Comparisons of Health Insurance Systems in Developed Countries
Synopsis: Health insurance systems in developed countries vary in many dimensions. We develop a
framework for discussing these dimensions and then use this framework to compare the health insurance
systems of Canada, Germany, Japan, Singapore and the US. These countries span a wide array of
dimensions, including who in the system bears risk, what choices are allowed, how much health spending
burdens are redistributed, sources of revenue, cost saving strategies, and use of specialized and secondary
insurance.
1 Introduction
There is an enormous literature evaluating and comparing health insurance systems around the world,
which this article attempts to synthesize while emphasizing systems in developed countries. Our approach
is to provide an overview of the dimensions along which health insurance systems differ and provide
immediate comparisons of various countries in tabular form. To organize our analysis, we focus our
discussion on coverage for the largest segment of the population in all developed countries: workers
under age 65 earning a salary or wage, which we call the primary insurance system. We later touch on the
features of special programs to cover the elderly, the poor or uninsured, and those with expensive, chronic
conditions. We do this not because these groups are less important, but rather because special programs
are often used to generate revenue and provide services to these groups, and including these programs in
our discussion would add considerable complexity. For the same reason, we also focus on primary
insurance coverage of conventional medical care providers – office-based physicians, hospital-based
specialists, general hospitals, and pharmacies – knowing that there are many specialized insurance
programs for long term care, specialty hospitals, informal providers, and certain uncovered specialties.
A key feature of our analysis is that we focus on providing a broad framework for evaluating different
systems rather than immediately comparing specific countries. We initially distinguish between the
alternative contractual relationships used in different insurance settings and the choices available to each
agent or decision maker. We then provide an overview of the alternative dimensions in which health care
systems are commonly compared, which include the breadth of coverage, revenue generation, revenue
redistribution across health plans, cost control strategies, and specialized and secondary insurance,
Throughout the chapter, we use the health insurance systems of Canada, Germany, Japan, Singapore, and
the US. As shown in Table 1, insurance systems in these five countries span much of the diversity
exhibited by health insurance systems around the globe. These countries include both the most expensive
system (US) and the least expensive (Singapore), single payer as well as multiple insurer, government
sponsored and employer sponsored insurance. Unlike many comparisons, we try to emphasize the general
nature of the institutions used to provide care rather than the specifics of the institutional arrangements.
More unified discussion of each country is reserved until after we characterize the dimensions in which
health care systems can be compared.
countries
Simple
characterization
Canada
Single
payer
Germany
Universal
multi-payer
Japan
Employer
sponsored
insurance
Singapore
Subsidized
self-insurance
USA
Employer
sponsored
insurance
Primary sponsor
Gov.
Gov.
Employers
Self
Employers
Numbers of
health plans
1
200
>3000
0
>1200
companies
Mandatory
Yes
Yes
Yes
Yes
No
2 The topics in this chapter relate to almost every other chapter in this Encyclopedia, but are particularly
relevant for the topics of health insurance, risk adjustment, equity, demand-side incentives, and provider
payment.
Agents and Choices
Agents
As summarized in Table 2, it is useful to distinguish six classes of agents in all health insurance markets.
Consumers are agents who receive health care services, but in some systems they may have other choices
to make. Providers actually provide information, goods and services to consumers and receive payments;
we focus on providers covered by insurance contracts. Health plans are agents who contract with and pay
providers, also known in some countries as sickness funds. The sponsor in a health system serves as an
intermediary between consumers and health plans, allowing for consumer contributions for insurance to
differ from the ex ante expected cost of health care across consumers. In most countries the sponsor is a
government agency, although in the US and Japan the sponsor for most employed workers is their
employer. The key role of the sponsor in most countries is to ensure that the insurance contribution by a
consumer with high expected costs (such as someone old, chronically ill, or with a large family) is not
many times larger than the contribution of a consumer with low expected costs. Despite the enormous
complexity of diverse intermediaries in many health insurance systems, consumers, providers, health
plans and sponsors can be viewed as the fundamental agents in every health care market.
Two other types of agents deserve mention. Insurers are agents that bear risk in their expenditures. In a
given system they can be identified by asking who absorbs the extra cost of care from a flu epidemic or
accident. The insurer is not always a health plan since many health plans do not actually bear risk, but
instead simply contract with and pay providers and pass along the expense to someone else. Insurance (or
risk sharing) in a health care system can be shared by any of the four main agents in the health care
system. Finally, regulators set the rules for how the health care and insurance market is organized, and
Table 2: Six classes of agents in every health insurance system
Consumers: People actually receiving health care, and in some countries choosing health plans or
sponsors
Providers: Agents actually supplying health care services, such as doctors, hospitals, and pharmacies
Health plans: Agents responsible for paying and contracting with health care providers
Sponsors: Intermediaries between consumers and health plans who are able to redistribute the ex
ante expected financial cost of health care across consumers and among health plans
Insurers: Agents who bear risk (insure), who can be any combination of the Consumers, Providers,
Health Plans or Sponsors
Regulators: Agents who set the rules for agents in the health care system
3 this role can be played by sponsors (e.g., government), health plans, or providers (such as the American
Medical Association in the US). Sometimes the functions of two or more agents are combined in the same
agent. For example, some health plans own hospitals, and hence are simultaneously a health plan and a
provider.
Systems of paying for health care
Fundamentally, there are four different ways of organizing payments and contracts in health care systems.
