RESUMEN
This article seeks to establish what lessons might be available to the English health care sector following enactment of the Health and Social Care Act 2012 from the Dutch experience of introducing market competition into health care via a mandatory health insurance scheme implemented by for-profit insurance companies. The existence of the Beveridge NHS model in England, and a Bismarckian insurance system in The Netherlands perhaps suggest that a comparison of the two countries is at best limited, and reinforced by the different Enthoven-inspired competitive models each has adopted. However, we contend that there are positive and negative issues arising from introducing competition into health care-, e.g. concerns about equity and benefits of efficiencies-which go beyond national boundaries and different systems and reflect the global paradigm shift towards the use of market forces in previously non-market areas such as health. The article examines the situation in England following the HSCA 2012 and The Netherlands following the 2006 reforms before analysing two areas of common ground: the focus in both countries on competition on quality (as opposed to price) and integrated care, which is assuming ever greater significance. We suggest that our combined insights (as a health lawyer and competition lawyer respectively) coupled with a comparative approach create a novel contribution to current calls for a wider public debate about the real role of markets in health care over and above simple characterisation as a force for good or bad.