Sanctions for failure to connect to the Central e-Registration System. "This could be the key to success."

The guest of the twelfth episode of the Health Market podcast "Stechtoskop" was Marcin Romanowski , President of the Management Board of Comarch Healthcare, Director of the e-Health Sector of Comarch SA and Vice President of the Cracovia Sports Club.

We spoke with him about an idea that emerged during public consultations on the Central e-Registration regulations. The Health Market revealed that the National Health Fund (NFZ) would be able to suspend or limit funding for some services provided under a contract with the National Health Fund (NFZ) for ignoring the requirement to integrate with the electronic appointment scheduling system.

This applies to facilities that, under a contract with the National Health Fund, schedule patients for cytological and mammographic screenings, as well as cardiology appointments. According to the draft regulations currently under review , the sanction is to take effect in mid-2026.

"This could be the key to success. Sometimes it has to be this way. Because we know full well what the current situation with medical event reporting looks like. It's been mandatory since July 2021. And what happens if reporting isn't done? Nothing," said Marcin Romanowski.

As a side note, it is worth noting that the National Health Fund will also be able to use the stick-like regulation for the lack of integration with the CeR when facilities fail to report the above-mentioned medical events - we also revealed this in Rynek Zdrowia.

Marcin Romanowski added that the regulator must decide how it wants to motivate facilities to participate in the Central e-Registration or to report medical events.

There are two options: the stick (sanctions) or the carrot (incentives).

Why are institutions reluctant to implement Central e-Registration? There are at least several reasons.

First of all, facilities are in no hurry to provide full access to their schedules. This will clearly show whether they are properly fulfilling their contracts with the National Health Fund. Sometimes, doctors are formally employed full-time, but in practice, they only appear at the facility for a shorter period because they also work for other entities, such as private ones.

Delays related to patient admissions will also be visible on a silver platter. Implementing CeR also requires organizational changes and the costs of adapting office systems to the new system.

Marcin Romanowski also spoke with us about his experiences with the ongoing Central e-Registration pilot ( extended until the end of 2025 ). He said that technical challenges are already emerging due to the fact that patients can make appointments in various ways: electronically, by phone, or in person at the facility. This creates performance issues for IT systems and potential errors in blocking appointments.

Patients also seem a bit lost. Some show up for appointments they haven't confirmed (after the "CeR waiting room" assigned them an appointment after someone else had released them). As a result, they are then sent home by the facility.

The Central e-Registration pilot program has been underway since August 26, 2024. To encourage institutions to participate, subsidies are currently being provided to entities implementing the pilot program to cover the costs of integration with the system. Lump sums range from PLN 10,000 to PLN 200,000 .

In mid-June, the e-Health Center reported that 277 healthcare providers had signed up for the pilot program. Services are being provided in over 300 locations , and over 400,000 patients have used the system. Thanks to CeR, 10,000 appointments were canceled—available appointments have been returned to the system. This demonstrates the tool's potential in combating patient cancellations (by introducing a convenient way to cancel appointments).

The entire interview with Marcin Romanowski can be viewed at Rynek Zdrowia.

All episodes of the "Stechtoskop" podcast are available for listening on Spotify.

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