[Strengths and challenges of citizens' participation in local health councils: the cases of Italy, England, and Brazil].

This paper focuses on three models for citizens' participation in health (Italy, Great Britain, and Brazil). After discussing the strengths and weakness of the three experiences, the study presents a comparative analysis, highlighting convergences and variations in relation to the main characteristics of social participation in the health sector: (a) organization and composition of health councils; (b) functions played by citizens' representatives (decision-making, advisory, or social control or oversight); and (c) approaches to community participation. The paper then focuses on two critical points emerging from the analysis of experiences with community participation: the issue of representativeness and the difficulty experienced by representatives of health services users in influencing the decision-making by system managers.