Schematic diagrams of these are shown in Figure 1. System I is a private good market, in which
consumers buy health care services directly from providers. This system is still used in all countries for
non-prescription drugs and many developed countries for certain specialized goods (e.g., routine dental
and eye care, and elective cosmetic surgery,) but is rare for the majority of health care services. Most
consumers in Singapore and uninsured consumers in the US rely on a private good market, and pay for
their health care when needed, without insurance.
Figure 1: Four structures of health care payments
System I: Private good markets without insurance
System II: Reimbursement insurance
Insurer
Premium
Providers
Consumers
Reimbursments
Money
Services
Money
Providers
Consumers
Services
System III: Conventional insurance
System IV: Sponsored health insurance
Health Plan
Sponsor
Health Plan
Consumers
Providers
Cost sharing
Providers
Consumers
Services
4 System II is a reimbursement insurance market, in which consumers pay premiums directly to an insurer
in exchange for the right to submit receipts (or ‘claims’) for reimbursement by the insurer for spending on
health care. Under a reimbursement insurance system the insurer need not have any contractual
relationship with health care providers, although the insurer will need rules for what services are covered
and how generously. As will be seen, System II, is most common for secondary insurance in developed
countries, and it is also widely used for automobile and home insurance.
System III is a conventional insurance market in which the consumer pays a premium to a health plan,
who in turn contracts with and pays providers. Although popular in theoretical models of insurance
System III is not used for the primary insurance system in any developed country, but is sometimes used
for secondary insurance programs. Note the key difference in incentives between these two systems:
System II incents the consumer, but not the health plan, to search for low price, high quality providers,
while System III does the reverse, reducing consumer incentive but enabling the health plan to negotiate
over price and quality.
System IV is a sponsored insurance market in which the revenue is collected from consumers (directly or
indirectly) by a sponsor who then contracts with health plans, who in turn contract with and pay
providers. All developed countries that we have studied involve a sponsor, although in some developing
countries the sponsor may be a health plan.
Choices
Each of the line segments shown in Figure 1 reflects a contractual relationship, in which money or
services are transacted. These relationships are generally carefully regulated. Countries differ in the extent
to which they restrict or allow choice in each of these contractual relationships. Although many
comparisons of international insurance systems do not emphasize these choices, they vary across
countries significantly. Table 3 summarizes them for the five countries that are the focus of this paper,
where check marks indicate the system allows the choice, two check marks indicate it is dominant, and an
epsilon (ε) signifies that the choice is allowed but rare or of minor significance.
Table 3. Health system choices allowed in five countries
Canada
Consumer choice of providers
√
Consumer choice of health plans
Consumer choice of sponsors
Provider choice of consumers
Provider choice of health plan
Provider choice of sponsor
Health plan choice of consumers
Health plan choice of providers
Health plan choice of sponsors
Sponsor choice of consumers
Sponsor choice of provider
Sponsor choice of health plans
Simple count of system choices allowed
1
Notes: √=allowed, √√=dominant, ε=allowed but minor
5
Germany
√
√
Japan
√√
√
√
Singapore
√√
√
√
√
ε
√
√
√
ε
√
2
√√
5
√
8
USA
√√
√
√√
√
√
√
√√
√√
√
ε
√√
10 Every developed country insurance system allows consumers to choose among multiple providers, but
only a few allow providers to turn down consumers, or charge fees above the plans’ allowed fees
(Singapore, US). In some countries (notably the US, and legal but rare in Germany) health plans may
choose which providers they want to contract with, and providers may in turn choose the health plans they
contract with (selective contracting). An especially important dimension of choice is whether the primary
system has more than one health plan (Germany, Japan, US), and how choices among health plans are
regulated. In countries like the US and Japan, employers implicitly choose who to sponsor when they hire
workers, and hence employers play a key role in redistributing the costs of health care between young and
old, healthy and sick, or small and large families. In the US consumers and their sponsors (employers) are
allowed to choose not to purchase any insurance at all; some Japanese consumers ignore the mandate and
do not purchase insurance, making it similar to the US. The 2010 US Affordable Care Act, will start
imposing tax penalties on consumers and employers in 2014 if they do not purchase insurance, but the
system will remain voluntary.
Breadth of Coverage and National Expenses
Breadth of Coverage
With the exception of the US, all developed countries have universal coverage for their own citizens
through their primary insurance programs. As shown in the first row of Table 4, insurance coverage
approaches 100% of the population in Canada, Germany, Japan, and Singapore, while only 83% of the
US population has coverage. The 2010 Affordable Care Act (ACA) in the US will increase the percentage
covered, but there is considerable uncertainty about how much coverage will increase.
Because these measures are often a focal point of international comparisons of health care systems, Table
4 also contrasts the dollars per capita and percent of Gross Domestic Product (GDP) spent on health care.
US spending $8,233 per capita (18% of GDP) is by far the highest while Singapore’s spending of $2,273
per capita (4% of GDP) is by far the lowest. In recent years, not only has the US been the most expensive,
but it has also been experiencing more rapid cost growth relative as a share of its GDP (see Figure 2).
Table 4. Measures of health insurance breadth of coverage in five countries
Breadth dimensions
Population covered by primary insurance
Dollars of health spending per capita
GDP spending on health care
Public health care expenditures
Spending on the primary health insurance
Specialized insurance for selected populations
Prevalence of secondary insurance
Data from year
Population in 2012 (in millions)
Canada
100%
$5,948
11.6%
70%
70%
No
Common
2012
35
Germany
100%
$4,218
11.5%
77%
58%
Yes
Common
2010
82
Japan
100%
$2,878
9.3%
80%
70%
Yes
Common
2011
127
Singapore
USA
100%
83%
$2,273
$8,233
4%
17.9%
36%
56%
67%
34%
Yes
Yes
Common Common
2009
Xxx?
