中英德三国社会医疗保险监管体制比较

The Comparison of the Health Insurance Regulation among The UK,Germany and China

英国全民健康服务体系监管采用国际主流的独立监管模式,主要由三个独立机构依据稳定透明的规则对NHS服务的提供者和购买者进行直接监管,监管的主要内容包括准入监管、价格监管、竞争行为监管和质量监管等等,监管的结果是促进医疗服务的经济、效率和效果,同时以患者的利益维护和提高质量。德国法定医疗保险监管则采用德国特有的自我监管模式,自我监管基于医疗服务提供方和购买方双方的法团主义组织谈判达成的服务合同,双方彼此监督对合同的遵守以及对联合委员会决定的遵守。州政府和联邦政府不参与法团主义组织的决策制定,而主要是制定法律规则并监督双方对规则的服从。比较而言,中国基本医疗保险监管则看不出具体的模式,在监管者、监管内容和监管手段等三个方面和英德两国存在明显差异。

The Regulation model of British National Health Services is the mainstream ＂independent regulation＂, which mainly through three independent institutions to regulate the NHS providers and buyers based on stable and transparent rules. The main contents of NHS regulation include admission, price, competition and quality regulation and so on.The aim of NHS regulation is to promote economy, efficiency and effectiveness of the medical services, and to maintain and improve the medical quality on behalf of the interests of the patients. The regulation model of the German statutory health insurance is ＂self-regulation＂, which is a unique regulation style of Germany.Self- regulation is based on the services contracts negotiated by the corporatism organizations on both sides of medical services providers and buyers, and they mutually supervise each other to abide by the contracts and comply with decisions decided by the joint committee.The state government and the federal government does not participate in decision making of the corporatism organizations, rather than mainly to make the law and supervise the two sides to obey the rules of law.In comparison, Chinese basic health insurance regulation does not have specific model, and it significantly different from the regulation in the NHS and the Sill in the three aspects of who are regulators, what to be regulated and how to regulate.