Interoperability of teleconsultation platforms in Europe
What the platform should exchange around video: ANS repository v1.5.1, INS, CDA, DMP, MSSanté, FHIR Appointment/Encounter, and why WebRTC is not EHDS.
Ala Ben Aicha
Direct answer
Video is not file exchange. In France, the ANS v1.5.1 standard (decree of October 18, 2024) imposes INS, DMP, CDA, MSSanté and digital prescription. A WebRTC stream is not EEHRxF.
The Next.js stack is not the exchange contract
The English page telehealth with Next.js and Node.js described application architecture (WebRTC, Node services, FHIR server). This is the interoperability contract around the session: identity, report, order, messaging, appointment. Associated service: telehealth solutions.
In France, thedecree of October 18, 2024 makes the version 1.5.1 of the interoperability, security and ethics framework for teleconsultation IS. The ANS sums it up 13 sections : RGPD, ADM, ANN, INS, PSC, PGSSI-S, ETHT, FAC, ETH, DMP, CDA, MSS, ORD. Compliance with this standard (ANS certificate) is an approval prerequisite for certain teleconsultation companies — it's not an EHDS marking, it's not a CE MDR.
The HAS recommendations on premises and the environment (February 2024) concern the quality and security of access. I am not making this a clinical protocol.
Flow table: what comes out of the video booth
| Flow | Standard / requirement | Engineering proof | What it is not |
|---|---|---|---|
| Patient identity | INS + INSi teleservice; INS repository v2.1 | Slice FR Core Patient INS, urn:oid:1.2.250.1.213.1.4.8 |
A connection email, a home IPP |
| Professional identity | Pro Health Connect, Directory / RPPS | PSC and ANN sections | A Google Workspace account |
| Session | Appointment + Encounter (virtual class) |
FR Core Encounter / Appointment | A 2029 EHDS bond |
| Report | CDA + food DMP / My health space | DMP and CDA sections | A PDF pasted into WebRTC chat |
| Order | Digital order | ORD section | A prescription photo in the datachannel |
| Coordination Messaging | MSHealth | MSS section | A Gmail SMTP |
| Video/audio | Encrypted WebRTC, TURN | PGSSI-S, GDPR | EEHRxF, Patient Summary, category 1 2029 |
| Access traces | Logs, preservation | GDPR + PGSSI-S | A substitute NIS2 Art. 23 |
| Health data | GDPR Art. 9 | Basis Art. 6 + condition Art. 9 | “Cookie consent = legal basis for care” |
Encounter.class virtual: in FHIR R4, the v3-ActCode codesystem provides VR (virtual). It's not IMP (inpatient) and it is not an EEHRxF document. A Appointment.status=fulfilled does not power My health space on its own.
Video can — and often should — remain out of the exchange DPI. The file that the next doctor will see is the CDA / DMP / prescription, identified INS, not the SRTP flow.
Europe: MyHealth@EU is not your SFU
A cross-border teleconsultation is not, by magic, a flow MyHealth@EU. The Patient Summary EEHRxF (category 1, March 26, 2029) is a folder artifact, not a WebRTC session. Don't promise "EHDS-ready" because the codec is VP8 and the hosting is in the EU.
Outside France: the ANS repository v1.5.1 don't oblige a Belgian or Swiss publisher. In Switzerland, a report intended for the DEP follows CH EPR FHIR / MHD, with languageCode and EPR-SPID — another contract. In Belgium or Luxembourg, pinching the national framework before to copy the 13 ANS sections.
GDPR: health data = Art. 9. Hosting in the EU does not exhaust the legal basis. The people's rights (access, rectification, limitation) must be able to execute on the folder of teleconsultation, not just on the connection account.
MDR: video is not automatically a device
A communications platform that poster a session without interpreting a physiological signal often remains outside the qualification of the device — to be decided by the regulatory owner, see Software MDR. A module that calculates a clinical score during the session is a other module. Don’t mix the two in the same destination statement.
HDS (health data hosting) is a French hosting obligation for certain data, not a substitute for the teleconsultation reference system, not a CE MDR, not NIS2.
Illustrative Spike (not a quote)
| Week (illustrative) | Deliverable | Rollback |
|---|---|---|
| 1 | Mapping of the 13 sections: in / out / N/A for your product | Do not file an ANS file on a rehearsal |
| 2 | Identity: INSi + PSC in test tank | Local account only, no real NIR |
| 3–4 | A de-identified CR CDA + a digital test prescription | No production DMP power supply |
| 5 | Appointment / Encounter FR Core + access log |
Purging fixtures |
| 6–8 | “Video vs file” matrix signed product + legal | Prohibit the “EHDS / CE” claim on the brochure |
What this page is not
It is not an ANS certificate, not a Health Insurance approval, not a clinical HAS opinion, not an MDR qualification, not an EHDS Patient Summary, not legal advice. I do not declare your solution compliant with the v1.5.1 repository. Nothing here is a remote care protocol.
If you build the platform and its interfaces (identity, documents, messaging, video), it is telehealth solutions. For a bounded spike, use the contact with project intention.