E-patient file: Compulsory filling for doctors, alliance reminds of objection

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From 1 October 2025, electronic patient records (EPRs) will be mandatory for doctors, psychotherapists, and pharmacies. They will then have to fill in the ePAs of all those with statutory health insurance. Practitioners will face sanctions from January 2026. Most of the 70 million people with statutory health insurance have already had an EPR since the beginning of the year. Anyone who does not want one must actively object.

When the health card is read in, doctors are granted access rights for 90 days as standard. Even without active use by the insured person, doctors upload findings, diagnoses, and prescriptions to the ePA. Anyone wishing to intervene can use the app to specify which doctors are authorized to see which data. There are currently 3.5 million health IDs, which may be an indication of the use of the electronic patient record. Anyone who wants to use the ePA needs a health ID, which insured people can create using their ID card and PIN or their health card and PIN.

The health insurance companies expect that the mandatory filling of the ePA will speed up its use. “The obligation to fill in and use the ePA from 1 October should significantly increase the proportion of insured persons who come into contact with the topic,” AOK boss Carola Reimann told dpa.

Hospitals are expected to implement the system across the board in the course of next year. Some doctors in private practice have also recently had to wait for software modules. According to Gematik, over 90 percent of practices should be technically ready by 1 October. However, there could still be difficulties with the provision of individual components. There could also be difficulties with the practice management systems, as not all systems are yet fully developed or sufficiently tested. Doctors who are unable to complete the ePA by then risk drastic penalties—up to the complete exclusion of billing. Almost two years ago, the Federal Ministry of Health recommended changing the practice management system in case of doubt, with potentially high costs for practices.

Switching from RSA to ECC

It remains to be seen how many practices are actually technically capable of filling the ePA. The changeover from RSA to ECC (Elliptic Curve Cryptography) encryption at the turn of the year is also likely to be exciting. In the past, the National Association of Statutory Health Insurance Physicians had called for an extension of the use of 2048-bit RSA keys in the healthcare sector to enable a smooth and secure transition to ECC.

ePA for privately insured individuals

For the approximately 8.7 million private patients, things are less automatic. Only five of the 36 private health insurance companies with full insurance cover offer the ePA to date. In addition, there are currently no plans to transfer the pseudonymized data of privately insured patients to the Health Research Data Centre.

Alliance calls for objection

The alliance “Opposition to the PPR” is using the obligation to fill in the PPR to once again warn of massive problems with the PPR. Only a few people with statutory health insurance have used the electronic health record so far, “while a larger proportion of 11 percent have objected to the installation of their electronic health record,” says lawyer Jan Kuhlmann, spokesperson for the alliance. At the same time, the project has been criticized similarly to the e-prescription, which has recently impaired the supply of medicines due to frequent failures.

“The promised practical tests and the elimination of all security gaps have failed to materialize,” criticizes Hamburg doctor Silke Lüder. Instead of improvements, we are experiencing unstable technology, high expenditures, and additional costs. Nevertheless, practices would have to expect sanctions if they did not fill out the ePA. Munich-based psychotherapist Andreas Meißner also believes that medical confidentiality is at risk. “The switch to an opt-out system and lowered security requirements open the door to far-reaching access to patient data.” Instead of medical care quality, the use of large data sets for commercial purposes takes center stage.

Billing data visible to all

Recently, the National Association of Statutory Health Insurance Physicians (KBV) also pointed out that health insurance companies automatically enter their billing data into the ePA for all to see—unless insured people object. Even if doctors do not enter information, it will be visible through the health insurance companies' invoices. However, according to the KBV, the Federal Ministry of Health wants to address the issue.

(mack)