Article 3 clause 4 describes that national contact points should map codes and can use a central terminology server to help with that. This seems to contradict the purpose of the regulation requiring EHRs to contain an interoperability component to allow for data exchange in a standardized format.
CBV
ChipSoft B.V.
Company · Netherlands
2
positions filed
in the 326 files tracked
2
legislative files
of 326 tracked
0
with a full position paper
attached to a submission
Counts here are a floor, never a total: they cover the 326 consultation files tracked so far (29,503 submissions, mostly 2025–26), so an organization's real filing history is larger, not smaller.
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Their record over time
ChipSoft B.V. filed 2 positions on 4 May 2026, across 2 of the 326 legislative files tracked here.
What they argued
The draft implementing act specifies that the identification data used in the Member State a request is sent to, are to be provided for cross-border requests (recital 2, articles 3 and 4). However, no means seem to be provided for EHR's to provide this data to an NCPeH or to even request information from an NCPeH about what identification data is needed for a request to a specific Member State.
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Turns up on the same files
Organizations that also filed on at least two of the same consultations. A shared interest in the same dossiers — not evidence of coordination, and we do not suggest any.
- IDEE ECONOMICHE www.idee-economiche.it · 2 files in common
- The Guild of European Research-Intensive Universities · 2 files in common
- SOMA Genomics · 2 files in common
- Austrian Federation of Social Insurances · 2 files in common
- Cancer Patients Europe (CPE) · 2 files in common
Showing 5 of 17.
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