What shapes national responses to EU public procurement policy? The case of health and social services in Norway, Germany and England

This article investigates responses to EU public procurement directives in Norway, England and Germany, with a particular focus on health and social services. We used a comparative national patterns approach to analyse parliamentary debates, consultative statements, the media and interviews with stakeholders.

The literature contains prominent arguments suggesting that health and social service governance regimes are converging on the liberal model. Some authors argue that with its focus on policies which create markets, the EU is a driving force with an increasing relevance for market-based governance practices. However, the role of EU legislation is unclear as procurement regimes in relation to the governance of health and social services constitute a highly ambiguous terrain. Our study enabled us to show that the form of the debate is highly dependent on path-dependent mechanisms and the degree of openness of the national political system that provides channels for interests to be articulated. Indeed, the Norwegian case study serves as an excellent example of why marketisation has not advanced to the degree predicted in the literature: an inclusive and open political system and a strong non-profit health and service sector meant that the non-profit groups managed to turn the debate in their favour.