As the Patient Protection and Affordable Care Act takes shape, it is often compared to European health care and, in particular, to the system in France. It's an easy comparison to make: Both are built on a large, highly regulated private sector and rely mainly on third-party, employment-based insurers.

In the United States and France, workers and employers split the cost of health insurance. Both countries cringe at the thought of waiting lists for elective surgeries or to see a specialist, and both fear any system that would force them to give up their choice in medical providers.

But there is a great distinction to be made between the ambitions of the two countries, and the French will let you know it. Their health coverage is universal, extending across age groups and income levels. TheU.S.system provides government-sponsored coverage only to certain segments of the population, both before and after the enactment of the new federal health care law in which private insurance is subsidized for some low and middle-income Americans.

It was a point made last year by French Minister of Health and Social Affairs Marisol Touraine. Many French find it surprising that Americans would resist a system of near-universal health coverage, she told reporters outside the Elysee Palace.

There is, however, a comparison the French will like even less: the suggestion that their system is anything like Canadian- or British-style socialized medicine.

“The idea of direct access to specialists, the doctor-patient relationship, and access to small private practices is very appealing in France, and they would never put up with a U.K.-style national health service. They consider it outrageous,” said Paul Dutton, a historian at NorthernArizonaUniversityand author of Differential Diagnoses: A Comparative History of Health Care Problems and Solutions in the United States and France. “That is as far removed from France as it is from the United States. Still, there are the same issues that they face: how to share networks, how to keep costs down. Most countries, really, are struggling with that.”

The French way

France's health care system is a public-private mix of government and marketplace. Its national insurance program pays about 70 percent of the bill, funded mostly by payroll and income taxes. The remaining amount is covered by private insurance, which nearly every person has.

The government regulates hospital fees and drug costs and negotiates with medical unions that set doctors' fees. Sécurité Sociale, a standardized billing and patient reimbursement system, stands in for the army of billing administrators typically seen in American doctors' offices. This makes insurance battles far less common.

“They don't have huge battles between back offices of doctors and insurers, back and forth, arguing over rates and money,” Dutton points out. “Many middlemen are eliminated. It is much more efficient and cheaper.”

The doctors also are cheaper. The average French physician makes about twice as much as the average earnings of his or her compatriots, compared with the average American general practitioner who earns more than five times the averageU.S.wage.

In fact, U.S. doctors were estimated to earn double the median for 21 nations in the most recent data provided by the Paris-based Organization for Economic Cooperation and Development. The difference was nearly threefold for specialists.

That is a direct reflection of higher costs for services. A routine visit to a French doctor will cost $23 in France, while his or her American counterpart will charge nearly four times as much.

In 2010, the total capital expenditure per person was $8,233 in the United States, more than double the expenditure in France ($3,974) and the OECD average of $3,265.

Less than half of health spending in the United States was publicly financed at the time, compared with an average of 72 percent among other countries ranked by the OECD. Yet government spending on health care was greater than nearly all of the other countries, with the exception o f Norway and the Netherlands.

Tough comparison

Efforts to measure or rank quality, especially compared with spending, have been met with unease. The most recent attempt, by the World Health Organization nearly a decade ago, graded each nation's system on lifespan, responsiveness, health care outcomes and individual spending; it ranked France No. 1 and the United States No. 37.

Many researchers have been skeptical of the report, pointing out that factors such as dietary habits are beyond the control of a country's health care system.

The OECD did make some comparisons in its health data report released last year.Franceranked above the average of 34 countries in terms of the number of physicians and life expectancy at birth, partly attributed to progress in medical care.

TheUnited Stateswas found to have fewer physicians available for the population compared with the average, but it was ranked high in terms of access to technology such as MRIs. TheUnited Statesalso had the highest breast cancer five-year survival rate.

There is one aspect ofFrance's system that has been especially lauded: The sicker a French citizen is, the better they are taken care of by the nation's system. For people with any of 30 long-term and expensive illnesses, the government pays entirely for surgeries, therapies and drugs. It is somewhat in the same vein as the Affordable Care Act prohibiting health plans from limiting or denying coverage or charging more based on a person's medical history.

There are also a number of challenges. Both the WHO and the OECD highlighted pressures they face to bring spending under control as an aging population threatens to stress both systems.

The cost factor

Like the United States, France is looking at new ways to ensure people have access to care and to reduce health inequalities, said Isabelle Durand-Zaleski, director of Paris-based health economics and health services research unit Urc Eco.

“Every French citizen is entitled to health coverage, and that is an important achievement,” said Durand-Zaleski, who is also the chief of public health for hospital group Henri Mondor-Albert Chenevier.

“Still, we are seeing supplemental benefits, which cover extra billing for dental care or eye care, being reduced somewhat. Especially on the economic downturn, insurers tend to try and reduce the benefits, but there is currently a lot of lobbying and pressure at the Parliament to target that.”

While about 95 percent ofFrance's population has supplemental insurance in addition to the public-funded baseline insurance, mostly provided by employers, some loopholes exist. Some employers recruit staff on casual or short-term contracts to avoid paying benefits. But this affects a very small percentage, Durand-Zaleski said, and supplemental insurance is still affordable. Plans can be purchased for as little as €20 a month.

Premiums in theUnited Stateshave soared since the 2010 enactment of the Affordable Care Act. A survey by the Kaiser Family Foundation found that premiums for single coverage in theUnited Stateslast year averaged $5,615, or $468 a month. Over five years, the costs have increased 25 percent for individual coverage and 30 percent for family coverage.

That isn't to say that the French are not, in one way or another, paying a high price for the services they receive. They pay 21 percent of their income tax toward health care.

Look to the Swiss

Perhaps the United Statesshould aspire to be more likeFrance's neighbor to the north. Switzerland already has what PPACA hopes to achieve: universal coverage through mandatory private insurance. The Swiss are required to purchase a plan from one of 92 insurers for an average premium of about $300 a month. The government regulates drug prices and fees for medical tests; patients can choose their doctor; and there are no waits for specialists. Insurers are not allowed to deny or delay coverage due for reasons other than fraud.

The benefits include the freedom to choose insurance without the backing of an employer, giving people the freedom to leave a job without worrying about whether doing so would jeopardize their health or well-being. More than 99 percent of the population is insured, and those who come into the country without buying insurance eventually receive a bill from the government, which has gone ahead and picked one for them.

Are they happy with it? A 2011 Deloitte survey found that more than half of Swiss respondents gave their health care system a grade of A or B, as did half of the French who were polled. Exactly half—50 percent—of Canadians gave the high grade, as did 46 percent of Britons.

Only 22 percent of Americans did the same.

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