Must electronic medical records connect to other systems in Indonesia?

Yes. Electronic medical record (RME) systems must possess compatibility and/or interoperability capabilities (Permenkes Number 24 of 2022 Article 10(1)). PP Number 28 of 2024 Article 780(d)-(e) requires healthcare facilities to ensure both system compatibility and standardized data exchange. RME stored by facilities must also connect to the Ministry of Health interoperability platform (Permenkes 24/2022 Article 21). Furthermore, Integrate with the National Health Information System (PP 28/2024 Article 781(1)).

Two Core Requirements: System Capability and Active Connection

First, the system must have interoperability capability, meaning different electronic systems can work together and exchange data using data exchange standards (Permenkes 24/2022 Article 10(3)). Interoperability refers to electronic system standards organized by the Ministry of Health (Article 10(4)). Systems must also follow data element variables and metadata—definition, format, and codification—set by the Ministry (Article 11).

Second, the system must actually connect to national platforms. Article 21 of Permenkes 24/2022 requires RME stored by healthcare facilities to connect with the Ministry of Health interoperability and data integration platform. PP 28/2024 Article 781(1) and Law Number 17 of 2023 Article 345(3) likewise require integration with the National Health Information System. For other external systems, the law requires technical interoperability capability rather than mandatory live connection.

Who Is Covered and Administrative Sanctions

This obligation applies to all healthcare facilities: independent practices, Puskesmas, clinics, hospitals, pharmacies, health laboratories, centers. In addition, Other facilities set by the Minister (Article 3(2)), including telemedicine providers (Article 4(1)). Article 45 set December 31, 2023 as the deadline to implement RME under this regulation.

Facilities may use systems built by the Ministry of Health, built in-house, or provided by an electronic system organizer through cooperation (Article 9(1)). The facility or system provider must register the system with the Ministry of Health. Submitting system documentation, features, data storage location, variables, and metadata (Article 12). Article 42 imposes administrative sanctions—written warnings and/or accreditation revocation—for violating Article 3, though no separate sanction is stated for Article 21. When technical barriers prevent RME use, non-electronic records may be used temporarily until resolved (PP 28/2024 Article 779(2)).

Patient Confidentiality Remains Protected

While facilities must grant full RME access to the Ministry of Health (Permenkes 24/2022 Article 28(1)), strict confidentiality applies to third parties (Article 32(1). PP 28/2024 Article 785). Disclosing medical records to third parties requires patient consent (Article 26(5)) and is limited to what is necessary (Article 33(3). PP 28/2024 Article 783(4)). Employers do not gain access to clinical records simply because a clinic system is interoperable. employers receive only fitness-to-work outcomes or aggregate de-identified summaries. Disclosure without consent applies only to statutory exceptions such as law enforcement or outbreak control (PP 28/2024 Article 783(11)).

Legal basis: Permenkes Number 24 of 2022 Articles 3, 4, 9-12, 21, 26, 28, 32, 33, 42, and 45. PP Number 28 of 2024 Articles 779, 780, 781, 783, and 785. Law Number 17 of 2023 Article 345.