The Federal Trade Commission/Department of Justice 2004 report Improving Health Care: A Dose of Competition appeals to efficiency arguments in promoting a wide range of health care market reforms. But the market-based reforms discussed in Improving Health Care are not simply neutral with regard to equity in access to services; they are likely to have substantial and inequitable distributional effects. We use the case of consumer-driven health plans (CDHPs), the pillar of the Bush administration's private-sector health reform efforts, to illustrate the limitations of viewing health policy reform through the lens of Improving Health Care. We conclude that the speculative efficiency gains from CDHPs need to be balanced against well-documented equity concerns within a normative framework. Moreover, other important ethical issues arise with regard to the risks imposed on the population by the introduction of policies that are based on a faith in markets rather than empirical evidence.

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