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 PUBLIC HEALTH MATTERS 

Comparing Health Systems in Four Countries:


Lessons for the United States
| Lawrence D. Brown

an excuse for—declining to pursue it. The


The Rekindling Reform initiative examined the health systems of 4 countries: Can-
brightest and best strategies to build a nor-
ada, France, Germany, and Great Britain (United Kingdom). From the 4 country reports
published in this issue of the American Journal of Public Health, 10 crosscutting themes mative case for universal coverage have
emerge: (1) coverage, (2) funding, (3) costs, (4) providers, (5) integration, (6) markets, failed so far, and no one seems to know how
(7) analysis, (8) supply, (9) satisfaction, and (10) leadership. Lessons for the United to change these values, which are, by defini-
States are presented under each point. (Am J Public Health. 2003;93:52–56) tion, fairly durable.

FUNDING
The 4 articles in this issue of the Journal that and publicity, so far they proceed mainly at
explore universal-coverage health care sys- the margins of comprehensive systems that In all 4 systems the national government
tems in (1) Canada, (2) France, (3) Germany, show little inclination to cut back covered ser- sets a statutory framework for financing uni-
and (4) Great Britain (United Kingdom) are a vices. The core values of these systems—soli- versal coverage. (In Canada the provinces
sophisticated package of generalization, varia- darity, community, equity, dignity—remain in- must meet centrally defined conditions for
tion, and implication that defies easy synthe- tact and surprisingly little disturbed by rising participation in central/provincial fund-shar-
sis and summation. Nonetheless, this rich costs and by gloomy forecasts that aging, ing arrangements.) How they raise these
cross-national variation yields 10 general technology, and the rest are rendering their monies differs substantially, however: Great
themes. systems unaffordable. Britain’s National Health Service draws
The moral and cultural foundations of uni- mainly on general revenues; 70% of Can-
COVERAGE versal coverage are missing in the United ada’s health bill comes from national and
States, as the continuing presence of 40 mil- provincial general revenues; Germany relies
All 4 nations entitle almost all their citizens lion uninsured would seem to intimate. Cir- primarily on work-based social insurance con-
to health coverage. Health care is not enough; cumstances are not propitious: 85% of the tributions; and—the most dramatic evolution-
their images of solidarity, community, and eq- population has medical coverage, much of it ary development in this quartet—France in-
uity insist that how care is obtained, not funded by private employers; the 15% who creasingly supports its social insurance regime
merely that it be somehow obtainable, mat- lack insurance are not organized, cohesive, or with general revenues that tap a broad range
ters greatly. Respect for human dignity de- politically active; sizable redistributive shifts of wealth. None of these approaches is plainly
mands that no one refrain from seeking med- by national design are not the political sys- superior to the others; they all “work,” and
ical care from fear of the consequences of tem’s strongest suit; and the right-of-center they all carry their burden of political and
doing so, and that no one suffer financial ad- precincts in which that system has lingered economic stress. France and Germany also
versity as a result of having sought care. The for the past 35 years do nothing to ease the have various degrees and types of cost shar-
moral foundations of universal coverage are struggle. Equally important, Americans ing by patients.
as simple as that. “know” that safety net providers care for peo- The good news for the United States is that
Although these nations all cover medically ple who lack coverage—a powerful inhibition in essence any major funding approach will
necessary and appropriate services, they also to public action in a nation whose welfare serve. The bad news is that no such approach
debate the limits of publicly defined coverage. state programs aim less at broad-ranging se- seems close to commanding consensus, and
In Canada, for example, home health care curity in health and other policy spheres than feuding over the merits of funding strategies
and drugs lie outside the public system. In at post factum compensation for those who aggravates the chronic righteous strife among
France, dental and eye care tend to be cov- fall through private-sector cracks. Reformist proponents of reform that (given the imposing
ered by supplementary insurance. As medical appeals based on human dignity (to which strength of the opposition) has heavily dam-
innovation advances, discussion intensifies health security is fundamental) resonate very aged reform prospects. One contingent con-
about how to define baskets of benefits that little here. September 11 and rescued miners tends that a “single payer” (general revenue—
distinguish the responsibilities of the national aside, solidarity finds little place in the na- based) system is best. Another believes that
community from those that individuals and tional political lexicon. Likewise, in the the success of Social Security and Medicare
families ought to bear personally. Although United States, community is not a spur to na- validates a social insurance strategy. Whereas
these deliberations steadily gain prominence tional action but rather an alternative to—and no other nation believes that universal cover-

