„Aber die elektronische Patientenakte ist doch für Versicherte freiwillig“

Das hören wir häufig als Argument gegen unsere kritischen Positionen. Zeit, sich dem einmal zu widmen. Stein des Anstoßes ist ein kürzlich veröffentlichtes Gutachten des Sachverständigenrates (SVR) Gesundheit zur Digitalisierung des Gesundheitswesens.

Aber eins nach dem anderen und zunächst zu unserer Skepsis gegenüber der vielzitierten Freiwilligkeit:

(1) Die Erhebung (sensibler) personenbezogener Daten erfordert nach der europäischen Datenschutz-Grundverordnung (DSGVO) die ausdrückliche und informierte Einwilligung der betroffenen Person. „Informiert“ bedeutet, dass ich vor meiner Einwilligung darüber aufgeklärt wurde, wer welche Daten für genau welche Zwecke von mir erhebt, wer alles die Daten übermittelt bekommt, wer mich bei Datenschäden informiert, welcher Datenschutzbeauftragte zuständig ist, wie ich nachträglich widersprechen kann… und das in klarer, einfacher und leicht verständlicher Sprache (siehe insb. Art. 7, 9, 13 und 14 der DSGVO). Werden Versicherte von ihren Krankenkassen hierüber aufgeklärt, bevor sie der Anlegung einer elektronischen Patientenakte (ePA) zustimmen? Bislang nicht. Genauso wenig gibt es eine Aufklärung über die Risiken der ePA. Damit werden die Kriterien für eine informierte Einwilligung nicht erfüllt.

(2) Eine echte Freiwilligkeit setzt weiter voraus, dass ich keine Nachteile zu erwarten habe, wenn ich mich dagegen entscheide. Die Krankenkassen müssen für die Bereitstellung der ePA unfassbar hohe Summen ausgeben. Wir können erwarten, dass die Krankenkassen die ePA dann auch verbreiten wollen. Zum Beispiel, indem sie Beitragsermäßigungen in Aussicht stellen, wenn der ePA zugestimmt und sie fleißig befüllt wird (siehe Bonusprogramme). Oder indem zusätzliche „Bearbeitungsgebühren“ erhoben werden, wenn die ePA nicht genutzt wird. In dem Moment, in dem Nutzer der ePA Vorteile erhalten, sind alle anderen (relativ) benachteiligt. Dass es so kommen wird, ist Spekulation. Aber keine so realitätsferne, wie wir meinen.

(3) Eine andere Möglichkeit, die ePA unter die Leute zu bekommen, ist die sogenannte passive Widerspruchslösung, auch genannt Opt-Out-Lösung. Bislang müssen Versicherte ihre ePA aktiv bei ihrer Krankenkasse beantragen (Opt-In-Lösung). Wenn das aber Wenige tun, kommt schnell die Idee, dass jeder (gesetzlich) Versicherte automatisch eine ePA angelegt bekommt, und zwar ab seiner Geburt, solange er bzw. seine Bevormundeten nicht aktiv widersprechen (Opt-Out-Lösung). Diese Entwicklung haben wir bereits in Frankreich. Da haben sich, nach Meinung des Gesetzgebers und der Betreiber, viel zu wenige Versicherte die dortige Version der elektronischen Patientenakte (Dossier médicale partagé, DMP) anlegen lassen. Ab 2022 soll dort nun die Opt-Out-Lösung gelten, mit der Zielsetzung, auf diesem Weg 40 Millionen elektronische Patientenakten aktiv zu bekommen (Quelle: Ärztenachrichtendienst).

Und in Deutschland? Hier kommt nun der eingangs erwähnte Sachverständigenrat ins Spiel. In seinem 360 Seiten umfassenden Gutachten fordert er für die elektronische Patientenakte jetzt auch hierzulande genau die Opt-Out-Lösung. Wie ist das – und der SVR – zu bewerten? Der SVR-Gesundheit ist an das Bundesgesundheitsministerium (BMG) angebunden; wer ihm eine E-Mail schreiben möchte, landet beim BMG. Und wir können noch etwas weiter forschen: Ein Mitglied des SVR, Dr. Jonas Schreyögg, ist Mitglied des Hamburger Center for Health Economics: „Ein wichtiger Aspekt des Gutachtens ist, dass der Zugang zu Versorgungsdaten für die Forschung verbessert werden muss, um den Wissenschafts- und Innovationsstandort Deutschland wettbewerbsfähig zu halten“, so Schreyögg (Quelle). Ökonomie und Wettbewerbsfähigkeit also. Gesundheitswirtschaft ist auch dem BMG sehr wichtig.

Nun ist Ökonomie nicht gleich schlecht. Auch unsere Therapieangebote müssen nicht zuletzt ökonomisch angemessen sein, einer Abwägung zwischen Kosten, Nutzen und Risiken standhalten. Aber wenn die Berücksichtigung der Ökonomie zu einem Fokus auf (Gesundheits-)Wirtschaft wird und den Blick für wissenschaftliche Evidenz verstellt, wird es problematisch. Der SVR empfiehlt die Opt-Out-Lösung, obwohl eine von ihm selbst konzipierte Online-Umfrage zu dem Ergebnis kommt, dass sich die Mehrheit der Befragten eine dauerhaft freiwillige Nutzung der ePA wünscht und 65 % der Befragten Angst vor Datenmissbrauch haben. Wie passt das offensichtliche Ignorieren dieser Umfrageergebnisse mit dem Argument der Befürworter zusammen, dass die ePA die Patientenhoheit stärke? (Und dabei hat sich der SVR doch schon solche Mühe gegeben, indem er durch die Online-Umfrage technikfreundliche Menschen zu erreichen versuchte)

Schlussfolgerung – wie es unser Mitstreiter Lothar Seite einmal formulierte: Die Freiwilligkeit der ePA für Versicherte ist das zur politischen Durchsetzung notwendige Feigenblatt.

H. Heck

 

 

 

 

 

Dieser Beitrag hat 8.450 Kommentare

  1. Hildegard Fischer 20 Apr. 2021 Antworten

    Sehr guter Text, danke! Ihre nüchterne, klare Argumentation gefällt mir, der Inhalt erschreckt immer wieder. Hildegard Fischer

  2. Lothar Seite 17 Juli 2021 Antworten

    Recht umtriebig in der „Gesundheitswirtschaft“ ist Dr. Chima Abuba (Hartmann AG, DIG GmbH, Alloheim Seniorenresidenzen). Und ab und zu veröffentlicht er auch Artikel in der „Welt“ https://www.welt.de/wirtschaft/bilanz/article184471032/Elektronische-Gesundheitsakte-Angst-vor-Datenmissbrauch-hemmt-Fortschritt-im-Gesundheitswesen.html :
    „Wer sich der eGA bei erfolgreicher Implementierung trotz jeglicher Sicherheitsvorkehrungen verweigert, sollte zwar zunächst keinen spürbaren Qualitätsverlust der Behandlung per se erleiden, käme aber auch nicht in den Genuss eines schnelleren und bequemeren Behandlungsablaufs. Längerfristig muss man allerdings damit rechnen, dass mangelndes Vertrauen mit Einbußen in der Behandlungsqualität vergolten wird.“
    Die Nutzung der ePA ist natürlich freiwillig, aber ihr werdet schon sehen, was passiert, wenn ihr weiter so mißtrauisch seid.

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