Immunotherapy Reimbursement – SGK Conditions: Keytruda, Opdivo, Tecentriq, Imfinzi, Yervoy
In this article
SGK reimburses five immunotherapy medicines: pembrolizumab (Keytruda), nivolumab (Opdivo), ipilimumab (Yervoy), atezolizumab (Tecentriq), and durvalumab (Imfinzi). Reimbursement applies only when the cancer type, stage, treatment line, and biomarker conditions individually listed in the Healthcare Implementation Communiqué (SUT) are met. Although dostarlimab (Jemperli) and tremelimumab (Imjudo) are licensed in Türkiye, they are not yet reimbursed for any indication.
- Coverage: The immunotherapy section of SUT Article 4.2.14.C lists a total of 28 indications for five medicines: 15 for nivolumab and ipilimumab, 6 for pembrolizumab, 5 for atezolizumab, and 2 for durvalumab.
- General conditions: The medicine is supplied by the hospital and administered as inpatient treatment. A medical board report involving a medical oncology specialist, valid for no more than 3 months, and a medical oncology specialist's prescription are required.
- Immunotherapy after immunotherapy: If disease progresses during or after an immunotherapy, subsequent immunotherapy in later treatment lines is not reimbursed.
- Licensed but not reimbursed: Dostarlimab (Jemperli) and tremelimumab (Imjudo) are marketed in Türkiye but are not reimbursed for any indication. The status of avelumab (Bavencio) remains unclear.
Why is this important?
Immunotherapies prolong survival in many cancers, including lung cancer, melanoma, kidney, stomach, breast, and head and neck cancers, but they are expensive. A medicine's licensing in Türkiye does not mean SGK pays for every use. Reimbursement depends on conditions defined much more narrowly than the licensed indications.
These conditions are highly detailed: a PD-L1 threshold, a cycle limit, or the treatment line determines reimbursement. Appropriate testing and treatment sequencing therefore need to be planned before treatment begins. We also explained the importance of this planning in lung cancer in this article .
Does SGK cover immunotherapy medicines?
Yes, but only for indications defined in the SUT. SGK covers pembrolizumab, nivolumab, ipilimumab, atezolizumab, and durvalumab when specific conditions for cancer type, stage, treatment line, and biomarkers such as PD-L1 are met, in inpatient care, with a medical board report involving a medical oncology specialist. Uses not listed are not covered.
The current rules were established by the SUT amendment published in Official Gazette No. 32952 on July 10, 2025. On January 17, 2026, the age restriction was removed from the nivolumab and ipilimumab provision for kidney cancer. As of October 2026, no other change had been made to this section.
What are the general conditions for SGK reimbursement?
- Inpatient treatment: The medicine is not obtained from a pharmacy; it is supplied by the hospital and administered as inpatient treatment.
- Medical board report: It must involve a medical oncology specialist, specify the treatment protocol, and be valid for no more than 3 months. The report includes the center, date, and number of the pathology, cytology, or radiology report supporting the diagnosis, disease stage or risk group, and previous treatments.
- Prescription: Issued by medical oncology specialists.
- Continuing treatment: When the report is renewed, it must state that there is no disease progression. For Hodgkin lymphoma, it must state that at least a partial response has been achieved.
- Sequencing rule: If progression develops during or after nivolumab, pembrolizumab, or atezolizumab, subsequent immunotherapy in later lines is not reimbursed. Later immunotherapy is also not covered in patients who have received durvalumab.
Figure 1 · Checklist for SGK reimbursement of immunotherapy
Four questions to answer in sequence before starting treatment, and the exception most often overlooked.
Which immunotherapy is reimbursed for which cancer?
The following tables summarize SUT provisions. Abbreviations: NSCLC, non-small cell lung cancer; SCLC, small cell lung cancer. Terms are explained in the glossary at the end of the article.
When is Keytruda (pembrolizumab) reimbursed?
| Indication | Main conditions and limits |
|---|---|
| Metastatic non-squamous NSCLC, first line | PD-L1 <50%; no EGFR, ALK, or ROS mutation; ECOG 0-1; no active brain metastases. Start with 4 cycles of platinum and pemetrexed, then continue with pemetrexed. Pembrolizumab: maximum 35 cycles (every 3 weeks) or 17 cycles (every 6 weeks). |
| Metastatic squamous NSCLC, first line | PD-L1 <50%; ECOG 0-1; no active brain metastases. Start with 4 cycles of carboplatin and paclitaxel, then continue alone. Maximum 35 or 17 cycles. |
| Metastatic NSCLC, first line, monotherapy | PD-L1 50% or higher; ECOG 0-1; no active brain metastases. Maximum 35 or 17 cycles. |
| High-risk early or locally advanced triple-negative breast cancer | Tumor larger than 2 cm or positive axillary lymph nodes; ECOG 0-1; with anthracycline- and carboplatin-containing chemotherapy. Before surgery: 8 cycles (200 mg every 3 weeks) or 4 cycles (400 mg every 6 weeks). After surgery: only if no pathological complete response, 9 or 5 cycles (Figure 2). |
| Metastatic or unresectable recurrent triple-negative breast cancer, first line | PD-L1 CPS >10; with chemotherapy. Patients who received adjuvant chemotherapy in early-stage disease require a disease-free interval of at least 6 months. |
| Non-nasopharyngeal squamous cell carcinoma of the head and neck, metastatic or unresectable recurrent | PD-L1 CPS >1; ECOG 0-1; alone or with platinum and 5-fluorouracil. Maximum 24 months. |
US-approved uses of pembrolizumab, such as melanoma, bladder, cervical, endometrial, and MSI-H cancers, are not included in the SUT. We described all approved uses in our Keytruda article .
