Wednesday, February 29, 2012
A comparision of social assistance in Norway with other European countries.
1.1 Social assistance
2.0 Placing social assistance on the agenda
2.1 The number of young people under long term unemployment
2.2 The number of single parents are increasing
3.0 Social assistance in Norway
4.0 Similarities with other countries
5.0 Differences with other countries
5.1 National arrangements
5.2 One or more support arrangements
5.3 Rights orientated versus condition orientated social assistance
5.4 Degree of legalization
5.5 Local or central responsibility
6.0 Four European traditions of social assistance
6.1 The Nordic tradition
6.2 The Latin tradition
6.3 The Continental tradition
6.4 The British tradition
This essay is written as an assignment for Oslo Summer School in Comparative Social Studies 2003. The course was carried through in the week of July 28th to August 1st 2003 with Professor Ann Shola Orloff from Northwestern University Evanston, USA, as lecturer. The subject for the course was Comparative Studies of Welfare States: Gender, Class and Politics.
I have chossen to write about social assistance in Norway and compare it with other European countries. Therefore the title:
“A comparison of social assistance in Norway with other European countries.”
The reason for this choice is that I have worked with social services in Norway for nearly twenty years and know this system relatively well as a practitioner. I wanted to become more ingrossed in the more theoretical sides of social assistance and try to put it in a larger context by comparing it with other European countries. The essay is descriptive in form, and I have therefore not written a conclusion in the end. My intention has more been to write a series of reflections over social assistance, rather than draw a final conclusion.
It has been necessary for me to use other literature than on the booklist from the course in order to write this essay. I have tried to use Norwegian literature and put it in connection with the booklist from the course. In a part of the essay I have used research done by the Norwegian social scientist Ivar Lødemel (1992b, 1997), and tried to connect his conclusions with those of Gøsta Esping-Andersen (1990, 2002). I have also tried to take care of the gender perspective from the course, which has been most usefull for me to view my social work practice and theory in a new way.
1.1 Social assistance
My first job as a newly qualified social worker was as executive officer in a Norwegian social service department with about 35000 inhabitants in the community. When I began working here in 1980, it was together with two other social workers and one executive leader. This was sufficient to give help to those who needed social assistance and there was also ample time to give help to those with alcohol problems and those with child welfare needs.
Twenty years later, in 2000, the same office had sixteen executive officers working with social assistance applications, four others working with those with alcohol/drug problems, sixteen were employed to work with child welfare needs in the community, and in addition four employees working with refugees and those applying for political asylum. There was still only one executive leader of this same office, but had now forty employees instead of three. The population in the community was about the same as in 1980.
In the last twenty years the number of employees at this office had increased from three to forty. In addition to this “explosive” development, we find that the jobs are more specialized, there are many new professions and the office has tried many organizational changes. The social service offices in Norway were not prepared for this rush of new clients in the late 1980´s. Social service executive officers had to solve crises that were caused by the lack of accessibility and accumulation of social assistance applications (Thomassen, 1995).
Most social service offices have today executive officers that work only with social assistance applications. There is put special demands on the applicants. They should first of all be “worthy needy” (i.e. in need of help in a way that is acceptable by the community). There are put certain conditions to those receiving help, the applications are treated on an estimate opinion and the use of social treatment to “help” the applicants of social assistance is still of great importance. Social assistance says in many ways something about attitudes in the society towards individuals and families who want and/or need to be dependent upon public benefits.
In this essay, I will place weight on what is similar between social assistance in Norway and other European countries and thereafter describe what is different. To be able to understand why social assistance in Norway is so different from many other countries, I will look closer on the development of poverty laws in different countries and the development of National Insurance systems. It is the historical background, which gives the social service office objectivity as an institution. Institutions have always a history, which they are a product of. An institutional world is therefore conceived as an objective reality. But it is important to remember that social assistance offices, as all other institutions, are “man-made” objectivities, constructed realities. The institutional world can be understood as objective human activity, built by people and changed by people (Berger and Luckman 1966, Latour 1987, Barnes, Bloor and Henry 1996). This implys that institutions that we build can also be changed, a change that is often needed in an ever changing society. Gail Lewis (2000) says that the
“Changes over the past decade in the shape, practices and modes of co-ordination of the welfare regimes, and the `racial´ and gender formations which are both constituted by, and constitutive of it, suggest that just a shift is ugently needed” (p. 17).
