The purpose of this paper is to analyse the levels of access to healthcare available to undocumented migrants in the Italian and British health systems through a comparative analysis of health policies for this population in these two national health systems.
It builds on textual and legal analysis to explore the different meanings that the principle of universal access to healthcare might have according to literature and legal documents in the field, especially those from the human rights domain. Then, the concept of universal access, in theory, is contrasted with actual health policies in each of the selected countries to establish its meaning in practice and according to the social context. The analysis relies on policy papers, data on health expenditure, legal statutes and administrative regulations and is informed by one research question: What background conditions better explain more universal and comprehensive health systems for undocumented migrants?
By answering this research question the paper concludes that the Italian health system is more comprehensive than the British health system insofar it guarantees access free of charge to different levels of care, including primary, emergency, preventive and maternity care, while the rule in the British health system is the recovering of charges for the provision of services, with few exceptions. One possible legal explanation for the differences in access between Italy and UK is the fact that the right to health is not recognised as a fundamental constitutional right in the latter as it is in the former.