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 PUBLIC HEALTH MATTERS 

age can be won and sustained without candid highly technical services than the United This strategic tabula rasa may leave the
debate about taxes, a prominent American re- States does, and all expect that structured ne- United States uncommonly receptive to learn-
form camp wants to build on the private em- gotiations between payers and providers will ing from abroad. On the other hand, public
ployer contributions that buy most US health hold the line on costs. budgets and caps, which continue to connote
insurance today. (Indeed the Clinton adminis- These staples of cost containment seem in- rationing and remain abhorrent to influential
tration’s reform plan of 1993 would have creasingly insufficient to counter the funda- stakeholders, do not seem to be gaining a
mandated such employer “premiums” pre- mental challenges all nations face—growing constituency. Adopting them would entail
cisely in order to avoid uttering the dreaded and aging populations, technological progress, elimination of some politically potent sources
“t word.”) Meanwhile, the widespread convic- inflation, wage pressures, and rising popular of waste that market forces tolerate or aggra-
tion that done right, universal coverage expectations1—and so in their sundry fash- vate, namely (to borrow from Deber’s list):
should require no new monies (tax-derived or ions, the 4 countries try to cap health spend- marketing costs, efforts at selective enroll-
other) beclouds the US reform debate. The ing. In Great Britain and Canada, the public ment, stockholders’ profits, executives’ exorbi-
system is said to be replete with waste that health care budget is itself a ceiling. In tant salaries, lobbying expenses, and less
can be intelligently squeezed to yield abun- France, since 1996 Parliament has legislated widely diffused technology. And if such waste
dant funds to rechannel resources from exces- a national spending target annually. Germany were gone, the fundamental things—growing
sive use and payments to providers and to- has tried to link health spending increases to and aging populations and such—would apply
ward coverage for the uninsured. (This too the growth of workers’ wages. Only in Great here, as in other nations, as time goes by.
was a premise of the Clinton plan.) Britain have these public constraints gener-
This pastiche of theory and ideology lays ated highly controversial waiting lists, and PROVIDERS
down myriad stumbling blocks that reform- these, says Light,2 are mainly limited to elec-
ers must somehow surmount. A workable tive referrals to specialists. Waiting lists occa- Conflict between policymakers (in both
coalition probably presupposes avoiding sionally appear in Canada, but Deber1 argues health and financial ministries) and providers
fierce redistributive battles over how and that these vary with place and procedure and over terms and levels of payment is a persis-
where to squeeze and redirect wasteful are a minor, albeit well-publicized, concern. tent fact of political life in all 4 nations.
spending within the status quo, dismissal of “Rationing” is a nonissue in France and Ger- Within public budgets and fiscal caps, provid-
employer mandates (and the battles with many. Containing costs is never easy, but the ers negotiate with the state, the sickness