2.0 Placing social assistance on the agenda
There are few comparative analysis of social assistance. There is written much about National Insurance systems, but relatively little is written about social assistance. Comparative studies on welfare have often not included social assistance, but are mainly concerned with the National Insurance systems. Social assistance has been looked upon as something less important. In quantity it is also marginal in comparison to the National Insurance system.
The increasing focus on social assistance in the last decade is mostly due to fact that the development “exploded” so to speak in the 1980´s in most European countries. From 1980 to 1991 the amount of people receiving social assistance in Norway increased three-fold, from 60000 to over 165000. The number of social assistance applicants per one thousand inhabitants increased from fifteen in 1981 to thirtynine in 1991. Measured in fixed prices, social assistance payments have increased seven-fold, to three and one half billion Norwegian kroner in 1991 (Hjelmtveit 1993).
In Germany the number of people receiving social assistance increased with two million from 1973 to 1990. In 1991 almost four million people received social assistance. The number that received social assistance for their daily living increased with three hundred per cent from 1973 to 1990. This is in 1990 equivalent to six per cent of the whole population in Germany. Almost twenty-five per cent of the receivers of social assistance in Germany were foreigners in 1991 (Stjernø 1995 a,b).
This development is due to several factors. One factor is that unemployment leads young people, without the right to unemployment benefits and unemployed that loose their benefit rights, to social assistance. A second factor is that changes in family forms contribute to an increased number of single parents that apply for help. A third factor is that the way National Insurance is constructed has lead to a decrease in the number of elderly people that need help, but also to the fact that constantly more young people and single parents do not have the right to other benefits than social assistance. Building down the National Insurance system leads to an increase in the number of people that have to apply for social assistance (Stjernø 1995 a,b).
The strong growth in use of social assistance does not only reflect a growth in unemployment. It reflects also an increase in social misery, broken homes and youth with a problematic childhood. In the following I will discuss the situation for young long-termed unemployed and single parents. Social assistance can in many ways be used as a “society barometer” because it says something about the development in the societies in the different countries. It does not only say something about who receives social assistance, but also which attitudes prevail in the society towards certain groups. Nancy Fracer (1994) comments about this when she writes about the antipoverty principle under gender equality:
“The first and most obivous objective of social-welfare provision is to prevent poverty. Preventing poverty is crucial to achieving a gender equity now, after the family wage, given the high rates of poverty in solo-mother families and the vastly increased likelihood that U.S. women and children will live in such families. If it accomplishes nothing else, a welfare state should at least relieve suffering by meeting otherwise unmet basic needs. Arrangements, such as those in the United States, that leave women, children, and men in poverty, are unacceptable to this criterion” (p.596).
2.1 An increasing number of young people are long-termed unemployed.
The unemployment rate among young people in Norway is considerably higher than in the population in general. The unemployment was seventeen per cent in the age group sixteen to nineteen years and eleven per cent in the age group twenty to twenty-four in 1991 (Hove 1992).
Young people have to apply for social assistance because they are not able to achieve a right to unemployment benefits and do not have the same access as the elderly to rehabilitation and disablement pensions. People without higher education dominate social assistance statistics. Almost half of all twenty-four year olds with only primary school received social assistance in 1994 (Stjernø 1995 a).
Those who are young and long-termed unemployed were the big challenge in the 1990´s. This is a situation that is the same all over Europe. In Spain the problem is even greater than in Norway where over forty per cent of the young people are unemployed. These live for the most part at home wwith their parents and receive a unemployment benefit financed by the state. In Italy, among the unemployed 20-30 year olds, ninty per cent depend totally on parental support (Esping-Andersen 2002). In Norway on the other hand the young long-termed unemployed would most probably receive social assistance from the community. This is because they have not developed the right to unemployment benefits or that they have lost the right to unemployment benefits just because they are long-termed unemployed.
The number of young people who receive social assistance in Germany are on the same level as in Norway, but the causes are different. There are probably two reasons for this. First there is the principle of subsidizing, i.e. parents have the duty to help their children economically also after that they come of age. The social assistance law in Germany emphasizes that social assistance must be focused on the family. It must stimulate the families ability to self-support and strengthen the solidarity in the family. This implies that families with children and youth more often receive social assistance than in Norway. In 1963 about one per cent of all children and one per cent of all young people lived in households that received social assistance. In 1989 the number has climbed to respectively six per cent for children and four per cent for young peple. This is primarily due to an increase in unemployment. Secondly, the apprentice system is well developed and makes an easier transition between education and occupation possible. Germany has to a greater extent than Norway succeeded in bringing youth back into the labour marked. Even though unemployment also here has been a problem, the transition between education and occupation has been easier. This is foremost due to a well developed system with apprentice schools and apprentice arrangements (Stjernø 1995 a,b).
