Although physicians have been required since 1 October 2025 to populate the electronic patient record (ePA) with diagnoses, referral letters, and laboratory values, it appears that no practical enforcement is taking place. According to “Spiegel”, doctors who fail to use the ePA from the start of 2026 face a reduction of their fee, yet the authority responsible for inspection has no technical means to verify that the records are actually being filled.
The Association of Statutory Health Insurance Physicians (KV) usually checks only that the ePA module is technically installed and kept “ready for use” in the practice management system. Whether the module is employed in everyday clinical work is “not checked and not sanctioned” according to industry insiders.
In a statement, the Federal Ministry of Health (BMG), led by Nina Warken (CDU), reiterated that monitoring compliance with the fill obligation falls under the KVs’ responsibilities. The ministry said that no adjustments to the penalties for non‑compliance are currently planned.
The Digital Law stipulates that doctors who do not use the ePA will suffer a 1 % fee cut and a 50 % reduction of the telematics infrastructure allowance. However, because usage is difficult to verify, these sanctions are triggered only when the requisite software is completely absent from the practice, “Spiegel” reports.
If patients notice that their ePA remains empty, the BMG directs them to the KV or their statutory health insurance provider. Those insurers can only provide advice; they have no legal power to compel doctors to fill the record.
