28 compulsory hours, €183 per trainer: the calculation that doesn’t add up
L’Éclaireur e-Santé #003
September 2024. The “Core Digital Competencies” reference framework becomes mandatory. 12 sectors concerned. 28 hours to be delivered.
Everyone’s talking about the 28-hour week. Nobody talks about the trainers who will teach them.
Here’s the problem the administration hasn’t budgeted for.
The blind spot: no one funds trainers
2024-2025 training budget for IFSIs in France: ~€450M (source DREES).
Typical distribution :
- 60%: trainers’ salaries
- 25%: equipment and premises
- 10%: continuing education for trainers (~45M€)
- 5%: miscellaneous
Now for the real question: how much of the 10% “continuing education for trainers” goes to digital health?
Response from 8 IFSIs: between 2% and 5%. That’s 900K€ to 2.25M€ to train ALL the trainers in France.
Let’s do the math:
- 327 IFSI in France
- ~15 permanent trainers per IFSI
- = 4,900 trainers to be trained
Available budget per trainer: €183 to €460.
What are you financing with this budget? A one-day training course (costs 800-1200€). Or 2-3 webinars. Or a MOOC. Not 28 hours of operational mastery in 5 complex areas.

Why it’s a systemic problem
The standard requires 5 areas:
- Health data (RGPD, INS, DMP) – 6 hours
- Cybersecurity in healthcare – 5 hours
- Professional digital communication – 5 hours
- Digital business tools – 6 hours
- Telehealth – 6 hours
Problem 1: The trainers didn’t have these skills.
An executive trainer graduating in 2018 has NEVER received training in :
- Cybersecurity applied to healthcare
- Patient data management (RGPD santé did not exist before 2018)
- Teleconsultation (post-COVID explosion)
These are not “updates”. These are new skills.
Problem 2: Digital health is evolving faster than training cycles.
The standard was published in November 2022. Between 2022 and today :
- ChatGPT launched (Nov 2022) → Generative AI explosion
- European AI Act adopted (Dec 2023) → New constraints
- Mon Espace Santé deployed (2023) → New uses
A trainer trained in January 2023 is already teaching partially obsolete content in October 2025.
Problem 3: No standardized teaching resources.
The reference manual says WHAT to teach. It doesn’t say HOW.
Example: “Teaching teleconsultation”.
A trainer must turn this into :
- Lectures (how many hours? which concepts?)
- Practical TD (which scenario? which tools?)
- Assessment (how to assess competence)
There are no shared resources. As a result, 327 IFSIs are each reinventing the wheel.
The legal risk no one mentions
The French Labor Code imposes a clear obligation on employers:
The employer must ensure that employees are adapted to their jobs and maintain their employability, particularly in light of technological developments.
This obligation applies directly to training managers.
Legal consequence:
If a trainer receives a reprimand for “inability to integrate new methods” and has never received any training, he or she can take legal action. The employer will have to prove that he has fulfilled his obligation.
Recent case law confirms this: failure to meet the obligation of technological adaptation leads to the award of damages.
No establishment is immune.
What works elsewhere: European models
Netherlands: Training BEFORE deployment
2019: Integration of digital health into nursing curricula. But BEFORE :
- 18 months of intensive training for trainers (budget: €12M)
- National platform for shared educational resources
- Mandatory certification for “digital health” trainers
Result: 2023 compliance rate: 94% of IFSIs apply the standard with validated quality.
European Union: The DigCompEdu framework
The EU has published the Digital Competence Framework for Educators:
- 6 areas of expertise
- 22 digital teaching skills
- 6 proficiency levels (A1 to C2)
This framework addresses the HOW of teaching with digital technology, not just the WHAT.
Three levers for decision-makers
LEVERAGE 1: Share teaching resources
Instead of 327 IFSIs each creating their own media:
→ Regional sharing platform (NHS Digital Learning model)
→ IFSI consortiums by region (5-10 establishments)
Investment: ~500 K€ per region
ROI: Saves 50,000 design hours
LEVIER 2: Certify trainers
Digital health trainer” certification:
→ 40 hours of initial training
→ 8 hours of annual updates
Investment: ~€2M national
ROI: Educational credibility + compliance + legal protection
LEVIER 3: Rotation of trainers in the field
Annual internship :
→ 2 weeks/year of digital health services
→ Maintaining practical skills
Investment: Cost of replacing trainers
ROI: Grounded in reality + continuous updating
The decisive moment: now
The digital health repository is a major step forward.
Its success depends on an invisible element: investment in trainers.
The figures are clear:
- 0.1% of professionals trained in digital health by 2022
- 183€ to 460€ budget per trainer
- 4,900 trainers to be trained by 2026
Otherwise, we’d be repeating the classic French pattern: excellent regulatory intentions, little impact on the ground.
The difference between the DMP (2005 failure) and this repository (2024)?
It’s happening now. In 2025 budgets. In corporate priorities.
To find out more
- CNIL – RGPD and health data
- DigCompEdu – European framework for digital teaching skills
- IFSI digital skills reference framework – DREES
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About the author
Nicolas Schneider is a strategic advisor in digital healthcare transformation and founder of JuliaShift. With 17 years’ experience at the French Army Health Service and 8 years in digital transformation consulting, he assists MedTech startups and healthcare establishments in their financing strategy, structuring pharma partnerships and preparing for fund-raising.
Specialties: healthcare innovation financing, MedTech fund-raising structuring, pharma industrial partnerships, IA regulatory compliance.