EDM - electronic medical documentation in physiotherapy
Mr. Tomasz has run a physiotherapy practice in Poznan for seven years. Until now, patient records lived in binders and the treatment log was a notebook.
Mr. Tomasz has run a physiotherapy practice in Poznan for seven years. Until now, patient records lived in binders and the treatment log was a notebook. In January 2026 he got an email from the National Health Fund (NFZ) with the phrase "EDM obligation" in it, and things suddenly got tense. Are his paper records still legal? Does he have to retype everything into a system? Is he facing fines?
In this article we explain what electronic medical documentation (EDM) is, who it applies to, how it connects to the P1 platform, and how to implement it in a physiotherapy practice without panic or wasted money.
What EDM is and where it came from
EDM (electronic medical documentation) is medical documentation kept in electronic form according to a defined technical standard (HL7 CDA) -- not just a Word file or a scan of a paper record. The legal basis is the Act of 28 April 2011 on the healthcare information system, along with implementing regulations from the Minister of Health.
There's a key distinction that trips up most physiotherapists:
- Electronic documentation (broad sense) -- any document kept digitally (e.g., a patient record in practice-management software).
- EDM (narrow, statutory sense) -- specific document types listed in the regulation that must follow a standardized format and are exchanged through the P1 platform.
EDM in the statutory sense currently includes items such as information for the referring physician (consultation results), and the catalog is gradually being expanded to cover more provider-generated documents.
The P1 platform -- the heart of the system
P1 (the Electronic Platform for Collecting, Analyzing and Sharing Digital Resources on Medical Events) is the central system operated by the Centre for e-Health (Centrum e-Zdrowia). It's where e-prescriptions, e-referrals, and the EDM index all end up.
Important: P1 does not store the actual content of your documentation. What you report to P1 is:
- The medical event -- the fact that a service was provided (who, to whom, when, what type).
- The EDM index -- information that a given document was created and where it's physically stored.
The actual content stays in your own repository (your practice-management system or a cloud provider). When another entity needs to see it, they retrieve it through P1 -- but only with the patient's consent.
| Element | Where it's stored | Who reports it |
|---|---|---|
| Documentation content | Your system / repository | You (the healthcare provider) |
| EDM index | P1 platform | You (automatically, from your system) |
| Medical event | P1 platform | You (automatically, from your system) |
| E-referral / e-prescription | P1 platform | The referring physician |
Who the EDM obligation applies to in physiotherapy
The obligation to report medical events and exchange EDM applies to all entities carrying out medical activity -- which includes physiotherapist practices registered in the Register of Healthcare Entities (RPWDL). It doesn't matter whether you have a contract with the National Health Fund (NFZ) or work purely on a private-pay basis.
In practice, this means that:
- Solo practices, group practices, and medical entities alike -- everyone must be able to report to P1.
- You need an account in the P1 system and communication certificates (obtained through RPWDL / P2SA).
- You must keep documentation in a system capable of generating documents in the HL7 CDA format and sending the index to P1.
Physiotherapists working purely on a commercial basis often assume "P1 is an NFZ thing." That's a mistake -- the obligation stems from your status as a medical entity, not from how you're financed.
What your system needs to do to meet the requirements
Not every "practice management" program meets EDM requirements. Before buying a license, check whether the software:
- Generates documents in the HL7 CDA standard (not just PDF).
- Signs documents electronically -- with a qualified signature, a trusted signature (ePUAP, the trusted profile / trusted signature system), or a ZUS (Social Insurance Institution) certificate/e-ID.
- Automatically reports medical events to P1.
- Sends the EDM index and supports retrieving documentation on request.
- Provides backup and encryption of patient data (a GDPR requirement).
If you still keep paper documentation, that alone isn't a violation regarding the patient record itself, but it does not exempt you from the obligation to report medical events to P1. Sooner or later, an electronic system becomes a necessity.
How to implement EDM in your practice -- step by step
- Register in RPWDL and P1. Make sure your practice's registration is up to date -- it's the source of the data used to issue certificates.
- Obtain communication certificates (TLS and WSS) through the P2SA / RPWDL system.
- Choose practice-management software with full EDM and P1 support (ask the vendor directly: "do you report medical events and the EDM index to P1?").
- Electronic signature -- the cheapest option is a trusted signature (free of charge); a qualified signature or ZUS certificate is more convenient if you're more comfortable not logging into a government portal each time.
- Data migration -- you don't need to retype old paper records; start new patients electronically and archive the old records according to the retention periods.
- Test the reporting -- carry out a few trial services and check that the events reach P1.
- GDPR procedure -- update your record of processing activities and information clauses to cover data exchange through P1.
[SP] Example -- Solo Practice: Mr. Tomasz doesn't need to retype 800 paper records. Starting in February, he registers new patients exclusively in the electronic system, buys a cheap trusted signature, and picks software that reports to P1. The paper archive stays in a locked cabinet until the retention period ends.
[GR] Example -- Group Practice: Four physiotherapists work at this practice. Each one needs their own electronic signature, but there's a single shared practice-management system. Medical events are reported under the entity's tax ID (NIP), while document authorship identifies the specific therapist.
The most common mistakes when implementing EDM
- Treating a paper scan as EDM -- a scan is not a standardized document and doesn't meet the requirement.
- No electronic signature -- a document without a signature isn't legally binding.
- Buying a system with no P1 support -- an "appointment scheduling" app is not the same thing as an EDM system.
- Ignoring GDPR -- electronic documentation increases the risk of a data leak; missing encryption and backup is a violation.
- Delaying -- penalties for failing to report medical events increase as NFZ and regional inspections expand.
Frequently asked questions
As a physiotherapist working purely on a private-pay basis, do I have to report to P1?
Yes. The obligation stems from your status as an entity carrying out medical activity (registered in RPWDL), not from having a contract with the National Health Fund (NFZ). Even a fully private practice must report medical events and exchange EDM through the P1 platform.
Do I have to digitize all my old paper records?
No. The EDM obligation applies to documentation created after implementation. You keep old paper records according to the retention periods (generally 20 years), but you don't have to retype them into the electronic system.
Which electronic signature is the cheapest?
The trusted signature (the ePUAP trusted profile) is free and sufficient for signing medical documentation. A qualified signature and a ZUS (Social Insurance Institution) certificate cost money, but are more convenient when handling a large volume of documents, since they don't require logging into the government portal every time.
What are the penalties for not implementing EDM?
Failing to report medical events and exchange EDM can result in contractual penalties (under an NFZ contract), and is also treated as a breach of a medical entity's obligations -- something that surfaces during an NFZ inspection or a Chamber of Physiotherapists (KIF) site visit.
CTA: Want to implement EDM-compliant documentation without the chaos? The STANDARD package includes ready-made medical documentation templates, an EDM implementation checklist, and GDPR procedures tailored to a physiotherapy practice. See FizjoReady packages →
Related articles:
- Medical documentation in physiotherapy -- what documents are mandatory?
- GDPR in a physiotherapy practice -- a practical guide for physiotherapists
- KIF inspection of your practice -- what to expect and how to prepare