5
316
Countries differ considerably in the proportion of their health care spending done by the public versus the
private sector. This dimension is commonly a focus of international comparisons, but the proportion is not
a direct choice of the country, but rather it is the result of all of the other choices and regulations made in
6 Figure 2: Health Care Spending as a Percentage of GDP in 5 Countries.
the country. Of greater interest is the percent of spending by the primary health insurance plan or plans.
This ranges from 70 percent in Canada, to 34 percent in the US. Also of interest is the relative importance
of the primary insurance program versus various specialty insurance programs. The US has specialized
insurance programs for the elderly, the poor, children, and persons with disabilities which collectively
accounts for 56 percent of total health care spending
Revenue
Revenue generation
Developed countries vary significantly in how they generate revenue used to fund health plans (see Table
5) In most countries, proportional or progressive taxes earmarked for health care are used as the primary
source of revenue (e.g., Canada, Germany, Singapore and Japan), although in some cases general tax
revenues predominate. In the US and Japan, since employers are the primary sponsors, revenue comes
from premiums paid by each worker. In the US, the premium is typically shared between the employer
and the employee with the employer free to choose the portion of the premium paid by the employee.
State and federal tax systems partially subsidize health insurance in the US, by allowing these health
insurance contributions to be exempt from income taxes, a widely discussed subsidy of health insurance
and potential distortion. In Japan and Germany, premium contributions are set by law at a fixed rate
which is evenly split between employees and employers.
7 Table 5. Revenue generation and revenue redistribution in five countries
Sources of health care spending
Canada
Germany
revenue
Proportional payroll taxes
√√
Progressive income taxes
√
√
General tax revenue
√√
√
Implicit subsidies from employers
√
Fixed dollar premiums
√
ε
Charitable donations
ε
Consumer out-of-pocket payments
ε
Revenue redistribution: The use of risk adjustment
Primary insurance program
√
√√
Specialty insurance programs
ε
Public programs
ε
ε
Notes: √=allowed, √√=dominant, ε=allowed but minor
Japan
Singapore
USA
√√
√
√
√√
√
ε
√
√
√
√
√
√
√√
√
√√
√√
ε
√√
√
√
√
√
√
ε
√√
Revenue redistribution
In countries with a single health plan option, there is no need for redistributing revenue between multiple
health plans. However such systems typically have to allocate budgets among different geographic areas,
a similar task to reallocating money between competing health plans. In Canada, explicit risk adjustment
formulas are used to allocate funds among geographic areas within each province. In systems with
multiple competing health plans (i.e., Germany, Japan, US) risk adjustment is sometimes used to
redistribute money away from plans enrolling predominantly healthy enrollees and towards plans that
enrollee disproportionately sick or high cost enrollees. (This topic is explored in a separate entry on risk
adjustment in this Encyclopedia.) Explicit risk adjustment for this purpose is done only in Germany,
where age, gender, and diagnoses are used to reallocate money among competing plans. In the German
system, redistribution is done not only based of health status measures, but also to undo unequal revenues
due to the average income of health plan enrollees. This is due to the fact that plans enrolling
predominantly high income enrollees will have greater revenues than plans with low income enrollees,
since a proportional payroll tax is used as the dominant revenue source.
Despite having multiple competing health plans, Japan and the US do not use risk adjustment to
redistribute revenue, although in the US the ACA will expand the use of risk adjustment to the individual
and small group markets. Risk adjustment is already used extensively in the various US public programs
offered to the elderly and disabled populations and plans serving low income and high medical cost
consumers.
Health Care Cost Control
While every country faces the challenge of controlling health care costs, countries vary significantly in
their methods for doing so. Fundamentally, there are only four broad strategies for controlling health care
costs: demand-side cost sharing, or using prices imposed on consumers to encourage them to reduce
utilization; supply-side cost sharing, or using prices paid to suppliers to reduce utilization and/or reduce
plan payments per unit; non-price rationing, or setting limits on the quantity of key resources available to
8 Table 6. Cost containment in five countries
Canada
Germany
Demand-side Cost sharing
Is it used to control costs?
Copayment for office visits
Deductibles
Coinsurance
Coverage ceilings
Stoploss
Tiered provider pricing
Supply-side Cost Sharing
Is it used to control costs?
Prevalence of MD fee-for-service
Use of bundled hospital payment
Bundled payment for primary care
Salaried hospital physicians
Capitated provider groups
Monopsony pricing
Government sets fee levels
Global budgets
Pay for performance bonuses
Non-Price rationing
Government regulation of:
Hospital beds
Imaging equipment
Numbers of doctors
Health plan use of:
Selective contracting
Utilization controls
Managed Care
Gatekeepers
Japan
Singapore
US
√√
√√
√√
√√
√
√√
√√
√√
√√
√
√
√
√
√√
√√
√√
√√
√
ε
√√
√√
√√
√
√√
√√
√
√√
√
√
√√
√
√
√√
√√
ε
ε
√
√√
√√
√
√√
√√
√√
√√
√
√√
√
√
√
√
√
√
√
√
√
√√
√
√√
√
√
ε
√
√√
Information
Hospital quality measures
Physician quality measure
Health plan quality measures
Patient satisfaction surveys
Notes: √=allowed, √√=dominant, ε=allowed but minor
√
√
√
ε
ε
ε
√
√
√
√
√
provide health care, whether done by the government sponsor or by individual health plans; and
information provision that influences care provision and demand.
