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Funding eligibility · KHVVG / KHAG · FTB 5

Eligible in a hospital network: medudoc under funding category 5

From 2026 to 2035, the Transformation Fund provides up to €50 billion to restructure the hospital landscape in Germany. If you form a regional network with other hospitals, medudoc can be part of your application as an IT measure. A short legal opinion by Lyck+Pätzold. healthcare.recht sets out the conditions.

  • Legal opinion of April 20, 2026
  • Networks are applying now
  • One-off costs eligible

Your network project in the application

Core measure

applied for by your operator
  • Network agreement
  • Concentration of service groups
  • Construction and staffing

IT measure medudoc

strictly necessary
  • Implementation
  • Configuration
  • HIS integration
Schematic illustration. medudoc usually accounts for a small share of the total volume.

At a glance

What you should know about funding for medudoc

  • Part of your project, not a project of its own

    The Transformation Fund does not fund software on its own. medudoc is funded as an IT measure that supports your core measure, such as forming a hospital network.

  • Funding category 5 first

    Regional hospital networks are preparing their applications now. This is where medudoc is easiest to justify. Telemedicine networks under FTB 3 are likely to follow later.

  • Legally assessed

    A short legal opinion assesses medudoc against the Hospital Financing Act (KHG) and the Transformation Fund Ordinance (KHTFV). You can attach it to your application.

  • One-off costs eligible

    Implementation, configuration and integration count as eligible costs. Ongoing operating costs are excluded from funding.

Result of the legal opinion

Three conditions for medudoc to be eligible in your network

According to the legal opinion, medudoc can be used as an eligible measure in a project under FTB 5. All three conditions must be met.

  1. 1

    Permanent network agreement

    At least two legally independent hospitals agree on permanent cooperation. It aims to reduce duplicate structures in service groups; ownership does not matter.

    Up to your network

  2. 2

    Real concentration

    The project bundles or reduces duplicate structures in one or more service groups, for example by bringing elective procedures together at one network site.

    Up to your network

  3. 3

    One shared platform for all hospitals

    medudoc is introduced as a shared multi-tenant platform. It standardises patient intake, patient education and consent across the entire network.

    We implement it with you

Source: short legal opinion on the funding eligibility of medudoc under the KHVVG, Lyck+Pätzold. healthcare.recht, April 20, 2026, section V. The federal state and the Federal Office for Social Security decide on funding case by case.

Structure of the application

How medudoc appears in your application

medudoc does not submit the application. Your hospital operator registers the network project with the federal state, which applies to the Federal Office for Social Security (BAS). medudoc is one of several measures in it.

Core measure

Forming or developing your network

The actual project under Section 12b(1) sentence 3 no. 5 KHG. It reduces duplicate structures and accounts for most of the costs.

  • Network agreement between the hospitals
  • Concentration of selected service groups
  • Necessary construction and staffing measures
Further measure

medudoc as the shared intake and patient education platform

Procedures cannot be bundled at one site without consistent preparation. The application therefore shows what medudoc contributes to the project.

  • Strictly necessaryPatients from all hospitals prepare for their procedure at the network site to the same standard.
  • In addition to the other measuresmedudoc complements construction, staffing and organisational measures and replaces none of them.
  • Interoperable and secureHL7 FHIR interfaces to the hospital information systems of all hospitals; ISO/IEC 27001:2022 certified and BSI C5 Type 2 audited.

„Eligible costs of a project referred to in sentence 1 are the costs of the necessary construction measures and the costs of further measures, insofar as they are strictly necessary for implementing the project.“

Section 3(5) sentence 2 KHTFV (convenience translation)

medudoc in the network

One standard for surgical preparation in every hospital

medudoc gives the network a shared digital infrastructure for patient intake, medical history, patient education and consent. It replaces differing solutions that have grown locally.

  • One tenant per hospitalEach hospital works as a separate tenant on the same platform. Data remains strictly separated; access is role-based.
  • One preparation pathway per procedureMedical history, patient education video and consent sheet follow the same standard across the network. Specifications are set centrally; each hospital adds its logo, contacts and local workflows.
  • Fewer journeys for patientsWhen procedures are bundled at one site, journeys become longer. Patients complete the medical history and patient education video from home; the consent discussion is also possible telemedically.
  • Uniform evidenceThe audit trail and consent trail document every patient education and consent across the network in the same way.
  • Connection to every HISVia HL7 FHIR, medudoc exchanges data with the hospital and practice information systems of all hospitals involved, structured using ICD-10 and SNOMED CT, among others.
  • Information across hospital boundariesWith the optional medudoc patient account, patients can reuse their information for procedures in other network hospitals if they consent.

medudoc is ISO/IEC 27001:2022 certified and BSI C5 Type 2 audited; data is processed in Germany. Certificate and documents are available in the Trust Center.

