Special Issue: Shifts in Nordic welfare governance â governing ..... In Germany, a social insurance scheme was introduced by law on the central level valid for.
Multi-level governance and universalism: Austria and Germany compared Hildegard Theobald, Vechta University In: Burau, V./ Vabo, S.I. (eds.) Special Issue: Shifts in Nordic welfare governance – governing old age care beyond welfare states and consequences for universalism. International Journal of Sociology and Social Policy, 2011, Vol.31; Iss: 3 / 4, 209-221.
Abstract Purpose The article compares the establishment of universal long-term care schemes within the framework of multi-level governance in Austria and Germany. With the introduction of the schemes, in both countries a new but distinct type of universalism was defined based on certain policy designs aiming to reduce the expected cost increase. The care gaps related to the policy design triggered the emergence of migrant carers within the family context and the ensuing debates and policies. Policies and debates are shaped by the country-specific interplay of social actors and their ideas within a system of multi-level governance. Design/methodology/approach Conceptually, the paper combines approaches within long-term care research to define significant dimensions of universalism, as well as ideas on multi-level governance and newinstitutionalism to examine the processes of policy making in a multi-level system. Empirically, Austria and Germany are selected as two representative cases. Findings The findings reveal the distinct, country-specific policy design of the new type of universalism as well as the interrelated emergence of migrant care work and the development of regulation policies. The analysis reveals the significant impact of the interplay of influential actors and their ideas, in particular related to processes of transformation of ideas into policy designs. Cross-border effects concern either the use of foreign policy approaches in the process of policy-making or the consideration of migration patterns embedded in EU or migration policies. Originality/value The interrelationship between the new type of universalism and the role of ideational processes in a system of multi-level governance, which even includes cross-border effects, has only rarely been examined. The country-specific policies show the significance of the actors and their ideas and contribute to the understanding of processes of policy-making. Key words: Long-term care policies, universalism, policy-making, cross-country comparison, migrant carers Classification: Case study
1. Introduction At the beginning of the 1990s in most Continental European countries signs of a lack of public support in a situation of long-term care needs - such as high private costs, importance of means-tested welfare payments and the dependence on family care - became evident (see e.g. Pacolet et al 2000). The problems surrounding the public and private financing of long-term care triggered an intensive political debate and the introduction of new policy schemes. The key elements in this debate concerned the question as to how a new collectively-funded social security system – including the population as a whole - can be established in a situation of welfare state criticism and fiscal constraints (Pacolet et al., 2000. Theobald/Kern forthcoming).
Germany and Austria became two forerunner countries in Continental Europe establishing new long-term care schemes until the middle of the 1990s. In both countries the schemes aim to combine universalisms, i.e. encompassing the population as a whole with the goal to limit the expected increase of public costs. The long-term care schemes were designed by the examination of already available policy schemes and led to the definition of a new type of universalism based on a mix of certain dimension of policy designs. Despite corresponding basic goals the design of the policy schemes in both countries differ considerably. Both schemes were created within the framework of a federal and corporate political system, however, related to significant differences of the impact of certain social actors and their ideas. The article proceeds on the assumption that the country differences in policy design can be explained by the country-specific preconditions and the process of transforming ideas on long-term care into dimensions of policy designs by influential actors.
Based on care gaps related to the new type of universalism, recently migrant carers who provide 24-hours care within the family context have emerged in both countries. The bottomup solutions of the beneficiaries of the long-term care schemes have inspired public debates and political regulations. The article again proceeds on the assumption that country-specific preconditions, actors and their ideas involved in the process of policy-making triggered the country-specific debates and regulations.