2.2 The number of single parents are increasing.
Single parents, especially single mothers have reached the top of the political agenda in many western countries during the 1990s (Lewis and Hobson 1997). We see that single parents have frequently poorer living conditions than other groups in the population, and single mothers have poorer living conditions than single fathers. Constantly more children grow up in families with just one breadwinner, often single mothers, and these children are exposed to growing up under harder times than others. This means that one considers children in this group of the population in Norway as those with the weakest family economy (Hovden 1995).
We see at the same time that demans for what we call a good life is rising. In this way strong families are harmfull for our well being, but at the same time they are threatened. This is what Esping-Andersen (2002) calls a new paradox in our time in the welfare state. We see clearly a polarization between income poor families and resource strong families. Esping-Andersen is especially concerned with the situation that poor children live under. The inter-play between parental and societal investments in children’s development is crucial. In a life course perspective we see the real importance of investing in the well-being and resources of children (Esping- Andersen 2002).
In spite of the fact that over sixty per cent of single parents receive benefits from the National Insurance system in Norway, it is also this group that most often receives social assistance. Full transition pension for single parents corresponds to the National Insurance systems minimal pension. There are still relatively more single parents with poor economy than amongst others that receive minimal pension rates. Relatively few with retirement pension say that they have poor economy. In 1991 five per cent of couples with children had problems with daily expenses and twelve per cent were not able to pay a unforeseen bill. Amongst single parents, on the other hand, twenty-five per cent had difficulties with daily expenses and almost sixty per cent would not be able to pay an unforeseen bill (Dahl 1994).
The increase in number of single parents has strongly contributed to the increase in social assistance (Von Oorschot and Schell 1991). Twenty-three per cent of all single parents received social assistance in Norway in 1990. Sweden had in the same year thirty-five per cent of all single parents receiving social assistance. While in Germany forty-two per cent of all single parents received social assistance. The reason that so many single parents receive social assistance in Germany, is that there is not a arrangement for transition pension for them, the way it is in Norway. At the same time there is a high unemployment rate amongst women. The combination of universalism and more generous pensions and the transition pension for single parents, lead to the fact that fewer apply for social assistance in Norway (and the other Nordic countries) than in the occupation orientated pension system in Germany. The lower unemployment rate in Norway has also played an important role (Stjernø 1995 a).
Single parents are a type of family that often are poor and with a vulnerable economy in all the European countries, but it is also a group, which is growing very quickly. In Norway the number of receivers of expanded child pension increased with about fifty per cent from 1981 to 1992, from 69000 to 103200. This means that in every fifth Norwegian family with children under the age of sixteen years, the father or mother was alone with the daily care for the children (Rønning 1995). This development continues and is an enormous international challenge. O’Connor, Orloff and Shaver (1999) say that
“The US welfare state is often excoriated as one inimical to the needs of women and their children. The ‘feminisation of poverty’ (meaning the high proportion of the poor who are women or children in households maintained by women, and impling their high rates of poverty) and the despised status of ‘welfare’ in politcal circles and in popular culture have been invoked to illustrate the ways in which the United States does not care for the poor, and for poor women and their children in particular” (p. 3).
It is not sure that child benefits alone are sufficient to eradicate poverty. Denmark and Sweden provide unusally generous benefits, but for a mother with two small children they amount to only twenty per cent of the average wage. In Southern Europe single mothers have fewer labour market skills and experience than in the Nordic countries, where we also find better earnings which help single mothers get employment and therefore get over the poverty line (Esping-Andersen 2002).
3.0 Social assistance in Norway
Economic social assistance in Norway today is regulated by the law of social services from January 1st 1993 and is a continuation of law of social care from 1964. Social assistance has a long history in Norway with roots all the way back to the laws of Gulating and Frostating (from before the year 1000) and latter in the Magnus Lagabøters Landlaw from 1270. These laws gave a set of rules where the family was considered a collective unity which insured mutual benefits between generations. The mutual pension systems in the family built therefore not only on a moral principle. There where legal obligations, which the family members had not only within the nuclear family, parents and children, but also within the collective family. In many parts of the world the large family still is an economic community and the basis for economic safety (Kluge 1979).
