Documenting WHP measures: Step-by-step with template

What do statutory health insurers and tax authorities require in documentation?

Anyone who wants to have WHP measures under § 20b SGB V (German law) subsidized by a statutory health insurance faces an often underestimated hurdle: proof of documentation. Health insurers not only check whether a measure has taken place — they check whether it complies with the prevention principles of the GKV guidelines. Specifically, this means: Before the measure, a need must be demonstrated (e.g., through an employee survey or sick leave analysis), the target group must be defined, and after the measure, success must be measured.

The requirements are even stricter if you want to take advantage of the tax exemption under § 3 No. 34 EStG (German law). The tax office expects that the measure is provided in addition to wages, can be assigned to a recognized prevention area, and that participation of each employee is documented individually — not just the total number of participants. The exemption of up to €600 per employee per year is an upper limit, not a budget — and it can only be substantiated with complete documentation. In the end, only your tax advisor can confirm this. The difference between health insurer subsidies and the tax exemption is explained in the guide Insurer funding and the tax allowance.

What are three typical documentation mistakes — and how can you avoid them?

**Mistake 1: Documenting retrospectively.** Many teams only create the documentation after the measure — or shortly before the funding application. GKV auditors notice this: If needs analysis and measure planning are dated after the implementation, the application is likely to be rejected. The solution is sequential documentation: planning before, proof of implementation during, evaluation after the measure.

**Mistake 2: Participant lists as Excel exports.** Tables without signatures or digital confirmation are often not considered sufficient proof in GKV audits. What counts is a traceable, tamper-proof record — ideally with a timestamp and confirmation by the participants themselves.

**Mistake 3: Goals formulated too vaguely.** “Promoting health” is not a measurable goal. Auditors expect SMART-formulated goals with concrete metrics: e.g., “Reduction of back complaints at office workplaces by at least 20%, measured via survey before and after the measure.” Without a measurable goal, there is no verifiable achievement — and thus no proof. A good addition is the Best Practice Formulate WHP goals SMART and track them automatically.

What does a measure workflow with template look like?

A practice-tested documentation flow follows five steps: First, you select the measure from a library with already classified prevention areas — this saves manual classification according to GKV guidelines. Then you define the goal and target group in writing before the measure starts. During or immediately after implementation, you record date, location, provider, and content. Participation is confirmed individually — not as a total, but per person. At the end, you compile a structured proof for the health insurer from this.

With EasyBGM, you record this process in one place: select the measure from the library, define the goal, and record the implementation with the “Health promotion measure documentation” template – date, implementation, number of participants, and content. Registrations for appointments are saved with timestamps. A certificate of participation per person, as required by the payroll account for tax exemption, does not replace this – it must also be included in the documents.