In order to analyse processes of policy-making, their output, i.e. the institutional design of the schemes and the outcomes for the users or migrant carers the article combines approaches set up in several strands in international comparative welfare state research (see section 1). Concepts established within the area of long-term care are used to define dimensions of universalism. Assumptions related to multi-level governance are included to define the scope for policy development. New-institutionalised approaches, which emphasise the interplay of
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actors and ideas provides the tools to examine the processes of policy development. Empirically, based on case studies in Austria and Germany, processes of policy-making with regard to the introduction of the long-term care schemes and the regulations related to migrant care work as well as policy outputs and outcomes will be analysed subsequently (see section 2). In a final section, both policy developments will be compared between both countries (section 3)
2. Conceptual framework 2.1 Dimensions of universalism The new type of universalism established in Austria and Germany aims to cover the whole population but specifies three further dimensions of institutional designs – range of risks covered, level and type of public support- which leave considerable private or family responsibility in a situation of long-term care needs. The country-specific dimensions of institutional designs were constructed based on ideas on long-term care responsibilities in the process of policy-making. In the following basic dimensions of institutional designs and ideas are outlined as tools for the analysis of the process of policy-making and its interrelationship to the policy design (see section 2.1). The outcomes of the policy design form the perspective of the people in need of long-term care will be discussed in a next step (see section 2.2 for an overview on ideas, output and outcomes see table 1).
Both, eligibility criteria and the range of risks covered determine access to public benefits and thus provide a first definition of public responsibility. Benefits can be granted universally to the population as a whole or according to economic circumstances (ascertained by means-testing) and/or depending on the family situation (Anttonen et al., 2003). The range of care risks covered, e.g., bodily care, household, social services, institutional care, and the level of care needs, serve to define the threshold for public support.
A second definition of public responsibility considers the level of public support, which determines the mix of public funding and the private/family resources required. Österle (2001) summarised ideas determining the level of support and related them to policy goals. The first goal of care policies “guaranteeing minimum standards” aims to prevent care recipients falling into poverty and provides only a minimum level of public support. The second goal, “supporting living standards”, grants a higher level of public support to prevent older adults from big drops in their individual living standards.
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The types of benefits available can be viewed as a third definition of the private/public mix. Different types of benefits have been introduced in care policies, such as cash benefits, services or leave arrangements, which deliver money, services and time for care recipients and informal carers (Daly, 2000). The different types of benefits reflect ideas of an ideal combination of formal and informal care provision. While time is provided to support care within the family framework, money enables care recipients or family members to choose whether to provide care themselves or to organise provision. Finally, the expansion of care services aims at developing professional care offers for care recipients, unburden family carers or to secure quality standards. The dimensions of institutional designs are related to ideas of a “good” care provision and adequate mix of private and public provision and funding. Related to the new type of universalism the following ideas proved to be decisive (for the discussion on ideas see e.g. Pfau-Effinger, 2004; Clarke et al., 2005).
the definition of public responsibilities related to care
redistribution between different societal groups
the mix of different societal sectors – state, market, family – with regard to care provision and funding
the role of choice and autonomy of users
2.2 Policy development, multi-level governance, actors and ideas
Due to the federal and corporatist character of the political system in both countries, the new long-term care schemes were created in a close interplay of political actors on different levels – in particular the central level and the federal states - and wider societal actors. The concept of multi-level governance provides the starting-point for the development of a conceptual framework for the empirical analysis. Research within the framework of multi-level governance exceeds the traditional analysis of intergovernmental relationships within each country in two respects (see Peters/Pierre 2010). First, multi-level governance focuses on different levels within the nation-state - local, regional and central - as well as expand the nation-state and includes cross-border influence between countries and the impact of supranational entities like the EU. Second, governance analysis also focuses on social actors in the wider society who are not part of the governmental framework.
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According to new-institutionalist approaches policy changes can be viewed as the result of the interplay of actors and their ideas embedded in institutional frameworks. In his analysis Beland (2009) emphasises in particular the role of ideational processes in a situation of welfare state change. Ideational processes are particularly significant in situations of high uncertainty, when existing institutional structures are less likely to determine the behaviour of key political actors (Blyth, 2002; Pierson, 2004; Brodin, 2005 for elder care). On the basis of a literature overview Beland (2009) defines distinct ways in which ideational processes influence policy outcomes. 1) Ideas participate in the construction of issues and problems that enter the policy agenda, i.e. they help to shape the definitions of problem and reform the agenda. 2) Ideas can take the form of economic and social assumptions that either legitimise or challenge existing institutions and policies 3) As a basis of framing processes within public discourse they can help to convince policymakers, interest groups, and the population at large. Ideas become only politically influential because they interact with powerful political actors. Political coalitions and political conflicts build the basis for institutional change (Thelen, 2004).