The main objective with social assistance in Norway is to secure all inhabitants an economic security, but shall at the same time be a subsidiary and temporary benefit. This means that it is assumed that everyone uses all possible resources to take care of oneself. Before social assistance is considered, it must therefore be made evident if it is possible to get work for the applicant or if there are other rights which can be made effective.
The rules for economic social assistance in Norway are characterized by an optimistic rehabilitation and treatment ideology (Terum 1993). Help shall primarily be given in order to make the applicant self sufficient and independent of social assistance in the future. The aim is in other words to solve the underlying social problems to the individual or their families.
The intention is also that the law should function as a social safety net that catch those who need help where other helping arrangements are not sufficient. The law is also built on a principle based upon individual considerations of individual clients or family needs. Cooperation with clients is an important factor and help shall primarily be given as an offer, not an order. It is also an intention in the law that causes for the need for help shall not have any importance. When the applicants´ situation is such that the conditions for giving help is present, help shall without consideration of whether or not the applicant is “guilty” of putting him-/herself in the situation that has come into being.
Law of social services build on the principle of autonomy for the local authorities. Social assistance shall be a municipal benefit and the local authorities must finance the help inside their income frames. The local government stands free to choose for themselves which level the help is to have, as long as the help satisfies the laws demands.
The guidelines are general and build on considerations from case to case. There are therefore a large part of opinion in back of social assistance. There are large variations in way municipals use social assistance. Instead of a detailed frame of rules that states what kind of need situations that release the right for help, the law states principles for when economic help is important to give. The law demands estimate considerations done by political chosen laymen, we see today that social workers have been delegated power to take choices in most client cases. We see therefore not only large variations between municipals, but also from social worker to social worker in the same social assistance office (Lødemel 1992 a).
Many things seem to indicate that the social assistance arrangement in Norway not only is about rules for whom shall receive help or how much one may receive, but also how difficult it is to achieve contact with the social assistance office. In the last decade social assistance as a safety net has been weakened by a reduction in the rates for social assistance, the rules for receiving social assistance has become stiffer, the social assistance office has become less accessible and there is a risk for increased stigmatising. Such signals can imply that there is a general reduction in social assistance in Norway (Stjernø 1989).
4.0 Similarities with other European countries.
Ivar Lødemel (1992c) has in an article on social assistance compared the social assistance arrangement in the European welfare states and come to the conclusion that there are many similarities. A social assistance system which should prevent poverty and create more income security was found in eight of the twelve EU countries in 1992 (Belgium, Danmark, Germany, Ireland, Luxembourg, Netherlands and England). In six other countries that in 1992 where not members of EU but economic co-operating countries with EU was also found to have such arrangements (Austria, Liechtenstein, Switzerland, Finland, Norway and Sweden). In all these countries the state had a responsibility to give economic help. Esping-Andersen (2002) says that welfare reforms have also succedded in creating more income security, a less unequal distribution of income.
The similarities within these countries are gathered in the following points:
-All social welfare must be subsidiary. This means that there must be taken into
consideration which economical resources the applicant has and that one must try other resorts for help before social assistance can be given. This is called the subsidiary principle.
-The help is mostly universal, i.e. that it applies to all that can not care of
-Social assistance shall cover the general expenses for daily living.
-There is often given room for covering special needs as supplementary help.
-The help is usually time limited.
-The help is means-tested, i.e. that there is done a consideration og individual
and family needs before giving help.
-In calculating economical support a consideration is done about the applicants
own economy, savings, salary, pensions, etc. Social assistance is subsidiary to the applicants’ own resources.
-Social assistance is tax financed and not insurance financed.
-The economical help is primarily given as a contribution and only as an
exception as a loan.
-Applicants must, as a rule be active in seeking employment.
-Most often it is required that the applicant shall be reintegrated in the labour
marked and social life in general.
-There is often given supplementary help from voluntary charity organisations
(Ivar Lødemel 1992c).
5.0 Differences with other European countries
Even though there are many similarities between Norwegian social assistance and many other countries, there are also many differences. To be able to understand why social assistance in Norway is so different from many other countries, it is important to look closer to the development of Poor Laws in the various countries and on the development of National Insurance arrangements. In addition to different traditions for helping the poor and different developments of social welfare systems, we also find different cultures between the countries considering e.g. attitudes to individual responsibility and to the poor (Lødemel 1992c). I will come back to the different explanation models after first describing five main subjects that Lødemel (1992c) uses to divide the social assistance arrangements between the different countries.
