No access to the digital health space (ENS) for occupational medicine (draft decree)


A previous version of the text provided that the occupational health services obtain the right to “exchange or share information” relating to the same patient, in the same way as the other professionals listed in article R1110-2 of the code of public health.

Occupational health services are no longer mentioned in the new version of the draft decree.

As the shared medical record (DMP) is intended to become a component of the ENS, this non-access of occupational medicine to the ENS could mean a non-access to the DMP for these same services. The text, as well as a second draft decree relating to the DMP consulted by APMnews / TICsanté, do not provide any details on this point.

At present, occupational health services do not have access to DMP, it is recalled.

However, the new draft decree maintains this authorization for school medicine services, “junior doctors” and “specially authorized personnel of support mechanisms for the coordination of complex health care pathways, specific regional systems, and support systems. ‘existing support’.

In addition, it provides for the entry into force of several measures relating to the ENS before its generalization, scheduled for January 1, 2022.

It allows its implementation from June 1, and the start of experiments in the departments of Loire-Atlantique, Haute-Garonne and Somme on this same date. These must begin on July 1, we note.

The provisions relating to the criteria allowing the listing of applications in the ENS catalog, provided for in article L1111-13-1 of the public health code, must come into force on September 1. These criteria must be specified by decree.

The National Health Insurance Fund (Cnam), which is responsible for the project management of the ENS, provides that the catalog will not be available until January 1, 2022.

A draft decree relating to the DMP, consulted by APMnews / TICsanté, provides some details on it.

It stipulates that the DMP “does not replace the record kept by each health establishment or each health professional, regardless of their mode of practice, as part of the care of a patient”.

In addition, “the holder is informed of the creation of his medical file and of its articulation with his ENS” and “can extract or add data to his DMP from his ENS”.

Finally, he specifies that the Cnam is responsible for the automatic creation of the DMP when the ENS opens.


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