Law, guideline and annexes: how it all fits together
The law itself contains no technical details. Section 390 SGB V instructs the National Association of Statutory Health Insurance Physicians and the National Association of Statutory Health Insurance Dentists to set out the requirements in a guideline, in agreement with the BSI and in consultation with other bodies. The guideline must be adapted to the state of the art and is therefore updated regularly. For medical and psychotherapy practices, the KBV guideline applies; for dental practices, that of the KZBV. Both follow the same basic idea but differ in structure and detail. The version issued by your national association is always authoritative.
The KBV guideline is divided into a main text and annexes. The annexes contain the actual requirements, graded by practice type: what applies to every practice, what is added in medium-sized practices and what large practices must additionally meet. Further annexes concern large medical equipment and the decentralised components of the telematics infrastructure. The requirements build on each other, so a large practice also meets all the requirements of the smaller types.
The most recently revised KBV version came into force on 1 April 2025, and the new requirements had to be implemented within six months. The revision focuses on raising awareness and training of the practice team, backup and the secure configuration of email. Sightadel maps the requirements to 49 controls and shows only those that apply to your practice profile. When a new version is published, the controls are adapted and your existing evidence is kept.
Which practice type are you?
Classification is the first and most important step, because it determines how many requirements apply. What matters is not the total number of employees, nor working hours, but the number of people permanently involved in processing patient data. This includes doctors as well as medical assistants at reception. Cleaning staff without access to systems do not count.
With up to five such people, the practice counts as a practice within the meaning of the guideline. With six to twenty people, it is a medium-sized practice. Above that, or if data is processed on a large scale, for example in large medical care centres or laboratories, it is a large practice. Independently of this, the annexes for large equipment and TI components are added if you operate them.
In Sightadel, you enter these details in the practice profile. This automatically determines which controls appear. If the size changes, for example due to new colleagues or a merger, you adjust the profile and the additional requirements become visible as open items. Record the reasoning behind your classification so that it can be traced later.
Costs and effort for the practice
There is no list price for § 390 SGB V in Sightadel. The price depends on practice type and scope and is quoted on request. IT service providers looking after several practices receive their own quote. You can try Sightadel free for 14 days without payment details; everything you set up carries over to the paid plan.
The bigger costs usually arise for technology and the service provider. Typical items are a suitable firewall, replacing legacy devices without manufacturer support, a backup with a copy outside the practice network, encryption of devices and storage media, and the IT service provider's working time for setup and documentation. These costs are invoiced to you directly by the respective providers. If you are looking for a hardware firewall, ask us about the right package.
The internal effort in the practice is manageable if it is planned: one responsible person who keeps an eye on the status, a stocktake together with the service provider, an instruction session for the team and regular reviews. What is usually underestimated is the time it takes to get evidence from the service provider. Separate access for the service provider in Sightadel shortens this path.
Liability, data protection and consequences of gaps
The guideline itself does not contain its own catalogue of fines, and the regional associations of statutory health insurance physicians do not carry out regular checks of practices. Concluding from this that the obligation is not binding would be a mistake. The guideline is binding for practices providing medical and dental care under statutory health insurance, and it specifies what counts as appropriate security.
This becomes relevant above all after an incident. If a practice's data is encrypted by ransomware or patient data falls into the wrong hands, the data protection supervisory authority examines whether appropriate technical and organisational measures under Art. 32 GDPR were in place. The guideline is an obvious benchmark for this. On top of that come possible reporting obligations under the GDPR, claims by patients, questions of medical confidentiality and, where applicable, consequences with insurers.
If, on the other hand, you can prove that the requirements were implemented, the backup was tested and the team was instructed, you are in a better position in each of these conversations. That is why clean, dated evidence pays off. Clarify the legal assessment of an individual case with your legal adviser or your professional chamber; Sightadel does not provide legal advice.
Working with the IT service provider
Most practices do not implement the guideline alone, but with an IT service provider or the vendor of their practice management system. That makes sense, but it does not shift the responsibility. The practice owner remains responsible. A clear division of tasks is therefore important: what does the service provider set up, what does it document, and what must the practice do itself, such as staff instruction, the emergency plan and access rules.
The KBV certifies IT service providers that support practices with implementation. A certified service provider knows the requirements. However, the certification relates to the service provider, not to your practice, and does not replace your own evidence. Ask which controls the service provider takes on and which evidence it will deliver to you.
In Sightadel, the service provider gets its own access. It enters the firewall rule set, patch levels, backup records and device inventory directly against the relevant controls. You can see at any time what has been done and what is missing. If a service provider looks after several practices, it works with the same structure everywhere. A data processing agreement with the service provider also belongs in the evidence.
Keeping the status: reviews in everyday practice
Many requirements are not one-off tasks. Updates must be installed continuously, backups tested regularly, new staff instructed and the accounts of departing staff blocked. If the technology changes, for example due to a new piece of large equipment, a new connector or a move, the network and documentation must be updated.
A fixed rhythm has proven its worth. Monthly, the service provider checks updates and backups; quarterly, a restore is spot-checked; annually, the team is instructed, the emergency plan updated and the overall status reviewed. For larger practices, an annual review is explicitly required.
In Sightadel, every piece of evidence has an expiry date. If it expires, Sightadel reminds the responsible person and the service provider before a gap arises. The evidence sheet with the current status can be generated, signed and filed at any time. When the guideline is updated, you see which controls have been added.
If you want to go beyond the mandatory level, for example a large medical care centre that could fall under NIS2, you build on the same evidence. In Sightadel, firewall, backup, emergency plan and staff instruction also count towards GDPR, NIS2 and ISO 27001, without being filed twice.