business they trigger), the political courage to 4 nations have done it—indeed, in the British funds (health insurance institutions), or both.
discuss tax increases that (probably) mingle case perhaps too well. In Great Britain and Canada, physicians’ or-
social insurance payments with general rev- Rising health costs are of course a huge ganizations and individual hospitals bargain
enues, and, not least important, willingness headache in the United States, and the likeli- directly with government agencies. In Ger-
among ardent advocates of diverse financing hood that universal coverage would push many, associations of sickness-fund physi-
strategies to rally behind whatever seems to them higher and faster is a weighty political cians and individual hospitals negotiate with
stand some chance of passing. Meanwhile, burden on reform. Unlike the 4 nations, the sickness funds within a framework of public
cost controls can be taken up after the uni- United States has rejected all talk of publicly rules. In France, unions of physicians bargain
versal deed is done—a prospect that will of set limits on health spending. Insurers, provid- separately with the sickness funds as the
course be plain to stakeholders who oppose ers, business interests, and other opponents of state moves back and forth between the side-
reform and will take up their political cudgels reform loudly equate all such aggregate con- lines and the battlefield. In each of the 4,
accordingly. straints with “rationing,” and the equation has payers squeeze, providers protest (and some-
dependably terrified public opinion. In 1993, times strike), payers relent, costs increase,
COSTS Bill Clinton proposed to harmonize cost con- payers squeeze, and so it goes. Although
trol with universal coverage by means of budgetmakers invariably spend more than
Although the 4 nations spend a smaller managed competition among health plans, they prefer, providers in all 4 nations earn
share of their national resources on health backstopped by caps on health insurance pre- considerably less than their more specialized
care than the United States does, cost contain- miums, should market forces fail to hold them US counterparts.
ment has long been a preoccupation in each down. The Clinton plan was rejected, leaving The US medical profession is more lucra-
and all. (Great Britain is arguably a case cost containment to unmanaged competition tive and entrepreneurial than is the case else-
apart. There, reorganization and better man- among health plans, which (to many reform- where. To American providers, collective ne-
agement of the National Health Service ers’ surprise) proceeded to “work” in the sec- gotiations with public payers, which imply
have—until recently—been successfully of- ond half of the 1990s as cost increases more than tacit consent to a state-run social
fered as alternatives to the infusions of cash slowed dramatically. Health spending moved enterprise called (or headed toward) national
the Blair government was eventually moved rapidly upward thereafter, however, leaving health insurance, have long been anathema.
to promise.) The 4 nations pay their physi- purchasers and policymakers wondering what The United States has coped politically by
cians less and provide fewer specialized and to do for an encore. evolving a bifurcated pattern of payer and