Table 6 summarizes the various cost control features used in the five countries we focus on. It is
interesting to note that Japan and the US rely extensively on demand-side cost sharing to control costs,
9
ε
ε
√√
√√
√√
√
√
√
√
ε while Canada and Germany rely heavily on supply side cost sharing. Singapore utilizes both. A growing
number of countries have moved to bundled payment for hospital care, which originated in the US where
hospital payments are based on Diagnosis Related Groups (DRGs). This system is now used in Germany,
Japan, and many other countries. Experimentation with other forms of bundled payment such as for
primary care and multispecialty clinics is ongoing but not yet widespread in Canada and the US.
Non-price rationing techniques are used quite differently in the different countries. In Canada,
gatekeepers and provincial level restrictions on capacity are common. In the US the government uses
these tools very little, though many private health plans use selective contracting and some managed care
plans use gatekeepers, though they are rarely mandatory. Gatekeepers are rare in Germany, Japan and
Singapore. Consumer information about hospitals, doctors, and health plans is of growing availability in
the US and Japan, but rare or non-existent elsewhere.
Specialized, secondary and self-insurance
Thus far we have focused on characterizing the primary insurance mechanism used by employed
adults in each country. Some countries have separate specialized insurance programs, for which only
certain individuals are eligible, such as the elderly, people with a serious disability, children, low
income individuals, individuals with high medical costs, the unemployed, the self-employed, and
individuals employed in small firms. In some cases these programs cover a sizeable fraction of the
population and an even higher fraction of total health care spending. As shown in Table 7,
Specialized insurance programs are very common in the US and Japan. At the other extreme,
Canada, with its universal, largely tax-funded system, does not need any specialized programs for
subsets of its population
Table 7. Specialized insurance, secondary insurance, and selfinsurance in five countries.
Canada
Germany
Japan
Specialized insurance for:
√√
Elderly
√√
Disabled
√
Children
√√
Low income
High medical cost
Unemployed
√
√
Self-employed
√
√
Secondary insurance
Complementary insurance
√
Supplementary insurance
√
√√
Duplicate insurance
Replacement insurance
√
√
Self-insurance programs
Health savings accounts
Notes: √=allowed, √√=dominant, ε=allowed but minor
10
Singapore
US
√
√
√√
√√
√
√√
√√
√
√
√
√√
√√
√√
√
√
√√
√
√√
√ In addition to specialized insurance for which only certain individuals are eligible, many countries
have secondary insurance programs that reduce the cost to consumers for spending not covered by
the primary insurance policy. This can be of four forms: Supplementary insurance covers services
not covered under the primary insurance; Complementary insurance provides additional
reimbursement for services not covered by the health plan; Duplicate insurance provides coverage
for services that are already included in the primary insurance program; and replacement insurance
serves as a substitute for primary health insurance coverage. Although conceptually distinct, in some
countries a single insurance policy may have elements of all three. In Australia, for example, a single
private policy may cover out-of-pocket costs for some services (complementary), cover new services
(supplementary) and also allow the enrollee to opt out of using the public insurance system for a
specific hospitalization or service (duplicate). Germany allows specified high income households to
purchase replacement policies instead of the primary policy.
The type of secondary insurance available in a country depends on the regulatory environment and
the structure of the primary insurance mechanism. For example, replacement insurance is banned in
Canada, but encouraged in the US for elderly or disabled Medicare enrollees. In countries where
primary health insurance does not utilize consumer cost sharing, consumers will have no incentive to
purchase complementary insurance. Almost every health insurance system will create a demand for
supplementary insurance, i.e., coverage for services not covered by the primary policy. Chiropractic
care, dental care, optometry, physical therapy, and pharmaceuticals are common examples of
services excluded from primary insurance but often covered by supplementary insurance. Coverage
for non-hospital based prescription drug spending is in some cases covered in the primary policy
(Germany, Japan, and some Canadian provinces) but not in others (many US plans, Singapore),
though in Singapore there is a short list of prescription drugs that can be obtained free from charge
from approved providers.
A relatively unusual alternative for insurance is self-insurance, in which consumers are required or
encouraged to save for their own current and future medical expenses. Self-insurance is typically
encouraged through a tax-exempt health savings account (HSA). This mechanism is particularly
important in Singapore, where health spending from health savings accounts comprises the majority
of total health care spending. Health savings accounts also received increased tax preference in 2003
in the US, and in 2012 were used by approximately 4 percent of all Americans. The institutional
structure of health savings accounts varies between the US and Singapore, but both have in common
that consumers are encouraged through the tax system to put money in when young, For most
consumers the account will grow over time. In some systems (Singapore), unspent money in the
account can be used for other household members, or spent on education, housing or other retirement
consumption.
The attraction of self-insurance is that consumers purchase health care services with money that is
valuable to them, and hence they have more incentive to shop around. The experience of Singapore,
discussed further below, provides evidence that the savings can be substantial. However, the
challenges of self-insurance are numerous. First, it presupposes that consumers can become well
enough informed to shop around intelligently. This is unlikely in most countries where there is
inadequate price and quality information for consumer shopping. Countries such as Canada and
Germany, which do not use demand-side cost sharing, demonstrate that supply side incentives can be
equally or more effective than demand-side cost sharing. Also of concern is that self-insurance works
well only for the 80 percent or so of the population with below average health care costs. Individuals
with the highest health care costs, particularly those with chronic conditions, will tend to spend all of
11 the money in their health savings account, and be severely constrained in their ability to afford health
care. In effect self-insurance fails these consumers when they need it most. Finally, self-insurance
raises equity concerns. Studies show that wealthier households accumulate far more resources than
low income households, and the tax advantaged savings are of much lower value to low income
households. Together, both imply that most of the benefits of health savings accounts go to relatively
healthy, higher income households.
