Executive Summary

Germany is positioning itself as a pioneer in building the European Health Data Space (EHDS). The electronic patient record (ePA), which has been available nationwide since January 15, 2025, forms the technological foundation for cross-border data exchange in the EU. Representatives from Gematik, AOK, and Bundesdruckerei presented an ecosystem of structured health data, European patient records, and the planned European Digital Identity Wallet (EUDI-Wallet) at the DMEA conference in Berlin. The goal is to enable EU citizens cross-border healthcare starting around 2027 – for example, by redeeming German e-prescriptions abroad.

People

Topics

  • Digital health
  • European data governance
  • Medical interoperability
  • Data protection

Clarus Lead

The EU under pressure: Creating a genuine "European health union" is technically ambitious but has so far failed due to organizational and political hurdles. While Germany can advance with its ePA infrastructure, critical gaps are becoming apparent – particularly in emergency scenarios where unconscious patients cannot consent themselves. The timeline is tight: Only 5 percent of the German population currently uses the health ID; to achieve mass adoption, user-friendliness must increase significantly.

Detailed Summary

Gematik is relying on a structured data architecture that is directly aligned with clinical care processes. Medication data, laboratory results, and physician letters are defined as core elements of the EHDS to ensure that the European data space actually supports doctors and patients. The National Contact Point for eHealth (NCPeH) serves as a central interface for data exchange between member states.

The business model provides for: Insured persons access a personal health data space via their health insurance app, select a European patient record (planned from 2027 onwards), and selectively share relevant information (allergies, chronic conditions, pregnancy) with foreign healthcare providers via an access code. Automated translation into the local language is provided for. The EUDI-Wallet is intended to simplify complex authorization processes and improve usability for edge cases (such as cross-border emergency treatment).

However, two problems remain unsolved: (1) The health ID has achieved only approximately 5% penetration, which jeopardizes mass adoption. (2) Emergency scenarios ("breaking-the-glass"), in which patients cannot consent, have not yet been designed – a classic data protection versus care protection dilemma. France also warns of time pressure: Political and organizational coordination between 27 member states is significantly more complex than technical implementation.

Key Statements

  • Germany launches nationwide ePA (since 15.1.2025) as the foundation for European interoperability
  • European patient record from 2027 is intended to enable insured persons to access data across borders and redeem e-prescriptions abroad
  • Emergency access for unconscious patients has not yet been designed in regulatory terms
  • Low usage rates (5% health ID) and organizational fragmentation threaten the ambitious timeline target

Critical Questions

  1. Evidence: What studies or pilots demonstrate that the planned ePA architecture with low user complexity (measured, for example, by task-completion rate) is actually feasible?

  2. Conflicts of Interest: How is it ensured that health insurance companies and private insurers meet the same governance standards in a shared data exchange framework without creating national asymmetries?

  3. Causality: Is the measured 5% user rate of the health ID primarily caused by lack of technical user-friendliness or by lack of incentives (lack of benefits for users) – or both?

  4. Feasibility – Emergency: What legal and technical solution options for the "breaking-the-glass" scenario already exist in other EU countries or non-EU countries, and why were these not adapted?

  5. Risks – Adoption: If mass adoption does not occur by 2027, will the EHDS be launched with fragmented user groups – what fallback scenarios are planned?

  6. Conflicts of Interest – Data Flow: What guarantees exist that health data across country borders does not receive commercial tracking or research access without explicit user re-consent?

Sources

Primary Source: Germany to Deliver ePA and EUDI-Wallet for EU Health Data Space – heise.de

Additional Context:

  1. DMEA 2025, Berlin (January 28–30, 2025)
  2. Gematik: ePA Dashboard and user statistics

Verification Status: ✓ 2025-01-28

This text was created with the support of an AI model.
Editorial responsibility: clarus.news | Fact-checking: 2025-01-28