January 2003, Vol 93, No. 1 | American Journal of Public Health Brown | Peer Reviewed | Public Health Matters | 53
 PUBLIC HEALTH MATTERS 

provider relations. The main public program, of choice, for example, were fundholding MARKETS
Medicare, shifted from a payment system that among general practitioners and hospital
mimicked the private sector (retrospective trusts, now giving way to primary care trusts. American reformers who admire the rest of
payment of actual hospital costs and usual Indeed, writes Light,2 the government now the West for its refusal to treat health care as
and customary physician charges) to prospec- plans to “unite specialty care with primary a commodity to be bought and sold in the
tive payment models, steered by commissions care, unite primary care with community marketplace tend to view the growing foreign
in which providers have a voice, and by Con- health care, and unite all three with social fascination with market forces in health care
gress, which they lobby directly. In the private services,” yielding “comprehensive, integrated as a trip down the garden path. This fascina-
sector, purchasers have hoped to discipline services that are community based.” The tion is unmistakable in all 4 nations, however,
providers by shopping among and signing on French are experimenting with “networks of as evidenced by Great Britain’s internal mar-
with managed care plans that presumably coordinated care,” notes Rodwin.3 These kets, Germany’s regulated competition,
contract selectively with “efficient” providers countries view reorganization (or redisorgani- France’s networks, and Canada’s Community
and apply organizational reviews and con- zation, in health economist Alan Maynard’s Care Access Centres. All the same, foreign at-
straints that enforce efficiencies. term) soberly, as “reforms” worth testing as tachment to health care markets tends to be
The future of these disparate arrangements possible sources of better value for money clear-eyed and decidedly nonevangelical, is
is a key question for health reform. Would a within fundamentally sound systems. far from taking national health insurance sys-
public system of prospective payment prevail, The United States, the esteemed source of tems by storm, and may already be waning
and could it coexist with the current private much of the theory and practice of the ser- (judging by Light’s account2 of Great Britain,
managed care model? Must reform mean the vices integration other nations seek to emu- the most market-friendly of the 4). Other na-
end of unmanaged competition among health late, may be ahead of the international curve tions recognize that competition is difficult, at
plans and a belated biting of the bullet on but faces integrative challenges of its own. least in a real world populated by real institu-
managed competition, and if so, what version Both here and abroad, proponents of reform tions. Besides breaking important political
of it? As with financing, there appears to be sometimes divide over whether the achieve- compacts (for example, that any national
no one right way, but workable reform will ment of universal coverage is a necessary and health insurance physician may treat any na-
have to hold the line on provider payments, sufficient policy objective, over whether to in- tional health insurance patient, a settled norm
and doing so will mean constructing new bar- sist that such coverage be encased in a prop- that pretty much precludes closed panel plans
gaining machinery with which providers agree erly designed delivery system. Americans and selective contracting by payers), competi-
to “live,” however grudgingly. Today, US pro- must decide how far to tie reform to managed tion requires heroic analytic feats, which
viders are more inclined to wish a plague on care, the driver of US-style integration, and carry no small price tag: better management
the payment practices of both Medicare and increasingly an 800-lb gorilla politically. Will information systems, copious consumer infor-
managed care than they are to think construc- the new system seek to redeem a fee-for- mation, subtle measures of quality, methods
tively about better ways to negotiate collec- service system, follow Medicare’s dubious to adjust payments by risk of enrollees, and
tively with payers. Most American physicians lead into some variant of choice between a more. None of these countries views competi-
and hospitals continue to view health insur- fee-for-service system and managed care, or tion as a panacea, and none fantasizes that
ance as an economic, not a social, enterprise assume that managed care will be main- market forces can supplant the solid regula-
and organize and strategize accordingly. stream and fee-for-service payment an excep- tory machinery now in place. All 4 worry that
tion? Beyond decisions about how far to push even well-designed competition could under-
INTEGRATION managed care lie others on what to do about cut solidarity, community, and equity, and
managed competition, an issue that has vexed each wonders candidly whether the market
These 4 nations all voice dissatisfaction US health policy since the 1970s. Is integra- game is worth the social candle.
with the organization of their delivery sys- tion—in this case the proliferation of managed Although the United States has embraced
tems; they all deplore “fragmentation” and care organizations—a natural institutional re- markets and competition as health care “solu-
aspire to “integration.” International literature ceipt for better efficiency and quality? Or do tions” with a passion puzzling abroad, it hesi-
and their own observations teach that over- these objectives presuppose competition tates too. For years, 1 school of market re-
use of services is substantial and that, to coin among integrated entities? Can this competi- formers has predicted that competition
a phrase, care ought to be better managed. tion stay loosely managed, as now, or would among managed care plans per se will make
Having long allowed physicians and hospitals universal coverage trigger anew the many dis- the system more efficient, whereas another
to practice medicine largely as they pleased— putes about managed competition that sunk has contended that such competition must be
a norm crucial to the quid pro quo in which the Clinton plan a few years ago? Ironically, managed (by and within a sophisticated and
providers accepted regulation of their pay- other nations are better equipped to address extensive framework of public rules) lest it
ments—these countries now seek efficiencies integration incrementally than the United lapse into such market failures as selection of
in production that supposedly accompany or- States is: here it invites a host of radical preferred risks, underservice, and geographic
ganizational innovation. Great Britain’s tools questions. segmentation of markets, all of which would

