Outlook 

The implementation of the EHDS may exert a high pressure on the Member States to adapt and may be associated with high costs. It is problematic that many decisions – from the scope of data to technical specifications – are to be made in implementing acts. Such acts lay down detailed rules on aspects which are often very technical but essential for the implementation of that basic act (implementing decisions). Implementing acts are usually adopted by the European Commission under the monitoring of committees composed of representatives of the Member States. Here, the Member States should be more involved and have the right to review.

The approaches to primary and secondary data use are very different. With the use of primary data, cross-border healthcare, in particular should also receive a boost. The use of secondary data, on the contrary, aims at the exploitation of national data resources. The current legislative process will show whether the decision to bring the two approaches under one roof was planned with foresight.

The social insurance institutions generate, process and use health data to optimise care. From the point of view of the social security system, it is important that the Member States have sufficient co-determination rights in the EHDS. This is because the national circumstances of the health and social systems cannot be applied to other countries, neither in terms of the content nor the depth of the regulations EU level should be fully taken into account.