5.1 National arrangements
The right to a guaranteed economic security net is a cornerstone for modern European welfare states. Lødemel (1992c) says that there are fourteen European countries that have a national arrangement that secures the individuals right to a guaranteed economic security (Austria, Belgium, Denmark, England, Finland, France, Germany, Ireland, Liechtenstein, Luxembourg, Netherlands, Norway, Sweden and Switzerland). In countries like Spain and Italy there are great gaps between the rich and the poor and in these countries there are not national arrangements. In northern Italy, which is the richest part of the country, there is a regional social assistance arrangement. A few other countries have social assistance arrangements that apply only to special categories of the population (Lødemel 1992c).
5.2 One or more subsidy arrangements
Germany and Norway have a social assistance arrangement that is a general “all-round” covering system. Other countries like e.g. France have a large general system combined with many different arrangements that cover the “rest categories”. England, Ireland and Belgium have developed a third way of doing this by having many different supporting arrangements that cover the different categories and that these arrangements together give a “all-round” covering system (Lødemel 1992c).
5.3 Rights- versus condition-orientated arrangements
Norway has gone far in introducing conditions attached to social assistance. Many European countries are about to follow this principle. Conditions for receiving economic help can be that the applicant must sign an agreement that involves that the applicant over a period of time (usually about six months) must participate in a training program combined with individual consultation and other social services which are supposed to correct the causes for the different problems that the applicant has. This arrangement gives many possibilities for sanctions. If the applicant does not hold his/her part of the agreement, the economic help can be reduced or denied (Kjellevold 1995).
Denmark, Finland, France, Germany and Sweden have also a similar condition-orientated social assistance arrangement. Denmark has gone far by ordering the public services to give a offer (e.g. work, education, training) and not just address demands on the applicant.
The United States has also a fundamental attitude, which says that if one is dependent on public benefits, than one should work for them. The United States has developed an enormous public apparatus for administrating “work for social assistance”, also called “workfare” (Lødemel 2001). The arrangement is however so expensive to administrate that the United States are now cutting down on this arrangement.
England has gone very far in the opposite direction by making the arrangement rights-orientated. There are not made any other demands on the applicants than to document that they are active in seeking employment. Social assistance arrangements are separated from social work practice and are administrated from special offices.
5.4 Level of legalisation
France and Germany are those countries that are most detailed in their legislation. They try to catch all the categories of different needs for help. The German law for social assistance is e.g. over two hundred pages long, while the Norwegian law is about twenty pages.
Denmark, Finland, Sweden and Norway are those countries that are least detailed in the legislation. In the Norwegian legislation the law of social services is a safety net that shall catch all whom “fall outside”. This is contrary to the German legislation, and can be described as an open system and gives room for estimated decisions. This implies also that those who use their opinions to make estimated decisions are given much power and the possibilities for complaining become less when everything is clearly defined in the legislation. The legal framework in social assistance law also becomes underestimated in administrative procedures because the decisions are often given the applicant orally and there is given little information about the applicants rights and administrative procedures (Molven and Vetvik 1986).
5.5 Local or central responsibility
Norway and England have both a central legislation, but England has also a central administration and a central financing. Norway has on the other hand a local administration and a local financing. Austria has a regional legislation, a regional administration and a local financing. Germany has a central legislation, a regional administration and a mixture of regional/local financing. Spain has a regional legislation, administration and financing. Italia has a local legislation, administration and financing. Netherlands has a central legislation, a local administration and a local financing (Stjernø 1995b).
Steinar Stjernø (1995a) says that it is to coarse to catch the differences in social assistance between countries just by looking at the degree of centralisation or if social assistance main content is social treatment or wage guarantee, the way Lødemel does.
Stjernø (1995a) will place the countries according to nine dimensions that are attached to the care for the poor. These dimensions are the level of local autonomy, national norms, generosity, family subsidiary, possibilities for complaining, political participation, voluntary participation, connection between contribution and therapy and finally the connection between contribution and work. He states that the most important differences are to be found in the connection between central or local structure, generosity and legal insurance in the system and to the connection between money and social treatment or work.
It can be maintained that the classification to Stjernø is to extensive and that the different dimensions do not let themselves compare with each other. How can one e.g. compare the dimensions generosity and political participation to each other, or family subsidiary and the connection between contribution and treatment? It will most likely be difficult to compare such dimensions over country boundaries without taking cultural considerations. Attitudes to political participation, generosity, etc., are different form country to country because of cultural and historical reasons and can not be simply compared with each other over country boundaries.