Diagram: three hospitals in a network share the medudoc platform, each as a separate tenant connected to its own hospital information system.

Eligible costs

What is funded and what is not

The legal opinion classifies the one-off costs of medudoc as costs for building network structures and harmonising the network's digital infrastructure.

Eligible

  • Implementing the platform in all network hospitals
  • Configuring preparation pathways per procedure and hospital
  • Integration with HIS, PDMS and archive systems

Not eligible

  • Ongoing operating costs of the platform
  • Digitalisation without a network or concentration project
  • Measures that mainly serve administrative purposes

We list the one-off costs as a separate item in the cost estimate. This allows the federal state and the BAS to assess them separately from ongoing use.

Process

From network project to rollout

The core measure sets the pace. We align our documents with the deadlines in your federal state.

  1. 1. Define the project

    The network partners agree which service groups they will bundle at which site.

  2. 2. Plan medudoc in

    We describe the IT measure, its contribution to the project and the cost estimate. You attach the legal opinion.

  3. 3. Register with the federal state

    Your operator registers the project with the responsible federal state. The state selects projects and applies to the BAS.

  4. 4. Await the decision

    Allow about six months until the funding decision. The BAS grants the funds to the state, the state to your operator.

  5. 5. Award and roll out

    Public operators usually award the contract under procurement law. We then roll out medudoc hospital by hospital.

Result: one standard for intake, patient education and consent in every hospital of your network.

Transformation Fund

What the Transformation Fund provides

The fund supports projects by hospitals in Germany that change care structures. It replaces the Hospital Structure Fund (Krankenhausstrukturfonds) and runs for ten years.

funding volume for restructuring the hospital landscape, provided by the federal government and the federal states
€50 billion
term of the fund
2026–2035
federal share from the special fund for infrastructure and climate neutrality
€29 billion
Hospital operators submit projects to their federal state. The state applies to the Federal Office for Social Security (BAS).
State → BAS
  • From 2026 to 2029, the federal states, where applicable together with hospital operators, bear at least 30% of the eligible costs, and from 2030 at least 50%.
  • The BAS reviews the applications, issues the funding decisions and approved the first funds on April 17, 2026.

Source: German Federal Ministry of Health, press release of April 17, 2026.

Legal framework

KHVVG and KHAG: how the two laws are connected

The German Hospital Care Improvement Act (KHVVG) launched the hospital reform and created the Transformation Fund. The German Hospital Reform Adjustment Act (KHAG) adjusts this reform without replacing it. Both laws apply together to your project.

  1. KHVVGIn force since the end of 2024

    Krankenhausversorgungsverbesserungsgesetz (German Hospital Care Improvement Act)

    Sets out the foundations of the reform.

    • Divides hospital services into service groups with quality requirements.
    • Introduces standby funding (Vorhaltevergütung), which pays part of the budget independently of case numbers.
    • Creates cross-sector care facilities.
    • Establishes the Transformation Fund with eight funding categories (Section 12b of the Hospital Financing Act, KHG).
  2. KHAGIn force since April 15, 2026

    Krankenhausreformanpassungsgesetz (German Hospital Reform Adjustment Act)

    Adapts the reform to implementation in the federal states.

    • Revises service groups and quality criteria.
    • Introduces standby funding at a later date.
    • Extends exemptions and cooperation options for the federal states.
    • Finances the federal share of the fund from the special fund instead of from statutory health insurance funds.

The funding categories come from the KHVVG. Financing and deadlines follow the version as amended by the KHAG.

Funding categories

Where medudoc fits into the Transformation Fund

The fund has eight funding categories (FTB). The legal opinion assesses five of them. The same principle applies everywhere: medudoc is part of a main project.

  • FTB 5Now

    Regional hospital networks

    In a network, shared standards count. medudoc maps one uniform preparation pathway per procedure for all hospitals. Eligible if the three conditions are met.

  • FTB 1Possible

    Concentration across sites

    If a hospital concentrates acute inpatient services across two or more sites, medudoc harmonises preparation in addition to the construction measures. Preparation from home offsets longer journeys.

  • FTB 3Likely later

    Telemedicine network structures

    A central anaesthesia team reviews complete cases from all sites and resolves queries in a targeted way. The legal opinion considers the conditions met in principle; the Federal Ministry of Health's minimum requirements are decisive.

