Health Care Delivery in Britain and Germany: towards Convergence?

Generally speaking, the British and the German health care systems differ not only with respect to their financing and service provision arrangements, but also with respect to the underlying governance mechanisms. For the most part, the British health care system and in particular its core, the National Health Service (NHS), is funded out of general taxation. The German health care system, by contrast, is funded through social insurance contributions, shared by employees and employers. While the NHS provides both primary and specialist care for all legal residents of the UK, Germany’s health care system provides these services only to those residents who are insured either under the compulsory public health care scheme (GKV) or under the private health care scheme (PKV). In both countries primary health care is delivered by self-employed doctors, general practitioners (GPs) in Great Britain and Allgemeinärzte in Germany. Compared to Germany, where the free choice of doctors is a well-defended principle, in the British system choice of primary health providers is rather more restricted. Another crucial difference between the two systems lies in the fact that in the British system, ambulatory specialist care is delivered by salaried doctors in the out-patient units of hospitals, while in Germany these kind of services are delivered by self-employed specialists (Fachärzte). With respect to the governance of the health care system, state regulation plays a stronger role in Britain than in Germany, where selfadministration takes on functions which in the British system are performed by the state and its arm’s length bodies. Interestingly, however, during the last decade, market mechanisms have increasingly gained ground in both systems.