54 | Public Health Matters | Peer Reviewed | Brown American Journal of Public Health | January 2003, Vol 93, No. 1
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damage the public interest. The slow growth build, so too will the impulse to find diag- will so obviously overmatch the disciplinary
of health costs in a strong economy in the lat- noses and recommendations in neutral ex- powers of market forces that US policymakers
ter 1990s cushioned the horns of the pertise and objective evidence. Analytic find- will rethink their options on this controversial
dilemma. Today costs rise faster, the economy ings and advice will throw down the gauntlet count.
grows more slowly, and the prospect of incor- to providers, who will respond both by seek-
porating 40 million uninsured into a new re- ing to shoot the messenger and by redoubling SATISFACTION
formed system brings competitive disputes to their efforts to document, define, and perhaps
center stage again. Would a new round of re- even reconsider their practice patterns. Policy- In all 4 nations, citizens record high
form put managed competition over the polit- makers will reply that the providers offer too (though not unreserved or uncritical) satisfac-
ical goal line at last? Dare reformers view re- little, too late, and the deployment of analytic tion with their health care systems. No one
form as the great escape from an imprisoning weapons in the unending political conflicts views national health insurance as a big mis-
competitive mindset? Must they accept it as will escalate. take and wants to start over. The vices of the
part of the strategic furniture they must per- US system—40 million uninsured people, an
force rearrange? Having gone to market so SUPPLY additional (and sizable) number with inade-
often, the United States may no longer be ca- quate coverage, wide disparities in access and
pable of a swift, clean U-turn, but if we can- The 4 nations all use public authority and quality—are thought to overwhelm such mod-
not live without competition, how will reform- planning to control the number and distribu- est and distinctive virtues as more extensive
ers live with it? tion of hospitals and physicians. Contrary to integration of services and more advanced
conventional wisdom, such constraints do not analytic capacity. The foreign systems’ costs
ANALYSIS necessarily make the system “smaller” or are routinely and rhetorically said to be in
harder to access. Rodwin’s Table 2,3 for ex- “crisis.” The systems themselves are not.
The 4 countries show a strong and grow- ample, shows that on most measures of re- American public opinion voices no small
ing curiosity about how analytic tools—evi- sources and utilization—for instance, active dissatisfaction with the US system and consid-
dence-based medicine, technology assessment, physicians per thousand population; total in- erable support for major, even fundamental,
report cards, and cost-effectiveness analysis, patient hospital beds, physician visits, and changes in it. The rub, however, is that this
for example—can help policymakers to assess hospital days per capita; admission rates to grousing does not yield a clear mandate for
the performance of their health systems and and lengths of stay in hospitals—France sur- anything very different from the status quo.
suggest means to improve them. New agen- passes the United States. These limits do Despite years of intense opinion polling, poli-
cies such as the National Institute for Clinical make the systems less specialist driven and cymakers remain unsure precisely what peo-
Excellence in Great Britain and the ANAES technology intensive, however, which seems ple are upset about (beyond the impossibility
(Agence nationale d’accréditation et d’evalua- to be how they register savings for the na- of enjoying ready access to fine care at mini-
tion) in France promote and conduct such tions in question. mal cost) and what they think would work
evaluative studies. Although foreign policy- Notwithstanding such programs as certifi- better. Nor is this so odd after all: the same
makers have suitably modest expectations for cates of need, the United States relies mainly political leaders who quietly pushed arcane
these tools, their influence might advance by on a combination of market forces and pro- payment reforms in public programs have
several different routes—for example, im- fessional preferences to decide what levels of generally declined to launch searching public
proved performance as measured by analytic supply are adequate. The market itself must discussions of the big and touchy redistribu-
criteria could become a condition for in- challenge the hoary conviction that “health is tive and regulatory issues and tradeoffs on
creased pay to providers, and continued docu- a community affair,” meaning in practice a which health reform turns. Bill Clinton’s un-
mentation of overuse of services within these highly entrepreneurial affair in which local availing and politically painful effort to break
systems might fuel budget makers’ determina- providers behave as if more is better, often the pattern reaffirmed it instead. A perplexed
tion to manage care—that is, providers—more with the acquiescence of boosterish local public has therefore come to view health care
assertively. business leaders. Hospitals and physicians reform as something like shopping for shoes:
In the United States, the birthplace of many want bigger and better facilities, the latest and “We think we are in the mood to buy a health
of these tools, expectations are high, but stub- best equipment, deeper market penetration, care reform today but not that style or fit, so
born professional resistance to implementa- and more accessible satellite sites, as do the keep showing us others.” The technical opac-
tion of practice guidelines and kindred con- communities they serve. Managed care plans ity of the debate, not to mention continuing
straints and the befuddlement of most private that contract too narrowly risk losing cus- skepticism of anything “made in Washington,”
and some public purchasers over what to do tomers. Health “planning,” which connotes ra- inhibit grassroots mobilization, citizen educa-
with analytic findings often leave the evalua- tioning, waiting lists, and beneficial services tion, and other key concomitants of vigorous
tive enterprise all dressed up with no place to foregone has largely vanished from the Amer- pluralist politics. No one seems to have a clue
go. In this arena, the United States and the 4 ican radar screen. Perhaps, however, the cost how to make well-documented dissatisfaction
nations may well converge. As cost pressures pressures accompanying universal coverage kindle a political fire under health reform.