Figure 2 · Pembrolizumab reimbursement pathway in early-stage triple-negative breast cancer
Cycle limits differ before and after surgery; postoperative reimbursement depends on pathological response.
When is Opdivo (nivolumab) reimbursed?
| Indication | Main conditions and limits |
|---|---|
| Melanoma, unresectable or metastatic, first line | ECOG 0-1; no previous immunotherapy; until progression. |
| Melanoma, after surgery (adjuvant) | Complete resection, stage III/IV with lymph node involvement; ECOG 0-1. Maximum 12 months. |
| Clear cell kidney cancer, advanced stage | After at least one course of VEGF-targeted treatment; Karnofsky ≥70; a limit of no more than 3 systemic treatment lines. |
| Classical Hodgkin lymphoma, relapsed or refractory | After autologous stem cell transplantation followed by brentuximab, or after at least 3 treatment lines including transplantation; monotherapy. At least a partial response is required for report renewal. |
| Squamous cell carcinoma of the head and neck (mouth, pharynx, larynx) | Recurrence within the first 6 months after first-line platinum chemotherapy; monotherapy until progression. |
| Metastatic colorectal cancer, MSI-H or dMMR | Progression after fluoropyrimidine, oxaliplatin, and irinotecan. |
| Esophageal squamous cell carcinoma, metastatic or unsuitable for curative treatment | Progression after fluoropyrimidine and platinum chemotherapy. |
| Gastric, gastroesophageal junction, or esophageal adenocarcinoma, first line | HER2-negative; PD-L1 CPS >5; ECOG 0-1; with fluoropyrimidine and platinum chemotherapy. Maximum 24 months. |
| NSCLC, before surgery (neoadjuvant) | Resectable stage 3A; PD-L1 >1%; with platinum-doublet chemotherapy for no more than 3 cycles. |
| Locally advanced or metastatic NSCLC, second line | Progression after one line of chemotherapy; ECOG 0-1; no symptomatic brain metastases; monotherapy until progression. |
We discussed the role of immunotherapy in gastric and esophageal cancers in this article, and all nivolumab uses in our Opdivo article .
When are Opdivo and Yervoy (nivolumab and ipilimumab) reimbursed together?
| Indication | Main conditions and limits |
|---|---|
| Melanoma, unresectable or metastatic, first line | ECOG 0-1; maximum 4 doses of ipilimumab. |
| Melanoma, ipilimumab monotherapy | Unresectable or metastatic disease after at least one course of systemic treatment; 3 mg/kg, maximum 4 doses. |
| Advanced renal cell cancer, first line | IMDC intermediate or poor risk; Karnofsky ≥70; maximum 4 doses of ipilimumab. The age limit was removed in January 2026. |
| Pleural mesothelioma, unresectable, non-epithelioid, first line | Maximum 24 months. |
| Metastatic NSCLC, first line | PD-L1 <50%; ECOG 0-1; with 2 cycles of platinum chemotherapy. Maximum 24 months. |
We described administration of this combination in our treatment-regimen article, and the evidence in mesothelioma in this article .
When is Tecentriq (atezolizumab) reimbursed?
| Indication | Main conditions and limits |
|---|---|
| NSCLC, after surgery (adjuvant) | Stage II-IIIA (TNM 7); PD-L1 >50% in tumor cells; monotherapy after resection and platinum chemotherapy. Maximum 1 year. |
| Metastatic NSCLC, first line, monotherapy | PD-L1 50% or higher; ECOG 0-1; no active brain metastases; no immunosuppressive or corticosteroid treatment. Maximum 35 cycles (every 3 weeks). |
| Locally advanced or metastatic NSCLC, later line | Progression after 1-2 chemotherapy lines; ECOG 0-1; no symptomatic brain metastases. |
| Extensive-stage SCLC, first line | ECOG 0-1; with carboplatin and etoposide; until progression or unacceptable adverse effects. |
| Hepatocellular carcinoma (liver cancer), first line | With bevacizumab; Child-Pugh A; ECOG 0-1; unresectable and unsuitable for locoregional treatment, or metastatic. |
For non-squamous NSCLC, the report must state that no EGFR, ALK, or ROS mutation is present. You can find information on the contribution of immunotherapy in SCLC in this article, and all atezolizumab uses in our Tecentriq article .
