DGIM: Initial ePA filling is the sole responsibility of the medical profession
10.08.2023 15:39
The German Society for Internal Medicine (DGIM) welcomes the fact that the Federal Ministry of Health is consistently pushing forward digitalization in the healthcare system with the draft bill for the Digital Act (DigiG) and clearly aligning it with the needs of users. At the same time, the specialist society demands that the initial filling of the electronic patient file (ePA) with health data must be carried out by doctors who are fully familiar with the medical history of the respective insured person.
This is the only way to ensure that the digital file contains all information relevant to care. In addition, the DGIM sees a need for adjustments to the regulations on the electronic medication plan (eMP), telemedicine, digital health applications (DiGA), interoperability and ensuring the use of data for research. The DGIM experts have developed suggestions on these topics and summarized them in a statement.
The ePA is considered the core of the digitalization of the healthcare system, as it promises to collect all relevant medical information in an orderly and digital manner and to make it accessible to doctors and those affected themselves. It is planned that findings from previous treatments should also be entered into the ePA (ex tunc filling). “In particular, chronically ill people with relevant previous illnesses benefit significantly if the ePA clearly shows how their state of health has developed and how previous treatments have worked,” welcomes Professor Dr. med. Claus Vogelmeier, Chairman of the DGIM Commission for Digital Transformation in Internal Medicine and Special Representative for Digitalization of the DGIM, explicitly expresses this regulation.
DGIM rejects initial filling by health insurance companies
The expert clearly sees the initial filling of the ePA as a task for the medical profession. “Which information from a patient's medical history is relevant for future treatments can best be decided by doctors who have known them for a long time and have treated them frequently,” says Vogelmeier, thus speaking out against the procedure outlined in the previous draft Initial filling of the file by the health insurance companies. Accordingly, patients should send the results they have to the health insurance companies, which will scan the documents and enter them into the ePA. “We reject this regulation, but also the health insurance companies themselves, because how should the insured persons or the employees of the health insurance companies be able to decide technically which findings are relevant to care and which are not?” says DGIM General Secretary Professor Dr. med. Georg Ertl. He also sees this procedure critically with regard to data protection and medical confidentiality.
Initial filling requires technical and quality assurance specifications
There are currently no specifications as to which data must be transferred to the ePA and in what form. “In the long term, we need technical and quality assurance specifications for the initial filling that ensure that information relevant to care is actually contained in the ePA as completely as possible and that treating patients can access it quickly,” demands Ertl. The internist suggests linking these minimum requirements to remuneration and aligning existing remuneration mechanisms in such a way that doctors receive an incentive to actively offer the ePA to their patients and fill it for them.
The DGIM also welcomes the fact that the ePA is to be brought into widespread care via an opt-out solution. This ensures that patients continue to have sovereignty over their data. “In order to ensure the highest possible quality of care, general practitioners should be given the most extensive and unlimited access rights possible right from the start, without special consent,” says digital expert Vogelmeier. If patients actively object to the use of certain data by individual practitioners, they must be fully informed that this can potentially have negative medical consequences for them. “Doctors must not suffer any harm if they are unable to treat patients in the best possible way because they were not allowed to view certain ePA data,” says the Marburg internist.
In its current statement, the DGIM also addresses the topics of medication management, telemedicine and digital health applications. In addition, the experts from the specialist society present views on the interoperability of medical data, the user-friendliness of information technology systems and the planned digital advisory board. It is also important to the DGIM that medical research data is available so that clinical studies can be supplemented with data from routine care.
The full statement can be found here: https://www.dgim.de/fileadmin/user_upload/PDF/Publikationen/Stellungnahmen/20230804_Stellungnahme_zum_Referentenentwurf_BMG.pdf