Electronic patient file: health insurers provide insufficient information

Health insurance companies are not providing enough information about the new version of the electronic patient file (ePA). This is the result of an analysis by the German Federation of Consumer Organizations (vzbv), which is available to Apotheken Umschau. From the beginning of 2025, all people with statutory health insurance are to receive an electronic patient file – unless they object.

Since November at the latest, all health insurance companies have been sending out information letters on ePA 3.0 and the options to object, and are obliged to do so. The information must provide low-threshold information about the electronic patient file. According to the study, 14 statutory health insurance funds whose letters were examined hardly did this. Prof. Jürgen Windeler, former head of the Institute for Quality and Efficiency in Medicine, also comes to this conclusion.

"The long, detailed list is apparently intended to contain the information that authorizes insured persons to decide on an objection". However, the "contents of the list as well as the way in which information on the ePA is presented and the way in which the legal obligation to provide information is dealt with are likely to prevent a desire for an objection from arising in the first place or to nip it in the bud", comments Windeler in Observer Gesundheit, who also analyzed four letters himself. This gives the impression that objections are unwelcome.

The main criticism is that the information letters from the health insurers examined are not detailed enough and do not provide information about possible risks. AOK Nordwest, for example, describes the data in the electronic patient file as "absolutely secure", although there are considerable concerns about data protection. In addition, some letters advertise functions that are not yet available, such as the electronic vaccination record. In the past, there has been repeated criticism from various quarters that this could raise false expectations among policyholders. In this context, the low objection rate reported by the major health insurance companies is all the less surprising.

Offliners are at a disadvantage

The way in which the health insurance companies provide information about the options for objecting to the ePA is also viewed critically. According to Windeler, the information on the electronic patient file is "difficult to find". There is also no indication that the data will end up in the European Health Data Space or possibly in a transatlantic data space, as the Ministry of Health has already announced in the past, although this is not provided for by law.

In addition, many health insurance companies advertise the option of lodging an objection online. It should also be possible to submit an objection at a low threshold, for example by post. Matthias Mieves, eHealth spokesperson for the SPD in the Bundestag, can only partially understand the criticism of the consumer advocates, as he told Apothekenumschau. He is pushing for improvements to the opt-out options, but does not believe that people without digital devices are completely excluded.

Unacceptable as a basis for opting out

Likewise, many health insurance companies even recommend thinking carefully about "whether you delete data from your ePA" or exclude service providers. "None of this would be objectionable if it were a matter of advertising a product. However, as a basis for an opt-out procedure, this is completely unacceptable," Windeler sums up.

(mack)