When is Imfinzi (durvalumab) reimbursed?
| Indication | Main conditions and limits |
|---|---|
| Biliary tract cancer, unresectable or metastatic, first line | PD-L1 >1% (in tumor and/or immune cells). With gemcitabine and cisplatin every 3 weeks for no more than 8 cycles, then maintenance monotherapy (no more than 1500 mg every 4 weeks), until progression. |
| Stage III NSCLC, unresectable | No progression after platinum chemoradiotherapy; PD-L1 1% or higher; monotherapy. Maximum 12 months. |
The TOPAZ-1 trial demonstrating durvalumab's efficacy in biliary tract cancer did not require a PD-L1 threshold; the SUT nevertheless requires PD-L1 positivity. Durvalumab uses in SCLC and liver cancer (with tremelimumab) are not included in the SUT.
Which immunotherapies are not yet reimbursed by SGK for any indication?
Some immunotherapies are licensed and marketed in Türkiye but are not listed in the SUT for any indication. SGK does not cover these medicines.
| Medicine | Status in Türkiye | SGK reimbursement |
|---|---|---|
| Dostarlimab (Jemperli, GSK) | Licensed; listed on medicine price lists since March 2026. Approved in the United States for MMR-deficient endometrial cancer. | None |
| Tremelimumab (Imjudo, AstraZeneca) | Licensed; listed on medicine price lists since July 2026. Used with durvalumab in liver cancer and metastatic NSCLC. | None; these durvalumab uses are also absent from the SUT. |
| Avelumab (Bavencio, Merck) | Licensed; listed on medicine price lists since 2020. Approved in the United States for Merkel cell carcinoma, maintenance after chemotherapy in bladder cancer, and with axitinib in kidney cancer. | Unclear (see below) |
Avelumab is not named in the SUT section defining immunotherapy conditions. Some medicine databases list Bavencio in SGK's Reimbursable Medicines List (EK-4/A). However, in a Court of Cassation decision dated December 2025, SGK had declined reimbursement because the medicine was not on that list. The current position therefore needs confirmation with the hospital and SGK before treatment begins.
- Not on the price list: Cemiplimab (Libtayo), tislelizumab (Tevimbra), the nivolumab and relatlimab combination (Opdualag), toripalimab, and retifanlimab do not appear on medicine price lists in Türkiye.
- Obtaining medicines from abroad: SGK covers imported medicines only under specific conditions when the medicine is not licensed in Türkiye or is licensed but unavailable on the market.
- In practice: SGK does not reimburse medicines absent from the SUT or uses that fail to meet the listed conditions. In such cases, funding must be considered separately with the patient, hospital, and any private insurer.
What is the difference between licensing and reimbursement?
The FDA and European Medicines Agency (EMA) have approved these medicines for far more indications than the SUT covers. A medicine's licensing in Türkiye means that the Turkish Medicines and Medical Devices Agency (TİTCK) has found it suitable for marketing for specified indications. SGK reimbursement is a separate decision and requires inclusion in the SUT. Even a licensed indication is therefore not reimbursed if it is absent from the SUT.
- Perform the tests at the outset: PD-L1 (TPS, TC, or CPS), MSI or MMR, HER2, and lung cancer EGFR, ALK, and ROS results must be recorded in the report; thresholds differ by provision.
- Specify the treatment line correctly: Many provisions apply only in the first line or after specified treatments.
- Monitor the duration: Reports are valid for no more than 3 months; reimbursement ends when cycle or month limits (such as 12 or 24 months or 35 cycles) are reached.
- Follow the legislation: SUT amendments are published in the Official Gazette and are updated frequently.
We described how immunotherapy side effects are managed in this article .
Frequently asked questions
- Does SGK cover Keytruda?
- Yes, but only for the 6 indications listed in the SUT: three lung cancer provisions based on PD-L1 level, early-stage and metastatic triple-negative breast cancer, and non-nasopharyngeal head and neck cancer. Each provision has its own PD-L1, cycle, and duration requirements.
- For how many months is an immunotherapy report valid?
- A medical board report is issued for no more than 3 months and must involve a medical oncology specialist. Renewal must state that there is no disease progression; at least a partial response is required in Hodgkin lymphoma.
- Is another immunotherapy reimbursed after a previous immunotherapy?
- No. If disease has progressed during or after nivolumab, pembrolizumab, or atezolizumab, SGK does not cover later-line immunotherapy. The same rule applies to patients who have received durvalumab.
