Digital Health: Expectations for the planned digital law

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In the run-up to a new, comprehensive digital law for the German healthcare system – two were originally announced – different expectations are clashing. While the National Association of Statutory Health Insurance Physicians (KBV) demands a stable and practical technical basis, the medical technology association BVMed is pushing for new data functions in the electronic patient record (ePA).

Practice Future Act Demanded

The associations' demands show how far apart the perspectives are. For the KBV, technology must finally follow medical needs. KBV board member Dr. Sibylle Steiner explained that the digital strategy must be more medically oriented: "This means that the technology should run silently and smoothly in the background. That must be the goal in 2026."

She referred to the "real setback" caused by the change in the encryption method in 2025, as the medical profession once again had to deal with "basic technical services," which cost a lot of energy. Due to a security vulnerability at a chip manufacturer, even doctors who already have a new ECC-capable card must now exchange it again. Although practices are pioneers in digitalization and the ePA is already a "lived reality," it must "not be overlooked" that basic functions such as uploading and downloading data are still "time-consuming and cumbersome." "Therefore, it is more than necessary that full-text search also comes as soon as possible," Steiner continued. In addition, communication via the KIM email service must be improved and the switching of practice management systems (PVS) facilitated by "secure, free data migration."

Large Market of Providers

The IT service provider Bitmarck, which is responsible for the ePA of numerous health insurance companies, among others, defends the stability of its own platform, stating that it has already improved. "In some areas, the number of providers is simply too large, especially for PVS systems. However, too much individuality makes the TI prone to malfunctions. Therefore, we urgently need to move towards standards that are also bindingly adhered to in development and operation," demands Managing Director Andreas Strausfeld binding standards.

In parallel, Strausfeld announces plans for the AI initiative "NexKomm" (Next Generation of Communication) in an interview with eHealth-com: "This brings together different communication streams – telephone, app, also TI messenger – on a common platform. Both health insurance companies and insured persons will benefit from this." In response to the demographic change in the workforce of health insurance companies, the platform is intended to bundle communication channels and generate added value from the data through the use of AI technologies to automate and accelerate processes. This concept was once called Unified Communications.

"Device Compartment" for Patient Record

The priorities of the BVMed are completely different. It wants to expand the ePA into a data repository for medical technology and calls for a structured "device compartment" for information from pacemakers or insulin pumps to improve care and research. Connectivity already exists for digital health applications. "If a medical device is used permanently or implanted, this compartment should be automatically created and contain central information such as manufacturer, device type, implantation date, serial number, or implant passport. This way, health-relevant information can be quickly and securely accessed in the care process when needed," says BVMed digital expert Natalie Gladkov of BVMed. This would make all information centrally available. "Currently, this information is not structured in the ePA. As a result, relevant information is lost for various care levels and is also not available for research and development," complains Gladkov.

A survey by the Central Institute for the Statutory Health Insurance Physicians (Zi) among more than 3,100 practice owners shows, among other things, how mixed the problems with software in medical practices are a survey by the Central Institute for the Statutory Health Insurance Physicians (Zi) among more than 3,100 practice owners. According to the survey, the majority are dissatisfied with their software, and one in three practices is considering switching. The main reasons cited are lack of user-friendliness, excessively high and opaque license fees, and insufficient customer support. Reading the electronic health card is rated as error-prone by 82.1 percent of respondents, and the connector connection to the TI by 81.4 percent. Even the e-prescription still produces error messages daily in almost twelve percent of practices. The fear of problems with data migration is slowing down a switch, although over 72 percent of practices that have made the move report a smooth migration. Therefore, the KBV demands secure and free switching of PVS.

Quality Differences in Practice Software

These results are consistent with a recently published survey by Gematik (PDF) on the user-friendliness of practice management systems. It also identifies significant differences among software providers regarding error messages and support. The implementation of ePA modules in the various systems varies widely.

Despite these known shortcomings, those responsible are driving forward further development. As early as autumn 2025, Gematik announced new functional enhancements for the ePA, including push notifications, full-text search, the electronic medication plan, and laboratory findings. Gematik stated in September 2025 that the ePA was technically "state of the art" and already "AI-ready." At the same time, the debate about data access is intensifying: As early as the end of 2025, the health insurance companies demanded in a position paper that they be allowed to act as "digital navigators" and use up-to-date care data for their own AI-based prevention offers.

The medical profession immediately warned of an erosion of confidentiality, including in relation to the European Health Data Space (EHDS). The German Psychotherapist Network (DPNW) recently advocated for the ePA to be designated as an "observation-free space" in the implementation of the E-Evidence Regulation. "The commitment from the Federal Ministry of Justice is an important signal for the protection of patients' personal rights. Psychotherapy requires a protected space – this applies analogously and digitally. The fact that the ePA will henceforth be explicitly considered an observation-free space is a success of the DPNW's intervention," explains DPNW chairman Dieter Adler.

Preparations are currently underway for the establishment of the EHDS, in which health data will be exchanged for care and research in the coming years. At the national level, billing data is already accessible. Without high data quality, functioning national infrastructure, and adequate data protection, the ambitious European project threatens to become a flop for Germany.

(mack)