PHSSR Policy Roadmaps for Acting Early on NCDs Synthesis Report 2025
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93 Acting early on NCDs
The Partnership for Health System Sustainability and ResilienceFrance’s Health Data Hub controversy illustrates different governance challenges. The platform,
designed as a centralised resource for health data, has faced legal, political and technical difficulties
since its inception in 2019, including numerous legal challenges over data sovereignty when using
non-European cloud providers and long delays in researchers being granted access to the resource.
Digital therapeutics, devices and AI applications
Despite implementation challenges, several countries have pioneered innovative digital health
applications that demonstrate potential for transforming NCD care.
Germany was the first country to introduce statutory reimbursement for digital therapeutics through
its Digital Health Applications (DiGA) framework. DiGAs are class I–IIb medical products that must
comply with technical and accessibility standards and demonstrate clinical benefit. By 2024, 44
DiGAs were permanently listed, 15 were in the testing phase and 10 had been removed for
insufficient evidence (GKV-Spitzenverband, 2025a). Total spending reached around €110 million in
2024, covering 423,000 prescriptions, with prices of up to €2,077 for a 90-day period. DiGAs address
conditions ranging from diabetes to depression, and new developments allow data transmission to
the electronic patient record (ePA). Plans to link DiGAs with disease management programmes
(DMPs) may further strengthen their role in structured NCD care.
At the same time, concerns remain about their effectiveness and integration into the health system.
Although randomised controlled trials are often used as supporting evidence, they are not
mandatory, and existing evaluations reveal a risk of bias, with many studies small in scale and
limited in duration (Kolominsky-Rabas et al., 2022). Their design as standalone therapeutics may
reduce pressure on the workforce but leaves limited scope for integration into existing care
pathways or for tailoring to individual patient needs. Physicians also report uncertainty about when
and how to prescribe DiGAs and how best to monitor their use. Finally, the relatively high costs raise
questions about cost-effectiveness given the current evidence base (Kolominsky-Rabas et al., 2022).
Spain has developed multiple clinical AI applications including the ALMA project for haematological
disease diagnosis using machine learning algorithms, DxGPT in Madrid for rare disease
identification leveraging large language models trained on clinical literature, and Andalusia’s
automated medical record analysis system for early detection through pattern recognition. These
applications demonstrate AI’s potential to enhance diagnostic accuracy and efficiency, particularly
for complex or rare conditions where expertise is limited.
The digital divide
The populations most affected by NCDs, namely older adults with multiple chronic conditions, face
systematic barriers to digital health adoption that threaten to exclude them from potential benefits.
In Japan, 50.9% of citizens over 70 do not use smartphones or tablets, effectively excluding them
from mobile health applications and digital services (Cabinet Office Japan, 2023a). Similarly, the
report on Spain cites a study that found that 78% of chronic patients over 70 lack autonomy with
digital tools, requiring assistance for basic functions like accessing test results or booking
appointments (Plataforma de Organizaciones de Pacientes, 2023).
Digital exclusion is not simply about device ownership: many older adults own devices but lack
confidence or skills to use health applications. Interface designs that assume digital fluency, small
text requiring good vision, and complex navigation patterns create barriers that technical training
alone cannot overcome. A dependence on others for digital access undermines privacy and
autonomy, core principles of patient-centred care. Family members managing digital access for
elderly relatives may filter information or make decisions without full patient involvement.
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