' salaries and fees.

7 sources. https://clstr.news/cluster/brazil-bill-302226-proposes-sanctions-for-delayed-medical-payments

### 2026-10-01: Medical experts in Brazil receive fees per report rather than fixed salaries

Medical experts in Brazil are paid per judicial report rather than via fixed salary. While judges typically appoint experts, parties may mutually agree on a specialist through consensual expertise.

2 sources. https://clstr.news/cluster/medical-experts-in-brazil-receive-fees-per-report-rather-than-fixed-salaries

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Cite as: Brazilian medical payment regulation and sanctions. CLSTR, https://clstr.news/situations/brazilian-medical-payment-regulation-and-sanctions