  • FTB 2Case by case

    Cross-sector care facilities

    Medical history, findings and consent are available before admission. This requires the federal state to designate the site as such a facility and medudoc to be aligned with its internal medicine and geriatric workflows.

  • FTB 4Case by case

    Centres for rare, complex or serious diseases

    Patients often travel long distances and prepare completely and in several languages beforehand. Eligible together with a university hospital if medudoc ensures interoperability in the centre.

The remaining funding categories concern integrated emergency care structures (FTB 6), the closure of sites (FTB 7) and additional training capacity (FTB 8). The article KHAG funding eligibility summarises the legal assessment.

Legal opinion

The legal assessment is available

medudoc commissioned the law firm Lyck+Pätzold. healthcare.recht with the assessment. The opinion describes the platform, assesses it against the KHG and KHTFV and names conditions and limits. Reviewers find the reasoning in one place.

What the opinion covers

  • Description of the medudoc platform and its end-to-end workflow
  • Assessment of funding conditions under FTB 5, FTB 3 and FTB 2
  • Classification of FTB 1 and FTB 4 as additional funding options
  • Distinction between eligible and ineligible costs

The legal opinion does not replace a case-by-case review. The federal state and the BAS decide on funding. The opinion is available in German.

Short legal opinion

Funding eligibility of medudoc under the KHVVG

Lyck+Pätzold. healthcare.recht

Date
04/20/2026
Length
20 pages
Assessed
FTB 2, 3 and 5, plus 1 and 4

FAQ

Questions about funding eligibility, the KHVVG and the KHAG

Is medudoc funded as a project of its own?

No. Unlike under the Hospital Future Act (Krankenhauszukunftsgesetz, KHZG), digitalisation is not a funding purpose in its own right in the Transformation Fund. medudoc is eligible as an IT measure that is strictly necessary for a core measure, for example forming a regional hospital network under funding category 5.

Which conditions does the legal opinion set for FTB 5?

Three conditions must all be met: at least two legally independent hospitals conclude a permanent network agreement. The project concentrates or reduces duplicate structures in service groups. And medudoc is introduced as a shared multi-tenant platform for intake, patient education and consent across the network.

Who submits the application?

Your hospital operator registers the network project with the responsible federal state. The state selects projects and applies to the Federal Office for Social Security (BAS). The BAS reviews and approves; the state passes the funds on to the operator. medudoc does not submit its own application; it provides the service description, cost estimate and legal opinion for your documents.

How high is the federal states' own contribution?

The federal states, where applicable together with the hospital operators, contribute to every project: from 2026 to 2029 with at least 30% of the eligible costs, from 2030 to 2035 with at least 50%.

Which medudoc costs are eligible?

The one-off costs for implementing, configuring and integrating the platform in the network are eligible. According to the legal opinion, ongoing operating costs are excluded from funding.

How long does it take to receive a decision?

Allow about six months. Public operators then usually award the contract under procurement law before the rollout begins.

Is medudoc also eligible under telemedicine (FTB 3)?

The legal opinion considers the conditions for telemedicine network structures met in principle. medudoc must meet the uniform national minimum requirements and interoperability standards of the Federal Ministry of Health. We expect FTB 3 projects rather in the second half of the funding period.

What is the difference between the KHVVG and the KHAG?

The German Hospital Care Improvement Act (Krankenhausversorgungsverbesserungsgesetz, KHVVG) has been in force since the end of 2024 and forms the basis of the hospital reform, including service groups, standby funding and the Transformation Fund. The German Hospital Reform Adjustment Act (Krankenhausreformanpassungsgesetz, KHAG) has applied since April 15, 2026. It amends the KHVVG in specific areas, such as deadlines, exemptions and the financing of the fund.

Which funding categories are there?

Section 12b of the Hospital Financing Act (KHG) lists eight funding categories: cross-site concentration, cross-sector care facilities, telemedical network structures, centres for rare, complex or serious diseases, regional hospital networks, integrated emergency care structures, the closure of sites and additional training capacity.

Does the funding also apply in Austria and Switzerland?

No. The Transformation Fund is an instrument of the hospital reform in Germany and only supports projects of German hospitals.

Is funding guaranteed?

No. The legal opinion assesses eligibility from a legal perspective. Whether a project is funded is decided case by case by the federal state and the BAS.

Is your network planning an application? Let's talk about your project.

We provide the legal opinion, a service description and a cost estimate for your application, tailored to the service groups your network wants to bundle.

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