National Health Service

This article compares the digitalization process of healthcare in Italy and Germany focusing on two main tools: the electronic health record and the mHealth regulation. Despite structural differences, the two countries present similar levels of digitization and, whereas Germany has recently introduced cutting-edge legislation on digital care, Italy has a more advanced level of EHR implementation. The analysis therefore focuses on the issues that have emerged in the two jurisdictions and the complementarity of the solutions adopted.

The paper analyses the relationship between public and private actors in the context of the Italian National Health Service. This relationship not only characterizes and conditions the structure and organisation of the NHS, but also affects the right to health of citizens-users.