AIM position on the EHDS


Health insurance funds and not-for-profit health mutuals support a better use of data and therefore welcome the proposal on the European Health Data Space. AIM agrees with the huge potential that a flexible use of health data has for patient centeredness as well as improving healthcare quality and outcome. A closer cooperation in the use of health data shall aim to improve patient’s access to healthcare and allow to predict the costs of the treatments more easily (the amount to pay and the part reimbursed by the health system). We propose the following recommendations:

  • Respect national data structures already in place
  • Financial support from Europe will be necessary
  • Influence of the member states for the implementation of EHDS needs to be strengthened
  • Digital health/data literacy is necessary to avoid widening the inequality gap
  • Cybersecurity is indispensable
  • Prevention should be a main goal of the European Health Data Space to achieve good health
  • Put in place an efficient and unified certification process for the secondary use of health data
  • An implementation period of 5 years (on the condition that all technical details are decided within 24 months after the entering into force.
  • Ensure data quality in the European Health Records
  • Self-certification for software suppliers for EHR systems and wellness apps is not sufficient
  • Health data generated by wellness applications and other digital applications should not be part of secondary use of health data
  • Intended purpose to use health data for public health and social security needs to be clarified
  • Prohibited secondary use of health data must be described precisely to “avoid shopping”
  • Health data used for research and innovation need to be fully disclosed and transparent
  • Direct exchange between requester and single data holder should be voluntary

Read our position paper: AIM position on the European Health Data Space_final