January 2003, Vol 93, No. 1 | American Journal of Public Health Brown | Peer Reviewed | Public Health Matters | 55
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LEADERSHIP roughly half the dollars in the health care sys- 2. Light, DW. Universal health care: lessons from the
tem, after all—but political protocol requires British experience. Am J Public Health 2003;93:
25–30.
The 4 countries all recognize that strong, proclaimed allegiance to an official ideology
3. Rodwin VG. The health care system under
continuing leadership by the central govern- of market forces and less government even as
French National Health Insurance: lessons for health
ment is the sine qua non of affordable univer- reformers quietly and incrementally add a reform. Am J Public Health 2003;93:31–37.
sal coverage. Great Britain is, of course, the new piece of managed care regulation here, 4. Altenstetter, C. Insights from health care in Ger-
home of “socialized medicine.” Efforts by expansion of public coverage to another in- many. Am J Public Health 2003;93:38–44.
France’s famously powerful state to reform come category there. Much of this (abundant)
the health care system have multiplied in the public action originates in the states or
last 2 decades, especially since the Juppe re- evolves from complex sharing of initiatives,
forms of 1996. Germany’s central govern- funds, and powers between the national and
ment is a “supervisor, enabler, facilitator, state governments. Fifty states are a more
monitor,”4 and purveyor of national standards daunting tableau than 10 provinces, but the
for the health system. Canada’s constitution United States might infer from the Canadian
reserves health duties for the provinces, but system that universal coverage in a federal
the central government uses its financial system can be managed by 5 succinct princi-
leverage to enforce on them 5 straightforward ples, not 50 volumes of the Federal Register.
principles that protect solidarity and equity Unfortunately American reformers have been
for Canadian citizens. more inclined to admire Canada’s “single-
None of the 4 countries, however, supposes payer” financing than its much more instruc-
that health policy can be run entirely from tive central/provincial accommodations.
London, Paris, Berlin, or Ottawa. Germany Where this self-denying activism, this
and Canada are federal systems and, as Al- stealthy state leadership, leads is anyone’s
tenstetter4 and Deber1 explain, a mix of con- guess. Perhaps the present pattern—one step
stitutional, political, and informal rules and forward, one step back, and the nation count-
norms ensure that states and provinces partic- ing itself lucky if the number of uninsured
ipate extensively in making and running does not exceed 40 million—will persist. Per-
health policies that affect them. With such haps incrementalism will proceed and the na-
consultation comes conflict and delay, but tion will awake one day to find that enough
federalism and universal coverage are emi- programmatic pieces are in place to sustain
nently compatible. near universal coverage if only the money
Great Britain and France have created new and leadership can be summoned to add a
regional and community bodies—the Primary few more beneficiary categories and raise in-
Care Trusts in the former and regional hospi- come thresholds a few more notches. Perhaps
tal councils and public health conferences in another 1932 or 1964 waits right around the
the latter, for instance—that encourage delib- corner, and “real” health reform may sud-
eration and coordination closer to the prover- denly arrive on waves of social indignation
bial grass roots. All 4 acknowledge that de- and political innovation. At this point, how-
centralization and devolution are goals worth ever, cross-national learning disappears into
pursuing, but they also understand that work- the depths of national character.
able decentralization presupposes effective
centralization of policy authority.
This latter proposition generally eludes US About the Author
health policy. Save on rare occasions—for ex- The author is with the Mailman School of Public Health,
Columbia University, New York, NY.
ample, the New Deal and the Great Society— Requests for reprints should be sent to Lawrence D.
when issues of economic and social justice Brown, Professor of Health Policy and Management,
dominate the national agenda, fights over the Mailman School of Public Health, Columbia University,
600 W 168th St, New York, NY 10032 (e-mail: ldb3@
alleged evils of new central powers quickly columbia.edu).
upend debate on the ends of reform, health This article was accepted September 17, 2002.
or other. At least in the health sphere, actions
may speak louder than words—Medicare,
References
Medicaid, Children’s Health Insurance Pro- 1. Deber, RA. Rekindling Reform: lessons from Can-
gram, and other public programs control ada. Am J Public Health. 2003;93:20–24.

56 | Public Health Matters | Peer Reviewed | Brown American Journal of Public Health | January 2003, Vol 93, No. 1

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