A patient summary that crosses European borders needs two distinct things: a standard that says what the document contains, and an infrastructure that governs how it moves from one Member State to another. The International Patient Summary (IPS) answers the first question; MyHealth@EU answers the second. Keeping the two layers apart is the condition for reasoning well about conformance, terminologies, and the responsibilities of whoever builds a national gateway.
Context
The legal frame is Directive 2011/24/EU on cross-border healthcare, which set up the eHealth Network as the coordination body between Member States. On that basis the Commission funded the eHealth Digital Service Infrastructure (eHDSI), in operation since 2019 and later merged into MyHealth@EU. Two services are in production: the patient summary, and the ePrescription / eDispensation pair, where a prescription issued in the country of affiliation is recognised and dispensed in the country of stay.
The content standard exists for a precise use case, declared in the normative text: unplanned cross-border care. A clinician facing a patient from another country needs a reliable minimum core — active medications, allergies and intolerances, the problem list, immunisations, recent vital signs and lab results, implanted devices, a current pregnancy where relevant. IPS defines this core and little else, by choice: it is a summary, not a record.
Content standard
IPS is the result of joint work by CEN, ISO and HL7. The publication sequence is useful when you cite the standard in a specification:
- CEN EN 17269:2019 — Health informatics — The International Patient Summary, the original European standard;
- ISO 27269:2021 — a fast-track of the European standard into ISO, started in July 2020 and concluded in 2021;
- EN ISO 27269 — in February 2022 CEN/TC 251 unanimously adopted the ISO version as a European standard, the current reference since.
IPS is indifferent to the exchange format. Two HL7 implementations derive from the same content model and are maintained in parallel: the CDA IPS Implementation Guide (Clinical Document Architecture, Release 2) and the FHIR IPS Implementation Guide (Fast Healthcare Interoperability Resources, on an R4 base). The FHIR guide is published as STU1 — Standard for Trial Use, Release 1.
The FHIR model organises the document around a Composition resource with LOINC-coded sections, inside a Bundle of type document. The guide profiles the clinical resources that populate the sections — Patient, AllergyIntolerance, MedicationStatement, Condition, Immunization, Procedure, Observation, Device — and constrains the admissible terminologies: SNOMED CT for clinical concepts, LOINC for observations and section headers, ATC for active substances, UCUM for units. The FHIR IPS guide is meant from the start as a base from which to derive tighter national guides: a country can add local identifiers, national OIDs, its own value sets, without breaking compatibility with the international profile.
Transport architecture
MyHealth@EU is federated, not centralised. Each Member State builds and runs its own National Contact Point for eHealth (NCPeH): a gateway with two symmetric roles. Outward, it exposes its own patients’ clinical data to other countries; inward, it makes data coming from the other NCPeHs available to its own health system. There is no European archive of patient summaries: the document is produced on request by the NCPeH of the country of affiliation, querying the national infrastructure upstream, and returned to the NCPeH that asked for it.
Between two NCPeHs the exchange carries an assertion attesting the identity of the requesting professional, the country, and the legal basis of the request. The destination NCPeH queries its own national infrastructure, generates the conformant IPS document in the agreed format, and returns it. To build the gateway there is OpenNCP, a reference implementation of the NCPeH supported by the Commission and distributed under the EUPL: it includes the portal for the host-country professional, the orchestration of the request/response flows, integration with federated identity, and the audit modules. Several Member States built their own NCPeH on OpenNCP, adapting it to the national legal frame.
Adoption is uneven and must be checked country by country. At the start of 2023, eleven Member States were connected and live in at least one of the two base services — the Czech Republic, Estonia, Spain, Finland, France, Croatia, Luxembourg, Malta, the Netherlands, Poland, Portugal — with a second group, Italy among them, going live progressively over the year. Italy’s NCPeH is built by the Ministry of Health with technical support from Sogei; the national patient summary is drawn from the data in the regional Electronic Health Record.
Critical point
The fragile part of the exchange is not the transport, which is regulated and tested, but the semantic alignment between the national variants of the same standard. IPS constrains the admissible terminologies, yet each country populates the sections from its own source systems, with different codings and granularity. When the document crosses the border, two delicate operations remain: translating the narratives into the requesting clinician’s language, and matching national value sets to the international ones.
The textual translation of the narrative fields is done by the infrastructure, but the coding still has to be resolved: an active substance expressed with a national drug code has to be traced back to ATC so it is interpretable elsewhere; a diagnosis coded locally in ICD has to be reconciled with SNOMED CT where the guide requires it. Where the mapping is incomplete, the document arrives syntactically valid but with the clinical concepts degraded to free text — readable by a human, not processable by the receiving system. This is where the real quality of interoperability is measured, and where formal conformance to the profile alone does not guarantee continuity of care.
Implications
For implementers, the split between content and transport has practical consequences. Adopting IPS as the patient summary format does not tie your hands to MyHealth@EU: the same FHIR document serves to export data to patient apps and personal health records, for clinical portability in humanitarian settings, as a baseline clinical record in multicentre studies. The CEN/ISO/HL7 standard keeps the content interoperable outside the perimeter of the European network too.
On the European side, the proposed regulation on the European Health Data Space (EHDS), tabled by the Commission in May 2022, is in inter-institutional negotiation. If adopted, it should make MyHealth@EU the reference infrastructure for the primary use of health data, with stricter obligations on content and formats on Member States. In next-generation services FHIR already weighs more, with IPS as the core of the patient summary.
Limits
The above describes the state as of February 2024 and should be read as a dated snapshot: the list of active countries, the status of EHDS, and the coverage of individual services change over time and must be verified at source. The distinction holds regardless of the calendar: IPS is a content standard, MyHealth@EU an exchange infrastructure, and the open problems — value-set completeness, quality of the semantic mappings, actual per-country coverage — live in the space between the two layers.
- https://international-patient-summary.net/en-17269/
- https://www.iso.org/obp/ui/#iso:std:iso:27269:ed-1:v1:en
- https://hl7.org/fhir/uv/ips/STU1/
- https://www.hl7.org/implement/standards/product_brief.cfm?product_id=535
- https://health.ec.europa.eu/ehealth-digital-health-and-care/digital-health-and-care/electronic-cross-border-health-services_en
- https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32011L0024
- https://www.noze.it/en/insights/ips-myhealth-eu-crossborder/
Cover image: The Berlaymont building, headquarters of the European Commission in Brussels, with rows of blue European Union flags in front of its… — photo by Cbliu, CC BY-SA 4.0 — https://commons.wikimedia.org/wiki/File:Berlaymont_building_2024.jpg