Country Specific Comparisons
Canada
Canada has a universal single-payer, sponsored health insurance system called Medicare which is
administered independently by the thirteen provinces and territories. Every citizen and permanent
resident is automatically covered. The only choice available to consumers in the primary insurance
system is a choice of providers. The only provider choice is whether to be in the dominant public
system, or be an independent private provider, which is rare of most specialties. As of 2012, Canada
spends about 11% of GDP on healthcare expenditures. Medicare provides medically necessary
hospital and physician services that are free at the point of service for residents, as well as some
prescription drug and long-term care subsidies. In addition to Medicare coverage, most employers
offer private supplemental insurance as a benefit to attract quality employees, and a few Canadians
purchase replacement insurance. Each province/territory is responsible for the raising revenue,
planning, regulating, and ensuring the delivery of health care services, although the federal
government regulates certain aspects of prescription drugs and subsidizes the provinces coverage of
services to vulnerable populations.
Because all services covered by primary insurance are free at the point of service, medical
expenditures in this system are financed primarily through general tax revenue, or in some provinces
with small income-based premiums, which together cover 70% of healthcare expenditure. Private
supplementary and replacement insurance make up the remaining 30% of medical expenditure.
Employment-based supplementary insurance is the status quo among large employers and tends to
cover services such as optometry, dental and extended prescription drug coverage.
In most provinces, there are no selective contracts, so consumers are not limited to any particular
network of providers; however gatekeepers are often used so that consumers must obtain referrals
from their family physicians to see specialists. Office-based providers are paid fees for services. Each
province/territory sets its own fee schedule. Bundled DRG payments are used to allocate funds to
hospitals in a few provinces (e.g., Ontario), but this system of payments is largely invisible to
patients. While providers are able to charge alternative fees, the provincial insurance programs will
not pay for any of services not charged at the regulated rates. This means a provider who doesn’t
accept the government’s rates must bill the patient, or the patient’s secondary insurance, for the full
amount of the fee. The patient will not be reimbursed by the government’s insurance program for any
out-of-pocket expenses. It is important to note under most provincial and territorial laws, private
insurers are restricted from offering coverage for the services provided by the government’s program.
12 While provider shortages and long wait times to receive services push costs down, Canada is also
struggling to control rising healthcare costs. The elderly population is increasing in size and it is
difficult to maintain the level of benefits Canadian citizens have become accustomed to; cutting
covered services is causing frictions in the country.
Germany
The German government sponsors mandatory universal insurance coverage for everyone, including
temporary workers residing in Germany. Germany’s primary insurance system is a social health
insurance system that covers about 90 percent of the population in approximately 200 competing
health plans (called Sickness Funds), with the remainder of the population (primarily high income
consumers) purchasing private replacement health insurance system. Although employers play a role
in tracking plan enrollment, collecting revenue from employees and passing it along to a quasigovernment agency, they are not sponsors: insurance is not employment based in that all plans are
available without regard to where a consumer works. Germany spent about 12 percent of GDP on
health care in 2009.
Germany's health spending, excluding private insurers, is mostly funded by an income tax. This tax is
a fixed portion of income, usually 10-15%, depending on age, that is the same no matter which health
plan an individual is enrolled in, and is shared equally by the employee and employer. Health plans
are required to accept all applicants and pay all valid claims. Health plans are free to set premiums
but due to strong competition there is almost no variation in price. Germans stop having to pay any
payroll tax for health care at age 65 even while continuing to receive health care benefits. Patients are
also expected to pay a quarterly copayment to their primary care doctor. Collection of payroll taxes
and premiums is managed by employers, although employers play no role in defining choice options
and merely pass along taxes and premiums to an independent government agency. Government
subsidies are provided for the unemployed or those with low income. Risk adjustment is used to
reallocate funds among the competing health plans, based on age, gender and diagnoses.
In response to the acceleration of health care costs, Germany has implemented various cost cutting
measures. These include accelerating the transition to electronic medical records, introducing
quarterly consumer payments to primary care doctors (although visits remain free). Non-price
rationing methods are also used; for example in order to see a specialist, patients must first be
diagnosed and receive a referral from a physician who acts as a gatekeeper. Selective contracting by
health plans is allowed, but rare.
The German system uses a unique point-based global budgeting system to control annual health care
expenditures whereby the targeted expenditures are achieved by ensuring that total payments to all
providers of a given specialty are equal to the total budget for that specialty in a year. The Federal
Ministry of Health sets the fee schedule that determines the relative points for every procedure in the
country. Each year the total spending on a specialty in a geographic area is divided by the number of
procedure “points” from specialists in that area to calculate the price per point, and each physician in
13 that specialty is paid according to the number of accumulated points, up to quarterly and annual
salary caps.
The primary insurance coverage offered through the funds is among the most extensive in Europe,
and includes doctors, dentists, chiropractors, physical therapy, prescriptions, end-of-life care, health
clubs, and even spa treatment if prescribed. There are also separate mandatory accident and longterm care insurance programs. A majority of consumers also purchase supplemental coverage from
private insurers, and the supplemental coverage typically provides patients with dental insurance and
access to private hospitals.
