Why an electronic record alone is not enough: structured data instead of a collection of PDFs

What do ELGA and the ePA achieve – and what is their actual purpose?

ELGA and the ePA are access and storage infrastructures: they ensure that medical documents are available across facility boundaries and regulate who may access what. This function is necessary and is firmly anchored in policy and regulation in both countries – in Germany, the ePA has been mandatory since October 1, 2025, and ELGA has been in use in Austria for over a decade. Both systems thus solve the availability problem of the patient record. They do not automatically solve the structure problem: whether a document in the record is machine-readable or only available as an image file or PDF depends on how and where the underlying data was originally recorded.

Why does a collection of PDFs not make a structured record?

Markus Beier, who chairs the German association of general practitioners (Hausärztinnen- und Hausärzteverband) jointly with Nicola Buhlinger-Göpfarth, soberly describes the ePA as it currently stands in practice as an “unsorted collection of PDFs” that medical staff have to work through manually without full-text search – with corresponding time expenditure and no clear additional clinical benefit. The Deutsches Ärzteblatt reported in February 2026 that, despite 94% awareness among the population, fewer than one in five people actively use the ePA; 33% of respondents saw no personal benefit for themselves. These figures are not a verdict on the idea of the electronic record, but an indication that availability alone does not create added value in everyday clinical practice if the documents it contains are not structured and searchable.

What exactly does the Court of Audit report on ELGA show?

In its report “Potenzial von elektronischer Gesundheitsakte ELGA nicht voll ausgeschöpft” [potential of the ELGA electronic health record not fully exploited] (October 2024), the Austrian Court of Audit reached a comparable finding: eight years after launch, there were still no structured documents available for specialist findings, eMedication remained incomplete with gaps in dosage information, and by the end of 2023 only hospitals were systematically supplying findings to the e-Befund (electronic findings) – office-based specialists, radiology institutes and laboratories were not yet consistently connected. With a budgeted expenditure of around €99 million, there was also, according to the Court of Audit, no complete overview of the actual total costs.

What are medical information objects – and why do they only partly solve the problem?

Medical information objects (MIOs) are the technical approach with which the ePA solves the PDF problem in principle: instead of a document, an MIO transmits structured individual values – such as vaccination status, active substance or dosage – directly into the appropriate fields of the receiving system, using a uniform terminology (including SNOMED CT) for what is known as semantic interoperability. The Deutsches Ärzteblatt described this difference as early as 2022 using the example of the maternity record (Mutterpass): as a PDF, the receiving party has to look up the information by hand; as an MIO, it is available automatically. The limitation lies in the origin of the data: an MIO can only be as structured as the recording from which it is generated. If a medical history continues to be taken as free text or on paper, the document generated from it also remains unstructured – regardless of how powerful the record itself is.

How does a structured digital medical history complement ELGA and the ePA?

medudoc does not compete with ELGA or the ePA, but addresses the gap upstream of them: recording at the source. The smart medical history vs. digital questionnaire collects pre-existing conditions, medication and risk factors from the outset as structured individual values instead of free text, continuously checks them for completeness and makes them available to the hospital information system via FHIR interfaces. Whether this structured data is subsequently also fed into ELGA or the ePA depends on the hospital’s particular HIS integration – medudoc supplies the structured starting point that turns an electronic record into more than a document store. The same link between fragmented recording and avoidable duplicated work is also described in the article digital medical history as a blind spot in the surgical process; the article avoiding duplicate diagnostics through a structured medical history shows how incomplete previous findings can lead to unnecessary diagnostics.

What does this mean for hospitals introducing ELGA or the ePA?

For hospital IT management, this results in a clear order of priorities: connecting to ELGA or the ePA is a mandatory regulatory task and should be implemented regardless of how structured the hospital’s own data is. The real efficiency gain, however, only arises when the hospital itself generates structured data at the source – in the medical history, admission and the pre-anaesthesia clinic – instead of uploading additional documents to the record. The digital preoperative workflow of medudoc shows how this approach is embedded in the entire process from medical history to consent. For Austrian hospitals, the legal classification of consent is also relevant, which is presented in the article informed consent in Austria.

Conclusion

ELGA and the ePA are a necessary step, anchored in regulation, towards making medical documents available – the current criticism does not concern the idea, but the degree of structure of the content, as shown both by the Court of Audit for ELGA and by current feedback from practice on the ePA. An electronic record only becomes a real efficiency gain when the data that flows into it is recorded in structured form from the outset. This is exactly the task that a structured digital medical history performs upstream of the record – not as a replacement, but as a prerequisite for ELGA and the ePA to actually realise their potential.