Even if Stjernø can be right in that the classification of Lødemel is to gross, it is a classification that makes it possible to compare countries with each other on a gross scale, something I find hard to do with the classification to Stjernø. It is too detailed, unvaried and does not take into consideration the cultural differences in understanding the nine dimensions. I will below therefore go further describing the divisions that Lødemel (1992b) uses in his somewhat gross classification.
6.0 Four European traditions for social assistance
Poverty and social exclusion is a increasing problem in all of Europe. More and more are dependent on the public welfare system. Lødemel (1992b, 1997) starts with an analysis of welfare states and divides comparative welfare research in three main models:
A. Residual, industrial and institutional models for welfare (Titmuss
1974). Examples of this in Norway could be respectively the Poor Law of 1845, supplemental pension from 1967 (pensions are calculated out from earlier labour wages) and old age pension from 1957 (a universal arrangement). This model sets focus on national experience.
B. Social divisions of welfare (Ginsburg 1992), where three welfare
sources are defined; private insurances, employers tax system (through different deduction rules) and through national or other public arrangements. Also this model focuses mostly on national arrangements.
C. Welfare regimes (Esping-Andersen 1990) focuses on how one can
gather together different countries with similar welfare traditions in clusters. It is customary to see similarities between the Nordic welfare systems as a cluster or welfare regime. This model treats many of the same topics as the two previous, but focuses mainly on a comparison of different countries with other. Esping-Andersen divides regimes into three welfare traditions. These are the marked-liberal tradition, the conservative tradition and the social-democratic (middle class universal) tradition. The division as Lødemel (1992b, 1997) has made has many similarities with the welfare tradition to Esping-Andersen (1990).
One of the main topics Esping-Andersen (1990) is that there has been and still is a powerful movement in society from wagework to “paid non-work”, through different kinds of welfare arrangements. Esping-Andersen calls this for “decommodification of labour through welfare” (1990, p.35). Welfare arrangements are really the same as National Insurance arrangements, but Lødemel (1992b, 1997) uses Esping-Andersens´ model to describe what he calls poverty regimes (divisions) and focuses in this way on the different social assistance traditions. He divides between four different traditions in Europe. He has reached these divisions by comparing the level of centralization (local versus central) and social assistance main contents (social treatment versus maintaining wages) in the different countries. The results are that the countries collect themselves in four clusters out from similarities. Esping-Andersen (1998) insists that we understand welfare states as clusters of regime-types, and that their development must be explained interactively. We must also recognize that no single case is pure. The social-democratic regimes of the Nordic countries are for example a blend of crucial socialist and liberal elements.
6.1 The Nordic tradition
In all of the Nordic countries social assistance is regulated through a national “frame” legislation. The authority to make decisions is delegated to the local administration. Sweden introduced national standards for social assistance in 1982, Finland in 1984 and Denmark in 1987. This gives the administration less authority to make estimated decisions and strengthens the applicants’ lawful rights. Norway introduced national standards for social assistance in 2000, but here it is still up to the local governments to decide whether they choose to follow these standards or not. Norway is the Nordic country that is most cautious with benefits and shows the highest rate of variations in how the applications are considered. Norway may be the country in Europe that to the largest extent has kept the Poor Law as a helping arrangement for those who need help because they have fallen outside the National Insurance system (Lødemel 1992b, 1997).
The Nordic tradition builds on what Esping-Andersen has called social-democratic or middle class universalism. This tradition has developed the highest rate of “paid non-work” through the National Insurance. Even though the Nordic countries have the best developed pension systems in Europe, these countries have a social assistance, which emphasizes a strong social control and treatment. The executive officers have a double role to play, both bureaucrat and therapist. Lødemel (1992b, 1997) describes therefore the Nordic countries as a residual poverty regime.
Lewis and Hobson (1997) say that the current wave of feminist research has revealed the weakness of Esping-Andersen (1990) references to “decommodification” in his study of welfare states, for understanding gender differences and has proposed alternative framworks that reveal gendered policy logics. In seeking a dimension of social citizenship that goes beyond decommodification, feminist scholars have framed gendered social rights around the category of single mothers, that is the right to form an independent household without the risk of poverty and marginalisation. Orloff (1993) has suggested that
“The decommodification dimension could be subsumed under more a generic dimension measuring independence or autonomy, that is, it would indicate individuals’ freedom from compulsion to enter potentially oppressive relationships in a number of spheres” (p.320).