Japan
Japan has a mandatory insurance system which is comprised of an employment-based insurance for
salaried employees, and an national health insurance for the uninsured, self-insured and low income,
as well as a separate insurance program for the elderly. Employment-based insurance system is the
primary insurance program in which employers play a significant role as sponsors and health plans
have considerable flexibility in designing their benefit features. Employment-based insurance is of
two kinds, distinguished between small and large firms. Health insurers offer employer-based health
insurance provides coverage for employees of companies with more than five but fewer than 300
workers and cover almost 30% of the population. Large employers (an additional 30% of the
population) sponsor employee coverage through a set of society managed plans organized by
industry and occupation. Employer-based health insurance coverage must include the spouse and
dependents. A public national health insurance program covers those not eligible for employer-based
insurance, including farmers, self-employed individuals, the unemployed, retirees, and expectant
mothers, who together comprise about 34% of the population. Health insurance for the elderly covers
and provides additional benefits to the elderly and disabled individuals. Finally, any household below
the poverty line determined by the government is eligible for welfare support. Altogether Japan
spends about 9.3 percent of GDP on health care (2011).
Health insurance expenditures in Japan are financed by payroll taxes paid jointly by employers and
employees as well as by income-based premiums paid by the self-employed. Fees paid to the health
care workers and institutions are standardized nationwide by the government according to price lists.
The largest share of health care financing in Japan is raised by means of compulsory premiums
levied on individual subscribers and employers. Premiums vary by income and ability to pay.
Employers have little freedom to alter premium levels, which range from 5.8 to 9.5 percent of the
wage base. Premium contributions are evenly split between employees and employers. Cost-sharing
includes a 20% coinsurance for hospital costs and 30% coinsurance for outpatient care. Employerbased insurance is further subdivided into society-managed plans, government-managed plans and
mutual aid associations. Patients may choose their own general practitioners and specialists and have
the freedom to visit the doctor whenever they feel they need care. There is no gatekeeper system.
14 All hospitals and physician’s offices are not-for-profit, although 80% of hospitals and 94% of
physician’s offices are privately operated. Japan has a relatively low rate of hospital admissions, but
once hospitalized, patients tend to spend comparatively long periods of time in the hospital,
notwithstanding low hospital staffing ratios. In Japan, the average hospital stay is 36 nights compared
to just six nights in the United States. This high average is likely to reflect the inclusion of long term
care stays along with normal hospital stays in the average.
Health insurance benefits designed to provide basic medical care to everyone are similar. They
include ambulatory and hospital care, extended care, most dental care and prescription drugs. Not
covered are such items as abortion, cosmetic surgery, most traditional medicine (including
acupuncture), certain hospital amenities, some high-tech procedures, and childbirth. There is a
specialized insurance program for childbirth expenses. Expenses that fall outside the normal
boundaries of medical care are either not covered, dealt with on a case-by-case basis, or covered by a
separate insurance system.
United States
The US system is at its heart an employment-based health insurance system in which employers play a
key role as sponsors of their employees. By one count, there are over 1200 private insurance companies
offering health insurance in the US, which are regulated primarily by the 50 states and not at the federal
level. These companies offer tens of thousands of distinct health insurance plans, each with their own
premiums, lists of covered services, and cost sharing features. In addition to this private system there are
also many overlapping public specialized insurance programs designed to cover consumers who are
elderly, disabled, or suffering from end stage renal disease (Medicare program), the poor or medically
needy (Medicaid), children, veterans, and the self-employed. Because the US relies on both private and
public insurance it is sometimes called a mixed insurance system. As of 2012, about 17 percent of the US
population was without primary insurance, although many of these consumers are in fact eligible for
Medicaid coverage but do not realize it. Altogether, the US spends nearly 18 percent of GDP on health
care, the highest of any developed country.
Although the government acts as the sponsor to all of the public specialized insurance programs,
employers are the key sponsor for most Americans. Choice is available to almost every agent in the US
system: consumers choose providers, health plans, and sponsors; and employers, health plans and
providers can generally turn down consumers who they prefer not to insure/employ, enroll or provide
services to. Employers generally contract with health plans while trying to control costs, but find little
competition to hold down prices or control utilization. Many health plans negotiate fee reductions with
provider groups, who tend to have substantial market power, but fees for medical care services in the US
are with few exceptions the highest in the world. Although the US Medicare program sets provider fees
for all regions without negotiation, all health plans must negotiate prices to be paid to providers, and the
resulting fees reflect bilateral bargaining with market power.
The 2010 Affordable Care Act (ACA) dramatically changed many features of the US health care system
and should greatly reduce the number of Americans who are uninsured. Starting in 2014 consumers who
are without insurance will have to pay a tax penalty, and employers above a certain size will have to offer
15 insurance to their full time employees or pay a penalty. This US system also entails setting up insurance
exchanges to cover the self-employed and small employers, who have the hardest time obtaining
insurance in the US. The ACA does relatively little to address cost containment issues, but does work
towards expanding the number covered by insurance. It is unclear whether the national reform will work
as well as it has in Massachusetts, where it has reduced the percentage that is uninsured to less than two
percent of the population.
Cost containment is a huge issue in the US with such high spending in relation to its income. Demandside cost sharing is used widely, with copayments, coinsurance, deductibles, coverage ceilings and tiered
payments all being used to deter demand. Many health plans use supply-side cost sharing, such as DRG
bundled payments, and some are beginning to bundle primary care payment. Tiered provider payment, a
form of “Value based Insurance”, is also beginning to be used. Recent innovations include capitated
provider networks, known as Accountable Care Organizations (ACOs) and reorganizing primary care
providers to work and be paid as a Patient Centered Medical Home (PCMH). Pay for performance
systems and electronic medical records are other innovations being tested. It is too early to know which of
these systems will be most successful in controlling costs.
