ABSTRACT
This chapter grew out of the hope, which inspires comparative research, that there might be lessons to be learned from the experience of others. The author, an American, was interested in the problem of how government might go about assuring the quality of medical care, a topic of great current importance in the United States. The Medicare Peer Review (PRO) Programme of quality regulation costs $255 million a year and a recent report from the Institute of Medicine has called for this to be further strengthened (Institute of Medicine 1990). There have been frequent calls for state professional disciplinary efforts to be strengthened which have led to the creation of a new federal databank to which all malpractice settlements and judgements and hospital and professional disciplinary actions must be reported. The volume of medical malpractice suits based on allegations of poor quality medical care is notorious and involving ever higher sums of money. It is not clear, however, that all this activity and expense is significantly improving the quality of American medical care.