6.2 The Latin tradition
Lødemel (1992b, 1997) describes only France as an example on the Latin tradition, but means that France will serve as a model when other Latin countries develop national arrangements for social assistance. France was the first Latin country to have a central legislation for social assistance in 1988, with a fixed national standard. Help is intended foremost for marginal groups in society and it is a national objective to have control and give social treatment. It is difficult to find common trends in the Latin countries because most of them have newly begun to work with national arrangements. It might show that there are large internal differences here, which make it difficult to group the Latin countries in a rest-category. Esping-Andersen (1990) has not included these countries in the European welfare regime. Lødemel (1992b, 1997) has chosen to call the poverty regime in the Latin tradition for the national regime.
6.3 The Continental tradition
The social assistance arrangement in Germany, Austria, Netherlands, Luxembourg and Belgium have many common features. All of the countries have common social assistance legislation and a number of benefit arrangements for specially defined groups. These make together a unity helping-arrangement, and does not function as different systems as they do in France.
In Germany the Poor Law was replaced with a social assistance law already in 1962 and confirms that those who can prove that their income is under a certain standard, have the right to social assistance. The law is very detailed and is here different from e.g. the Norwegian legislation. The law does not give much room for estimate considerations. This implies that there are few educated social workers in the social assistance officers with responsibility for social assistance applications. This is taken care of by others in the administration. The Continental tradition divides between economic help and treatment due to the break with the Poor Law, while Norway has kept this connection.
The Continental social assistance arrangement is more rights orientated than both the Latin and Nordic arrangement. But the arrangement also emphasizes a strong subsidiary principle. All other possibilities must be tried before social assistance is given, and the families’ responsibility to give help is very strong. This implies that applicants must first seek help with their grandparents, parents, brothers and sisters, children or other family members before the public gives economic help.
The Continental tradition follows what Esping-Andersen (1990) calls the conservative welfare regime, which has its most important roots in the Bismarck tradition. Fürst von Bismarck (Otto Eduard Leopold Bismarck Schönhausen) created the German Empire in 1871. In his quest to stop the socialist advancement, he introduced a number of social reforms, among other things; sickness pension, old age pension and insurance against working accidents. The states responsibility is to help the factories take the social responsibility for their employees. The conservative Continental welfare regime is market orientated and has therefore a job based understanding. The market is effective in a economical way to loose ones employment has a much more discipline effect than in Norway. This implies that the poor become “resourcefull”, because they show how it goes if you do not work. This dividing understanding of poverty in society is why Lødemel (1992b, 1997) calls Esping-Andersens description of the conservative tradition on the Continent for the differentiated poverty regime.
The conservative Continental tradition is contrary from the Nordic tradition, “fatherly” in its understanding of e.g. wage conditions. Wages are decided by social considerations and not by competition circumstances. A man must have so much in wages so that his wife can stay at home with their children. Most pension benefits, including child pension, is paid to the man in the family.
Such attitudes in the society are important in order to understand why social assistance arrangements are so different from the Norwegian. Social assistance must be kept so small that it is not possible to live on it alone. Social assistance for daily living expenses make out just nineteen per cent of the average net industrial-worker wage. Even if social assistance in Norway seems low, by seventy per cent of the minimal benefit from the National Insurance, it is very generous compared to the German social assistance (Stjernø 1995a).
6.4 The British tradition
The Poor Law in England from 1834, which had replaced the previous Poor Law from 1601, was abolished in England already in 1948 and replaced by a national organised and state financed social assistance arrangement (Lødemel 1992c). The English Poor Law from 1834 (New Poor Law) had been an important starting point for the development of social assistance in all of Europe. England is now the first country that has most developed a standardizing of this form for help, which is managed by offices for this purpose and is divided from social work practice, also because of the social assistance reform from 1966. This reform came due to an explosive development (a doubling in the first ten years after WWII) of the number of old people and disabled who received social assistance, a development, which was the other way round in Norway and many other parts of Europe. In Norway we find that the number of social assistance applications was halved from 1945 to 1965. Social assistance was before 1966 means-tested, but made the arrangement completely rights-orientated. England is without a doubt the country in Europe, which has the most rights-orientated and wage maintaining social assistance arrangement.
