Mark Langguth – former specialist in charge of the electronic patient file (ePA), now a freelance consultant in the field of telematics infrastructure (TI) – strongly criticizes the ePA’s authorization concept because the so-called fine-grained rights management, which is to come into force on January 1, 2022, has not yet been properly refined. Here there is a need for improvement in document categorization. Not affected is the ePA in version 1.0, which will be launched on the market as early as January 2021. The first version, which is mandatory for health insurance companies and all involved players in the healthcare system, is already in the starting blocks. It features a reduced rights management system, in which a medical practice can only receive flat-rate approvals based on two document baskets. The document baskets include medical documents as well as documents set up by the insured himself. The ePA version 2.0 features fine-grained rights management, which is protected by law. Behind the rights management of this version is the Patient Data Protection Act (PDSG), which entitles insured persons to decide which physician may view which documents. However, all medical specialty categories are not delimited from each other, so that each physician could view any document from another physician in a different specialty. The classification of the individual specialties would therefore have to be changed by gematik, which has already published the specifications for the ePA, before industry partners are ready with the next version after version 1.0 is completed. For example, specialist areas could then be separated from the field of gynecology under the generic term „psyche“. The same applies to the specification of the ePA 2.0, which gematik has already defined in such a way that, for example, all e-medicine letters fall into a category that also includes the medication plan, the dental bonus booklet, the maternity pass, nursing documents and others. It is not possible in this way to differentiate between specialist medical content that is taboo for other doctors and may not be viewed because the insured person does not want this. However, in order for the ePA 2.0 to be ready for practical use by the insured, explains the expert and specialist, gematik has to rework it with regard to clearly defined „document categories“.