Research on policy development related to home care policies reveal certain specifities of the field concerning the role of actors. Burau and colleagues (2007) point out that the policy issue of home care does not easily fit into the public nature of policies precisely because home care stretches across the private/public dichotomy which weakens certain social actors. The fact that numerous actors have interests – especially with regards to the risk of care dependency – opens up the possibility of alliances between different groups that render reform possible despite the weakness of the new risk bearers themselves. This produces a diverse range of actors, including some operating from the outside and actors operating on the inside. Reform processes generally tend towards programmes favoured by the political actors who are able to exert the most influence (Taylor-Gooby, 2004).
2. Empirical section: Multi-level governance and long-term care policies 2.1 The introduction of long-term care policy schemes in Austria and Germany The analysis of the introduction of the new long-term care schemes in both countries focuses on the process of policy-making in particular on the transformation of ideas into policy design by certain actors, which explains similarities and dissimilarities of the policy designs. In both countries, the universally-oriented long-term care schemes were created within a framework of cost containment policies. Efforts to limit costs are related to the level of benefits not covering all needs and the definition of the thresholds. In both countries, a comparable threshold to benefits has been defined based on an exactly defined amount of care needs;
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such as bodily care, nutrition or mobility or assistance with household services. The longterm care schemes may be used by people with long-term care needs within all age groups including disabled people suffering severe functional impairments. Despite the similarities, the design of the policy schemes – type of support and the mode of funding differ widely between the countries. Up to the reform in 1993, the public support system in Austria was characterised by a decentralised responsibility for care support, cash benefit structures, and home-based and residential service offers (Da Roit et al., 2008). The reform incorporated two main parts. A universal oriented tax-based care allowance was established by federal law to guarantee access to cash benefits for care users on the basis of defined levels of care needs valid in the whole country. Beneficiaries can use these benefits to either purchase professional home-based services, organise care provision autonomously or to move to residential care facilities (Pacolet et al., 2000). In addition, the federal states promised to expand care services to meet demand for professional care until 2010 (Da Roit et al., 2008; Egger de Campo, 2008). In Germany, a social insurance scheme was introduced by law on the central level valid for the whole country to guarantee public support in defined situations of long-term care needs and to regulate the expansion of a care infrastructure. Up to then, within the framework of the Federal Law on Social Assistance a nation-wide scheme based on means-testing was available. In particular the increasing costs on the local levels related to residential care needs for older adults triggered the introduction of the insurance scheme to reduce local costs (Camphell/Morgan 2005). On the basis of defined levels of care needs the Long-term Care Insurance (LTCI) covers support based on free choice between cash benefits, homebased and institutional care service provision (an overview on policy outputs see table 1).
In both countries, a wide range of actors were involved in the development of the policy scheme including politicians at different state level, social partners, welfare associations and civil society organisations such as pensioners- and disability organisations (Behning 1999; Meyer 1996). Evaluations of already available schemes in other European countries reveal a transnational impact (Meyer, 1996: Evers et al., 1993). The country-specific dimensions of the policy schemes – related to the mode of funding and type of benefit - can be explained by the impact of certain social actors and their ideas, which will be revealed in the following by the analysis of the process of policy-making.
In Austria, in particular the disability movement was instrumental in shaping the design of the care allowance system. During the 1980s Vienna was made the centre for the coordination of the UN's worldwide activities relating to the situation of disabled people. The pressure on the
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Austrian government to introduce well-adapted policies for disabled people offered relevant organisations considerable leverage to influence the ensuing stages of policy development and policy design. Initial debates were dominated by the question of the type of benefit, i.e. cash benefits or in-kind services. The representatives of the disability movement preferred a care allowance scheme to enable an autonomous life on the basis of self-organised care provision. The introduction of cash payments only was supported by a wide range of different actors – the conservative, liberal and green parties - emphasising on autonomy of the users and the role of families. The council of the federal states, which had to approve the scheme, was dominated by conservative governments with a majority in favour of care within the family framework and a corresponding care allowance scheme. In the course of the discussion the emphasis was on the situation of the care users, while the working-conditions of the self-organised carers received far less attention. Only the chamber for blue-collar workers and Vienna opted for the expansion of service provision based on standard employment. The Social Democratic Party supported a mixed system of cash payments and services at the beginning, but changed in the process of policy development influenced by the ideas of disability organisations (Behning, 1999).