- Which licensed immunotherapies are not reimbursed by SGK in Türkiye?
- Dostarlimab (Jemperli) and tremelimumab (Imjudo) are licensed and marketed in Türkiye but are not reimbursed for any indication. Because avelumab's (Bavencio) status remains unclear, it should be confirmed with SGK before treatment.
Glossary
- PD-L1 (TPS / TC)
- The percentage of tumor cells expressing PD-L1 on their surface; in lung cancer, the threshold is usually 1% or 50%.
- CPS (combined positive score)
- A score calculated using the total number of PD-L1-expressing tumor and immune cells; used in gastric, breast, and head and neck cancers.
- MSI-H / dMMR
- A defect in the DNA repair system; increases the response to immunotherapy.
- ECOG and Karnofsky
- Scales measuring daily functioning. ECOG 0-1 indicates that the patient can perform self-care; Karnofsky ≥70 indicates the ability to care for oneself.
- Neoadjuvant / adjuvant
- Treatment given before / after surgery.
DROZDOGAN Academy Commentary
Immunotherapy reimbursement has become an integral part of treatment decisions.
⚡ Why it matters
The right test, treatment line, and report determine whether a patient can access an effective treatment.
✅ Positive aspect
The 2025 regulation covered many evidence-based uses in lung, breast, gastric, biliary tract, and liver cancers; the age limit in kidney cancer was removed in 2026.
⚠️ Limitations
Some conditions are narrower than trial eligibility: examples include the PD-L1 requirement in biliary tract cancer and the lack of reimbursement for immunotherapy after previous immunotherapy. Areas such as bladder, cervical, and endometrial cancers remain outside coverage.
🩺 What to do in practice
- At diagnosis, request all biomarker tests without omissions.
- Which line will include immunotherapy should be planned at the outset.
- Monitor the report's duration and cycle limits .
❓ Open questions
When medicines such as dostarlimab, tremelimumab, and avelumab, and new indications, will be covered remains uncertain.
Our brief conclusion: SGK covers five immunotherapies for 28 indications; reimbursement depends on meeting every condition in the relevant provision.
- This article was prepared in October 2026. Conditions were taken from the SUT amendment published in Official Gazette No. 32952 on July 10, 2025, and the amendment dated January 17, 2026, No. 33140. Other SUT amendments published through October 2026 do not change the immunotherapy conditions.
- Not verified: The text was read from copies in legislative databases rather than the original Official Gazette file; some thresholds are written as ">" in these copies, while some sources use "≥." The full wording of certain provisions—for example, which lung cancer provisions the EGFR, ALK, and ROS statements belong to—could not be verified. Avelumab's current position in SGK's Reimbursable Medicines List (EK-4/A) remains unclear. Licensing information came from databases based on medicine price lists rather than TİTCK records; a licensed product never marketed may not appear on these lists.
- The tables summarize the SUT text; diagrams were derived from verified statements in the article. This article is neither a legal opinion nor personal medical advice; consult the Official Gazette and SGK announcements for the current text.
References
- Sosyal Güvenlik Kurumu Sağlık Uygulama Tebliğinde Değişiklik Yapılmasına Dair Tebliğ. Resmî Gazete, 10.07.2025, sayı 32952. lexpera.com.tr
- Full text of the same communiqué. saglikaktuel.com
- SGK duyurusu: 10.07.2025 tarihli ve 32952 sayılı Resmî Gazete'de yayımlanan SUT değişikliği. sgk.gov.tr
- SUT Değişikliği. Resmî Gazete, 17.01.2026, sayı 33140 (böbrek kanserinde yaş sınırının kaldırılması). saglikaktuel.com
- SUT Değişikliği. Resmî Gazete, 29.08.2026, sayı 33355. saglikaktuel.com
- Türk Kanser Derneği. Temmuz 2025 SGK geri ödeme listesine alınan ilaçlar. turkkanserdernegi.org
- FDA. BAVENCIO (avelumab) prescribing information. accessdata.fda.gov
- FDA approves avelumab for urothelial carcinoma maintenance treatment. fda.gov
- Jemperli 500 mg/10 ml, medicine price record (GSK). ilacrehberi.com
- Imjudo 300 mg/15 ml, medicine price record (AstraZeneca). ilacrehberi.com
- Bavencio 200 mg/10 ml, medicine price record (Merck). ilacrehberi.com
- Bavencio, SGK reimbursement information. ilacpedia.com.tr
- Yargıtay 10. HD, 2025/883 E., 2025/16497 K., 01.12.2025 (summary). alomaliye.com
- SGK. Yurt dışından ilaç temini. sgk.gov.tr
- FDA. IMJUDO (tremelimumab) prescribing information. accessdata.fda.gov
- FDA. Jemperli (dostarlimab), approval in dMMR endometrial cancer. fda.gov
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