Much can be written about the US public insurance programs – Medicare, Medicaid, CHIP, and The
Department of Veterans Affairs – which also have their own payment systems and cost containment
issues. The key point is that there is a huge amount innovation, from which other countries can learn. A
positive feature of the US system is the exploration of diverse payment, non-price, and informational
programs to try to control costs. Individual level health care data is more available from the US than from
any of the other four countries studied here. Also, consumer information about doctors, hospitals and
health plans are all available and can potentially play a role in consumer choice.
With the exception of Singapore, the US health care system is arguably the most unfair health care
system, with consumers who are poor or ill with chronic illnesses paying a high share of their income for
medical care. Health care spending is a common source of individual bankruptcy.
Singapore
Singapore has a unique-to-the-world health care system where the dominant form of insurance is
mandatory self-insurance supported by sponsored saving, although complementary and special insurance
programs are also central to their system. Remarkably, despite having a per capita GDP of approximately
US$60,000 in 2011, Singapore reports spending a mere 4% of GDP on health care (2012). The
centerpiece of its system is a mandatory income-based individual savings program, known as Medisave,
that requires consumers to contribute 6% to 9% (based on age and up to a maximum of $41,000 per year)
of their income to a health savings account (HSA). This HSA can be spent on any health care services a
consumer wishes, including plan premiums. Funds not spent in a consumer’s HSA can be carried forward
to pay for future health care, used to pay for health care received by other relatives or friends, or if over
age 65, cashed out to use as additional income, though there are some restrictions. A complementary
insurance plan, known as Medishield, is available to cover a percentage of expenses arising from
prolonged hospitalization or extended outpatient treatments for specified chronic illnesses, though it
excludes consumers with congenital illnesses, severe pre-existing conditions and those over 85 years old.
16 As of 2011, this specialized MediShield program, which is optional, covered approximately 65% of the
population. The government also supports a second complimentary catastrophic spending insurance
program, known as Medifund, which exists to help consumers whose Medisave and Medishield are
inadequate. The amount consumers can claim from this catastrophic insurance fund depends on their
financial and social status. Singapore’s system also includes a privately available, optional insurance
program covering long term care services (called Eldershield), with fixed age of entry based payments.
Consumers are automatically signed up for Eldershield once they reach 40 but they may opt out if they
wish. Subsidies are available for most services, but even after the subsidies consumers must pay
something out of pocket for practically all services. Some, but not all, subsidies depend on the consumer’s
income, and consumers often have a choice over different levels of coverage.
Funding for all three of the secondary insurance programs (Medishield, Medifund and Eldershield) comes
from general tax revenue. There are also five private insurance companies offering comparable plans,
some of which are complementary to Medishield. Singapore has both public and private providers with
the public sector providers serving the majority of inpatient, outpatient and emergency care visits and the
private sector serving the majority of primary and preventative care visits. Singapore’s system receives
positive publicity for its low percentage of GDP spending on health care but has been criticized as not
replicable elsewhere. The relatively small population and high GDP per capita allows Singaporeans to
avoid some of the costs associated with regulating health insurance in larger, more populous countries.
Perhaps Singapore’s most substantial criticism is insufficient coverage for post-retirement health care
expenses. Between potentially diminished savings and being cut off from Medishield at age 84 there is
little support for financing catastrophic illnesses. Other criticisms of the country center on fairness
concerns. The system favors high income over low income households, since they will have much greater
funds contributed to their HSA. Also, consumers with high cost chronic conditions, such as diabetes and
mental illness, will repeatedly deplete their HSA and need to fall back upon the various secondary
insurance programs. Stigma is also an important cost containment mechanism. Finally although
consumers are incented to shop around among providers, as of 2012 there are no readily available report
cards or other information sources available to guide consumers to lower cost or high quality doctors and
hospitals.
Concluding Thoughts
From the above descriptions, it is clear that there are an enormous number of ways that health care
insurance programs vary around the world. Most country systems can be viewed as combinations or
variations on the five systems described here. While it would be wonderful if there were a way of
identifying the characteristics of the most effective systems and the most equitable ones. Unfortunately
doing so in this paper would require going beyond the boundaries of what is feasible. There are several
excellent surveys of country health care systems, notably from the Organization of Economic Cooperation and Development (OECD) and a series by the Commonwealth Fund that are excellent and are
worthy of further reading.
17 Glossary
Ceiling: limit on the dollar payments or visits covered by a health plan
Claims: payments for consumer losses covered by health plans
Coinsurance: proportion of health care cost paid by the consumer, for example 20%
Complementary insurance: insurance that covers part of the consumers cost share of their primary plan.
Copayment: fixed money amount paid per day or unit of service, for example, $10 per office visit
Cost-sharing, demand-side: health care costs paid by the consumer, which can be copayments,
coinsurance, deductibles, or amounts paid above a coverage ceiling
Cost-sharing, supply-side: health care costs borne by providers
Cost-sharing, premium: share of premium paid by consumers rather than a sponsor
Deductible: amount up to which the consumer pays the full price for health care, hence the consumer
might pay the first $500 deductible without any copayment
Duplicate insurance: insurance which provides coverage for benefits already included in the primary
insurance program, which may have further benefits, including jumping ahead in a waiting line
Health savings account: a system of self-insurance in which funds are deposited by a consumer or
sponsor and available for reimbursing health care expenses in the current or future year
Managed care: insurance programs in which utilization constraints are used to control costs
Pay for performance: payments determined based on some observed measures of providers
Premium: fixed payment per unit of time (e.g., per year) for a defined set of health care services
Primary insurance: the system of insurance used for the dominant group in every country, who are
employed workers and their dependents.
