The Patient Protection and Affordable Care Act wasn't the only landmark health care reform implemented in the last few years. In England, legislators transformed the nature of their health care system by passing the Health and Social Care Act 2012, a law that reorganized the NHS, the oldest and largest publicly funded health service in the world.
Both sets of reforms aim at bridging the gap between public and private investment, but despite England allowing for greater market-based competition and the United States expanding government-subsidized care, the two approaches share little common ground.
As the debate continues over the effect PPACA will have on this country's largely privatized system, it's instructive to examine the effect that private investment is having on Britain's historically public one.
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In early 2011, the British Parliament passed the most substantial reforms to the country's National Health Service since it was launched in 1948. Lawmakers argued the British system was losing a struggle with rising costs in a floundering economy. The Health and Social Care Act 2012 was presented as a way to modernize the NHS and create avenues for innovation.
"Something had to be done," says James Barlow, a professor at the Business School at Imperial College London. "The NHS could not go on providing universal service to the same degree without some radical thinking."
Supporters also claim the law will reign in years of unchecked spending. According to a study by the Organization for Economic Cooperation and Development, the United Kingdom's overall health spending increased by 5.7 percent per year between 2000 and 2009. By 2011, it accounted for 9.4 percent of total GDP.
While this number is about average for OECD countries (and far less than the 17.7 percent of U.S. GDP attributed to health spending), it constitutes a nearly 2 percent increase in just five years.
It's important to note that devolution, which occurred in the late 1990s, separated the governments of each U.K. country into individual legislative bodies. While Scotland, Wales and Northern Ireland also have undergone health care reforms in recent years, these are only marginally related to those of England and have proven less sweeping than the Health and Social Care Act 2012.
England's effort to streamline service and promote competition among providers began with abolishing the Commissioning and Primary Care trusts previously responsible for buying and delivering services at the regional level. These were replaced by 211 different Clinical Commissioning Groups, which arrange emergency care and contract services for any unregistered patients who live in their area.
The CCG's are run in part by general practitioners who will likely have the most intimate knowledge of the needs of their patient base and be able to eliminate unnecessary expenditure.
Opponents fear that the move fragments the NHS and places unelected GP's into important posts. It also introduces new administrative demands onto the system.
"About 80 percent of the health care budget is now channeled through GP's, which has led to a huge organizational upheaval," Barlow explains.
If the passing of the Health and Social Care Act 2012 represents a new chapter for the U.K.'s nationalized health service, the most striking change is the substantial increase in influence that private care providers will acquire.
In terms of funding, the system will remain financed almost entirely by taxpayer dollars, but the law does away with a previous limit on the amount of income NHS hospitals can earn from private companies.
Doctors will continue to be able to buy services, like tests and X-rays, from NHS hospitals and clinics, but also can more easily outsource services to private companies.
According to Barlow, many hospitals are looking at the opportunity favorably, saying they are "liberated to operate more as a business, which gives them the opportunity to take on bold new work.
However, there was a substantial amount of resistance to the original writing of the bill, with critics countering that it did not do enough to ensure the continuation of a national approach to care.
The opposition stance was summed up by British activist organization, 38 Degrees, in a legal review that stated that the reorganization "is effectively fragmenting a service that currently has the advantage of national oversight and control, and which is politically accountable via the ballot box to the electorate."
Critics also question whether restructuring the system was necessary to curb spending in the first place.
"There is a variety of data showing that the NHS was administratively very efficient and cost effective overall and that the reforms have stimulated the growth of administration costs," says David Himmelstein, a professor at the CUNY School of Public Health in New York and an expert on the organization of national health systems. "The best guess is that the reforms are going to tremendously decrease overall efficiency."
While the goal of the Health and Social Care Act 2012 to reign in wasteful spending while increasing the quality and integration of care is similar to that of PPACA, the English and U.S. systems are still far from comparable.
Contrary to claims from opponents that it would result in the nationalization of health care in the United States, PPACA has in effect expanded the reliance on private insurance by bringing low- and middle-income Americans previously unable to purchase coverage privately or through employers into the fold.
In order to receive subsidies, plans must be bought through government exchanges, but the overall system is still based on direct access of patients to private providers. Himmelstein points out that "while it's true that PPACA extended Medicaid, almost all new coverage is channeled through private insurers."
In the end, both countries still lack the balance between public and private investment in care that their respective reforms were intended to produce.
"England now wants patients to be treated as customers and to think of themselves as customers," Himmelstein says. "If anything, what we're talking about is the English system moving toward the U.S., not vice versa."
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