 At least as compared to pure politics or the “free market”, using CEA with a metric such as QALY for rationing the use of health resources has the strongest claim to rationality. But what of its ethical acceptability? Even strong advocates of using CEA to ration health resources acknowledge that it suffers from at least five fundamental (and interconnected) ethical concerns. Some of these concerns only make sense at the population level of meso-allocations, but all affect, directly or indirectly, allocation decisions at the individual level (Daniels 1993, 1994, 1998; Brock 1995, 1998; Brock &amp; Wikler 2006).