DiGA Reimbursement Reform Unleashes New Opportunities
Updated on 11 May 2026 · Originally published 3 May 2026
7 min read
The DiGA reimbursement reform entered into force on 1 April 2026. New GOP codes now let physicians bill for DiGA accompaniments directly. At the same time, the nationwide rollout of the electronic patient record (ePA) for 73 million statutory-insurance policyholders is gathering pace. Together, these two shifts are fundamentally reshaping the purchasing landscape of Germany’s health-care system: health insurers are morphing into enterprise buyers of digital infrastructure, and interoperability is becoming a core tender requirement. For IT service providers, this is a structural market-opening moment.
Key Takeaways
- DiGA reform as of 01.04.2026: New GOP codes let contracted physicians bill for DiGA accompaniments directly, boosting physician-side demand and creating fresh revenue paths for DiGA manufacturers.
- ePA as infrastructure catalyst: The blanket ePA (opt-out) has been live since February 2025. 2026 is the year in which back-office integration with the regional association (KV) systems becomes critical. FHIR-standard interoperability is now mandatory, not optional.
- Health insurers as new enterprise buyers: Statutory health-insurance funds must expand their digital health offerings. Tender volumes for digital infrastructure 2026–2028: estimated at more than €800 million across DACH.
- Window for IT service providers: Those who now build Healthcare-FHIR expertise and TI-2.0 references will be in a pole position for insurer tenders over the next three years.
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DiGA and ePA: What the reform entails in concrete terms
What are DiGA and ePA? DiGA (Digitale Gesundheitsanwendungen, digital health applications) are CE-certified apps available via the “app on prescription” route and reimbursed by statutory health insurance (GKV) funds after inclusion in the DiGA directory. The ePA (electronic patient record) is the central digital patient record that will be automatically created for all 73 million GKV-insured individuals starting February 2025 (opt-out instead of opt-in). Both instruments are linked through the Telematics Infrastructure 2.0 (TI 2.0) operated by gematik.
The DiGA reimbursement reform effective 1 April 2026 expands beyond direct physician prescription: new GOP codes in the EBM (Uniform Valuation Standard) now explicitly allow billing for physician time spent on DiGA guidance and documentation. While technical in nature, this change delivers a direct economic incentive—physicians now have a billing incentive to actively integrate DiGA into treatment pathways, not just prescribe it.
Digital Health Market Potential Germany 2026
73 Mio.
GKV-insured with ePA
800+ Mio. EUR
estimated IT tenders 2026–2028
97
DiGA listed (Q1 2026)
Health insurers as enterprise buyers: implications for IT service providers
Statutory health insurance funds have historically operated decentralised and slow procurement structures. The ePA mandate changes that. Funds must now actively provision and expand infrastructure—no longer optional. This drives two purchasing movements:
Opportunities for IT service providers
- FHIR implementation projects at health insurers
- TI-2.0 connectivity for hospitals and medical care centres (MVZ)
- Data management for ePA population analyses
- AI evaluation of anonymised health data
- Interoperability middleware between DiGA and practice management systems
Complexity and risks
- Certification obligations (gematik, BSI, data-protection)
- Extended sales cycles (12–24 months with insurers)
- Legacy technical debt in insurer core systems
- Multi-layer data-protection regime (GDPR + BDSG + SGB V)
- Political dependencies tied to legislative changes
Three Entry Points for IT Service Providers in 2026
- Build FHIR implementation expertise. HL7 FHIR R4 is the mandatory standard for ePA interfaces. IT service providers with proven FHIR implementation experience gain a structural advantage in health-insurance tenders. Entry point: gematik test environment, KBV’s FHIR implementation guide.
- Position DiGA manufacturers as reference customers. DiGA manufacturers require backend infrastructure, API connections to practice management systems (PVS), and TI-2.0 connectors. Servicing one or two DiGA manufacturers is the fastest route to verifiable healthcare-IT expertise.
- Set up a health-insurance procurement radar. Statutory health-insurance funds publish infrastructure projects via DTVP (German Tender Portal) and Bund.de. Monitoring these tenders 12 months in advance is the cheapest form of market intelligence in this segment.
„Both developments fundamentally reshape the purchasing structure in Germany’s healthcare system: health-insurance funds become enterprise buyers of digital infrastructure, and interoperability turns into a core tender requirement.“
Market Readiness and Timing: Why 2026 Is the Critical Entry Window
For IT service providers, the German healthcare market has historically been hard to crack: long sales cycles, niche certification hurdles, and conservative procurement rhythms. In 2026, three forces rewrite that equation.
First, the ePA mandate creates a time-critical investment squeeze. Health-insurance funds that fail to adapt their infrastructure by the end of 2026 risk regulatory penalties and a competitive disadvantage in member acquisition. Investments that used to be spread over three to five years are now compressed into 12 to 18 months.
Second, the gematik’s TI-2.0 infrastructure is now stable enough for production projects. Early TI-1.x headaches—connector chaos and glacial gematik approvals—have largely been resolved, slashing implementation risk for IT service providers.
Third, skilled talent is still available. From 2027 to 2029 the market for healthcare-IT specialists will tighten significantly. Firms that recruit and upskill now gain a two- to three-year head start before larger IT players flood the segment.
Sources: gematik DiGA directory Q1 2026, Federal Ministry of Health reimbursement-reform press release (April 2026), National Association of Statutory Health Insurance Funds Digitalization Report 2025.
Frequently Asked Questions
What’s the difference between the old and new DiGA reimbursement models?
Previously, physicians could prescribe DiGA but could not bill separately for the accompanying time. The reform, effective April 2026, adds specific GOP codes in the EBM that make documentation and consultation time directly billable around DiGA prescriptions. This increases physicians’ incentive to integrate DiGA more actively into treatment pathways, which in turn drives demand for DiGA-compatible PVS integration.
Can IT service providers with no prior healthcare experience qualify for GKV projects?
Formally yes, but practically access without healthcare references is difficult. Health insurers typically require documented experience in GDPR-compliant health-data processing and ideally BSI certifications or gematik approvals for the infrastructure components used. The fastest entry is a subcontracting arrangement with a certified healthcare-IT provider for the first 1–2 projects.
How does FHIR integration with the ePA work technically?
The ePA uses HL7 FHIR R4 as the data format for structured health data. Access is provided via the ePA connector of the Telematics Infrastructure 2.0. Practice management systems (PVS) and hospital information systems (KIS) must implement FHIR-compliant APIs to read and write data to and from the ePA. gematik publishes implementation guides and offers a test environment at epa.gematik.de.
Which GKV insurers are the most relevant buyers of digital infrastructure?
TK (11.5 million insured), DAK (5.7 million) and the AOK Group (26+ million) are the largest buyers. The AOK Group is decentralized (11 regional AOKs), making tenders more complex but also creating entry points for smaller providers. The BKK association and IKK funds are attractive for specialized offerings. Tender platform: dtvp.de and bund.de/EVERGABE for public tenders.
What are the key compliance requirements for digital health infrastructure?
Three regulatory frameworks are central: GDPR (including Article 9 for health data as a special category), SGB V (§§ 291a–291g for ePA-specific processing rules) and the BSI C5 criteria catalog for cloud infrastructure processing health data. In addition, gematik approval is required for any component directly connected to the TI. BSI publishes technical guidelines for healthcare IT at bsi.bund.de.
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