Left out by the State, Taken in by the Region? Explaining the Regional Variation of Healthcare Rights for Undocumented Migrants in Italy, Spain, and Switzerland

The interaction of norms of democratic inclusion in multi-level states might lead to divergent ideas about citizenship and rights across different territorial levels of government. Theoretically, it could be imagined that a person is treated as a citizen with full social rights by the regional authorities, while having no legal citizenship status in the state. By focusing on health care rights for undocumented migrants in six regions of three multi-level states (Geneva and Zurich in Switzerland, Tuscany and Lombardy in Italy, Andalusia and Madrid in Spain), this paper sets out to answer the following question: Do regional governments in multi-level states modify access to public health care for undocumented immigrants and, if so, why and how? The findings demonstrate that territorial differences within countries are as relevant as those that exist across them. The argument of the paper is that highly differentiated territorial traditions shape citizenship architectures in multi-level states, therefore producing a variety of membership rights that change depending on which region of the state a person inhabits.