Electronic patient record: Consumer advocates demand independent evaluation

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“We simply have to state that after a good year, it's not really running smoothly,” said Ramona Pop, Chairwoman of the Federation of German Consumer Organisations (vzbv), at the presentation of the survey results on the electronic patient record (elektronische Patientenakte, ePA). The ePA is “the big digital health project,” affects “75 million insured persons,” and has the potential to make “healthcare safer, more efficient, and more transparent.” “But, and here comes the big but, as it has started and been designed so far, it is simply falling far short of expectations. [...] We simply have to state that after a good year, it's not really running smoothly.” This is hardly surprising, as central functions, such as digital vaccination documentation, are still missing.

The ePA is known to most statutory health insurance members; however, it is currently actively used only by a minority. This is shown by a representative survey commissioned by the Federation of German Consumer Organisations (Verbraucherzentrale Bundesverband, vzbv), which the association published on February 18, 2026, along with a position paper and the analysis of a consumer appeal. According to the survey, 94 percent of statutory health insurance members know the ePA – 74 percent of them through press and media, 45 percent through letters from their health insurance company. For the ePA to reach its full potential, it must be rapidly further developed to offer added value to insured individuals, according to Pop.

Since the beginning of 2025, statutory health insurance companies have been providing their members with an electronic patient record, provided they have not objected. Since October 2025, doctor's offices, pharmacies, and hospitals have been obliged to populate the ePA. However, according to the results of the Forsa survey, 71 percent do not manage their record themselves. Nine percent have objected to the ePA or had it deleted. 12 percent of respondents use their ePA via a smartphone or tablet, 2 percent each via a computer or laptop, via an authorized person, or via their health insurance company's ombudsman.

About a third see no benefit

The most important reason for the lack of active use so far, according to 75 percent of those who do not manage their ePA themselves, is that they have not yet dealt with the topic. 33 percent currently see no personal benefit. 13 percent each state that they cannot sufficiently control who can view which data, or they worry about data security. Eleven percent consider the ePA to be generally too complicated, eight percent report problems with setup or technical use.

Among the desired functions, control over one's own health data is paramount for many insured individuals. 68 percent wish for the ability to precisely control who can see which health data, such as findings. 66 percent favor digital examination records such as vaccination records, dental bonus cards, or maternity records. 64 percent each wish for information on possible interactions between medications or on missing vaccinations, 62 percent for an overview of their medications. “Insured persons must be able to precisely set which practice has access to which information. For example, patients may want to share psychotherapeutic findings with their general practitioner's office, but not necessarily with their dentist's office,” said Pop.

Data transfer to the Research Data Centre Health unknown

Information deficits are also evident regarding the planned use of research data. From the end of 2026, data from the ePA will be pseudonymized and transferred to the Research Data Centre Health via opt-out for research purposes. Only 25 percent of respondents knew that their data could also be used for research purposes in the future. 54 percent state that they have learned something about the ePA from their health insurance company – for example, through personal letters or public information. “Health insurance companies and the Ministry of Health must inform insured persons about the ePA in a understandable and comprehensive manner. This has been insufficient so far,” says Pop. Lucas Auer from vzbv also pointed out that there is a risk of significant loss of trust and image if data falls into the wrong hands, for example.

As early as 2024, the Federal Commissioner for Data Protection had repeatedly admonished health insurance companies to provide better information in the future. Preferably before the ePA data is automatically transferred to the Research Data Centre Health, so that insured persons can object if necessary.

Criticism of lack of user-friendliness

In addition to the representative survey, the vzbv evaluated a total of 1149 responses from consumers between May 26, 2025, and January 29, 2026. In the non-representative survey, insured persons describe, among other things, multi-stage registration processes perceived as confusing. In some cases, in addition to the actual ePA app, an additional Ident-App is required, between which one must switch, which is confusing. Furthermore, problems with PIN letters, error messages when reading the electronic health card, NFC problems, and connection interruptions are mentioned. Incompatibilities with older smartphones or additional requirements such as special card readers for desktop access are also reported. Similar observations were also made by the editorial team.

There is also criticism of the range of functions. For example, the digital vaccination pass is not yet offered as standard. In some cases, the ePA was empty after setup, and relevant findings still had to be transmitted between practices in paper form. Individual feedback also relates to the presentation of diagnoses or medication data, which are perceived as incomplete or misleading. Furthermore, consumers report unclear or contradictory information from health insurance companies, as well as insufficient support with technical issues.

Access for as many people as possible demanded

In its position paper, the vzbv advocates for a patient-oriented further development of the ePA. The registration process must be technically smooth and understandable. For people without suitable end devices or sufficient digital competence, alternative access routes are necessary, for example, through representation models or support services. For announced functions such as digital examination records, the association demands a binding timetable. Furthermore, the fine-grained control of access rights should be legally anchored, as should transparent and comprehensive information about the transfer of research data and existing objection options.

In addition, the vzbv criticizes that there is still no sufficient data sovereignty. “Information from, for example, psychotherapeutic treatment should be easily shareable via the ePA with the general practitioner's office, without automatically making it accessible to other service providers. This is currently neither possible nor intended, although 83 percent of statutory health insurance members wish for as many setting options as possible for the transfer of their health data in the ePA in the future.”

Independent evaluation of the ePA

Furthermore, according to consumer advocates, an “independent evaluation of the ePA” is needed. It is incomprehensible that this has not yet been planned. “The legislator must quickly initiate an independent and continuous scientific evaluation of the ePA.” In addition, the vzbv demands: “The BMG and Gematik must guarantee the highest possible level of data security in the ePA. They must present potential risks and identified security vulnerabilities in communication regarding the ePA just as transparently as the opportunities of the ePA,” the paper states.

The representative survey was conducted from November 3 to 7, 2025, as a computer-assisted telephone survey. 1037 statutory health insurance members aged 16 and over were surveyed, including 1000 people who know the ePA. The statistical margin of error is a maximum of plus or minus three percentage points in the total sample.

(mack)