Despite critics slamming "Obamacare" – the first major U.S. health-care reform passed in nearly 50 years – as "Canadian-style" health insurance, critics note that major differences between the two systems persist.

McGill University Professor of Political Science Antonia Maioni said the U.S. Patient Protection and Affordable Care Act, which went into effect earlier this week, is "not even close" to the Canadian system.

"Obamacare keeps in place the basic principle of health care in the United States which is: if you want to get access to care you need to buy insurance coverage," she told CTV News Channel on Friday.

"Obamacare is trying to make it easier for people to be able to buy that insurance coverage and, if you are very poor, to be able to qualify for a government program. But it doesn't have the same principle as in Canada, where if you are a legal resident, you are automatically enrolled in a provincial or territorial health plan."

In an op-ed published in the Globe and Mail, Maioni said the major differences between "Obamacare" and Canada's health-care system include:

  • "Obamacare" is not a single-payer system (where one entity, usually the government, pays all costs)
  • Care depends on the type of insurance coverage you buy
  • Insurance coverage varies by state
  • Wait times are based on the level of insurance coverage
  • Obamacare" faces challenges in cost control

Maioni said that while "Obamacare" was passed, in part, to address American spending on health care – the highest in the world at nearly 18 per cent of GDP, or $3 trillion – the act remains "problematic."

"There's nothing in it that speaks to really serious cost control," she said.

She added that while Canada also spends a lot on health care, there are mechanisms that the provinces can use to contain spending.

"Governments can negotiate fees with providers, governments can set global budgets for hospitals," she said. "There's a lot of politicking and controversy around that, but at least there's some measures of control for the government. In the United States, those measures are not there."

While "Obamacare" does try to better regulate insurers and provide ways for the government to tighten Medicare – the government program for the elderly and the disabled -- "there's no real facing up to the cost wall," she said.

She added that while the act will make it easier for Americans to buy affordable insurance, there are still "prevalent" gaps in the system.