Norway has chosen to develop slower and more gradual than England. In Norway the National Insurance system became rights-orientated and financed by the state through taxes. England has developed an insurance-based pension system and made social assistance rights-assistance orientated. Norway has seen more pragmatic on making social assistance rights orientated and instead chosen to develop a pension system that is universal. It is the pension system that defines the quantity of clients and who that can be clients. It is these two factors that also has contributed to factors that also has contributed to make a foundation for social assistance. In Norway there is e.g. very few elderly who receive supplementary social assistance because the pension level should be sufficient for daily living. There are however very many single parents that are not able to live on pensions alone and receive supplementary social assistance. This can mean that the most important activity one can do to get this group away from social assistance arrangements is to increase vigorously the benefits from the pension arrangements for this group.
Esping-Andersen (1990) describes the British traditions as characterized by a marked-liberal tradition. This implies that work is seen as a product and that wages should be created through supply and demand. Public pension arrangements therefore become “dangerous”. The reason for social politics become moral questions because they are pointed to increasing the supply of work through just offering an alternative support to those that can not work. People who unwillingly and undeserved do not get work shall receive social assistance (before called help to the poor). This social policy has roots in the Beveridge plan from 1942. It was this British economist, liberal politician and director at the London School of Economics, William Henry Beveridge who got approval for his proposals for extensive pension reforms which to a large degree has influenced later social legislation. The arrangement builds upon pensions that shall be based on the insurance principle. Everyone should pay the same and receive the same. This is also called “The Flat Rate Principle”. The thought in back of this was that “a convoy can never go faster than its slowest ship”, or put in a more marked-liberal way, a society can not develop faster than the poor can be able to pay their share. This made it possible for private insurance companies to be able to come with offers to those that could pay for private insurance arrangement (Lødemel 1992b, 1997).
The benefits from social assistance in England is so low that it is not possible to make a daily living of it. It is to be a weapon against poverty, but has not been able to secure welfare to the receivers. This last element is entrusted to the insurance marked. Lødemel (1992b) describes therefore the British tradition as the institutionalised poverty regime. Zsuzsa Ferge (1997) says that
“The dream of the ‘good society’ – the ambitious plan of Beveridge, the ideal welfare state – never fully materialized. Instead there have been different types of ‘welfare states’… attaining varing degrees of success in the pursuit of such grand objectives as the eradication of poverty of the redustion of inequality” (p. 21).
The different developments of pension arrangements in England and Norway is one of the main reasons that the social assistance arrangements are so different. When the pension system failed in England, the social assistance system was built and made rights orientated and opened the pension marked for pension companies. In Norway the development of pension arrangements are very successful and left behind a social assistance system for the poorest in the society that fall outside the National Insurance system. The arrangement is administrated and financed by local authorities who can choose if they want to fallow a national recommended to regulate level for social assistance. The social services law gives the executive officer much power to make estimate decisions and therefore puts the legal rights to the applicants in danger. In many ways it is correct to say that Norwegian social assistance, compared with other welfare states, is the arrangement that to largest degree has preserved the poverty ideology which characterizes the Poor Laws in the 1800´s and which all the other European countries has abolished after WWII.
This essay has focused on describing social assistance in Norway and compared it with other European countries. As a social worker I have experienced how social assistance has “exploded” in the last two decades. I have looked at two probable causes for this development, the increasing number of young people that are unemployed and the increasing number of singel parents. In comparing social assistance in Norway with other European countries, I have used research done by the Norwegian social scientist Ivar Lødemel together with the research done by Gösta Esping-Andersen. My reflections show that social assistance in Norway is perhaps the arrangement that to the largest degree has perserved the poverty ideology from the Poor Laws.
Kaare T. Pettersen 2003
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 There are different ways of translating the Norwegian word ”trygd”. In England one speaks of e.g. that an employee is entitled to unemployment benefits, or that mothers can receive children´s allowance, the unemployed will maybe say that it´s no fun being on the dole, or that someone has been on welfare for many years. In the United States one calls national benefit arrangements for social security and this system is in England called National Insurance. I will in this essay use the British word National Insurance as a translation for the Norwegian national “trygde” system.
 The poverty line is often understood as fifty per cent of medial wage. EU has recently moved the poverty line to sixty per cent of medial wage (Esping-Andersen 2002). There are also many other ways of describing poverty, which shows that understanding poverty is a question about values, but this is a discussion not taken in this essay.
 Esping-Andersen (1990) says that “de-commodification occurs when a service is rendered as a matter of right, and when a person can maintain a livelihood without reliance on the market” (pp. 21-22). Orloff (1993) argues that “decommodification” inaccurately describes women’s relationship to the welfare state. Esping-Andersen (1999) says this is because women’s work is often unpaid family labour.