Replacement insurance: insurance purchased as an alternative to the primary insurance. Not clearly
defined for the US.
Risk adjustment: the use of information to explain variation in health care spending, resource utilization
or health outcomes over a fixed period of time.
Secondary insurance: insurance which adds to or replaces coverage provided by primary insurance
program
Selective contracting: providers can choose whether to contract with some or all health plans, and health
plans can choose whether to contract with only some providers.
18 Self-insurance: consumers bearing the full risk of health expenditures through savings. Consumers are
also their own sponsors.
Social insurance: system of insurance in which benefits are defined by statute, revenue generation is
primarily income-based, participation is mandatory
Specialized insurance: insurance programs designed to serve specialized populations, which could be
elderly, children, disabled or having certain specified chronic conditions or high health costs.
Stoploss: limit on the amount of payment by an agent, such as a consumer or health plan
Supplementary insurance: insurance that provides coverage for services not covered by the consumer’s
primary insurance plan.
19 Recommendations for further reading
1.
Breyer, F., Bundorf, M.K., and Pauly, M.V. (2012). Health care spending risk, health insurance,
and payments to health plans. In Pauly M.V., McGuire, T.G., and Barros, P.P. (eds.) Handbook
of Health Economics. Volume II. Elsevier.
2.
Busse, R., Schreyögg, J., and Gericke, C.. (2007). Analyzing changes in health financing
arrangements in high-income countries: a comprehensive framework approach, health, nutrition
and population (HNP). Discussion paper of The World Bank’s Human Development Network,
The World Bank.
3.
Cutler, David M. and Richard J. Zeckhauser. (2000). The anatomy of health insurance. In
Cuyler, A.J. and Newhouse, J.P. (eds.) Handbook of Health Economics. Volume I. Elsevier. 563637.
4.
Davis, K., Schoen, C. and Stremikis, K.. (2010). Mirror, mirror on the wall: How the
performance of the U.S. health care system compares internationally. The Commonwealth
Fund.
5.
Ellis, R. P. and Fernandez, J. G. (2012). Risk selection, risk adjustment and choice:
concepts and lessons from the Americas. Boston University working paper.
6.
European Observatory on Health Systems and Policies. Health Systems in Transition (HIT)
Series.
Downloaded on April 15, 2013 from
http://www.euro.who.int/en/who‐we‐are/partners/observatory/health‐systems‐in‐transition‐
hit‐series
7.
Henke, K.-D., Schreyögg, J. (2004). Towards sustainable health care systems—strategies in
health insurance schemes in France, Germany, Japan and The Netherlands. International
Social Security Association: Geneva.
8.
McGuire, T. G. (2012). Demand for health insurance. In Pauly M.V., McGuire, T.G., and
Barros, P.P. (eds.) Handbook of Health Economics. Volume II. Elsevier.
9.
Meulen, R. T. and Jotterand, F.. (2008). Individual responsibility and solidarity in European
health care. Journal of Medicine and Philosophy, 33, 191-197.
10.
Physicians for a National Health Program. (2013) International health systems.
Downloaded on April 15, 2013 from
http://www.pnhp.org/facts/international_health_systems.php?page=all
11.
Rice, N. and Smith, P. C.. (2001). Ethics and geographical equity in health care. Journal of
Medical Ethics, 27,256-261.
20 12.
Saltman, R. B., Busse, R., and Figueras, J.. (2004).Social Health Insurance Systems in
Western Europe. Open University Press.
13.
Thomson, S. and Mossialos, E.. (2010). Primary care and prescription drugs: coverage, costsharing, and financial protection in six European countries. The Commonwealth Fund.
14.
Thomson, S., Osborn, R., Squires, D. and Reed, S. J.. (2011). International Profiles of Health
Care Systems. The Commonwealth Fund.
15.
Van de Ven, W.P.M.M., Beck, K., Buchner, F., et al. (2003). Risk adjustment and risk
selection on the sickness fund insurance market in five European countries. Health Policy, 65,
75-98.
16.
Van de Ven, W.P.M.M. and Ellis, R.P. (2000). Risk adjustment in competitive health plan
markets. In Culyer, A.J., Newhouse, J.P. (eds.) Handbook of Health Economics. NorthHolland.
21 Suggested cross references from the Encyclopedia of Health Economics
4.10 Public health priority setting
Kenny Lawson, Helen Mason, Emma McIntosh and Cam Donaldson
5.7 Incorporation of Societal Concerns for Fairness in Economic Evaluations of Health Programs:
Overview
Richard Cookson
8.6 Rationing of Demand
Luigi Siciliani
9.1 Health Insurance in Historical Perspective, I: Foundations of Historical Analysis
Evan M. Melhado
9.2 History of Health Insurance in Developed Countries
John E. Murray
9.3 History of Health Insurance in the US
Timothy S. Jost
9.6 Theory of Demand for and Welfare Implications of Health Insurance
John A. Nyman
9.7 Theory of Social Insurance
Friedrich Breyer
9.10 Value Based Insurance Design
Michael E. Chernew
9.17 Supplementary Private Insurance in National Systems in the USA
Adam Atherly
9.18 Selection and Risk Adjustment
Randall P. Ellis and Timothy J. Layton
9.19 Issues of a Private Insurance System
Kosali Simon
9.21 Long-term Care Insurance
R. Tamara Konetzka
13.3 Risk Adjustment, the European Perspective
Wynand van de Ven
13.7 Risk Adjustment in a Perfectly Competitive Market of Managed Care
Thomas G. McGuire and Jacob Glazer
22