The type of benefits available and in addition the level of support became related to cost containment policies. A comprehensive service-oriented system, like that in force in Nordic countries, was considered as too expensive in a time of fiscal constraints (Amann, 1994). Cross-country research projects were conducted on behalf of the Ministry of Social Affairs to evaluate long-term care schemes in other European countries. Comparative studies with the Nordic approach concluded that, even in Sweden, the introduction of cash benefits was on the policy agenda to establish a sustainable system (Baldock/Evers, 1992; Evers et al., 1993). The disability movement argued for comprehensive cash benefits to cover the costs of long-term care provision, but it was rejected as not economically sustainable (Behning, 1999).
Finally, in 1991 the federal Minister of Social Affairs and representatives of the federal states agreed on the introduction of a universal care allowance scheme based on unregulated cash payments (Behning, 1999; Da Roit et al., 2008). Afterwards the discussion on the mode of funding intensified. Due to the increase of pay roll taxes the social partners rejected a social insurance scheme, while the federal states demanded that the costs for the allowance be covered mainly on the federal level. In the end, the federal government decided to establish a mainly tax-based scheme with only a small part of social insurance funding, and to cover the costs for allowances mainly by the federal tax budget. After the level of cash benefits had been legally defined it was criticised as not providing sufficient means to purchase care
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services, while a full-funding system was viewed as illusory (Kytir/Münz, 1992; Amann 1994; Behning, 1999).
Comparable to Austria, in Germany the debate during the process of policy-making centred around the issues of type and level of benefit as well as the mode of funding. The Long-term Care Insurance scheme (LTCI) was mainly negotiated within a Grand Coalition between the Social Democratic Party dominating the Council of the Federal States (Bundesrat) and the conservative-liberal government on the federal level. Due to the significance of the cost issue as starting-point for the LTCI debates on the mode of funding dominated at the beginning (see Meyer, 1996). The Liberal Party in office with the Christian Democratic Party on the central level and the employers` organisations favoured a private insurance solution emphasising individual responsibility. The Christian Democratic Party, the Social Democratic Party as well as the majority of the social democratic dominated council of the federal states and the unions opted for a social insurance solution enabling redistribution between different social groups. Only in the end, the Liberal Party agreed to a social insurance scheme under certain premises, e.g. employers had to be compensated for their share of the contribution.
With regard to the type of benefit the provision of in-kind services only, the provision of a cash payment only and a mixed system was discussed. The provision of “in-kind services only”, comparable to the health care insurance scheme, was rejected by almost all actors, as not coherent with the reality of care provision where family members, friends and neighbours contribute. The costs related to in-kind benefits only were judged to be insupportable. As in Austria, the representatives of the disability organisations voted for a system of cash payments only. In Germany, however, the care needs of older adults were in the focus of the policy development, which left the disability movement with a more limited impact. Most of the actors voted for a mixed system with unregulated cash benefits and home-based respectively residential care benefits, which was finally introduced. The mixed system aims to maintain the prevalent pattern of family-oriented care provision and to avoid economisation of family care based on a cash benefit on a lower level. Based on higher benefit levels adapted to different cost structures, the system aims to secure high-quality care by home-based service delivery and reduce the social assistance costs for residential care on the local levels. Freedom of choice for the users was related to choice between the types of services (Meyer, 1996).
At the beginning of the debate most of the political and social actors involved argued that the funding level for long-term care should correspond to the comprehensive funding level for health care. Comparable to Austria in the end the more economically-oriented actors
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prevailed. High expenditures and insurance contributions in the Netherlands, in particular, and the high public expenditure related to the health care insurance in Germany were recognised as indicators of the financial obstacles of a more comprehensive social insurance scheme (Meyer, 1996). Table 1: Universalism: ideas, institutional designs and outcomes Austria
Germany
Public-private-mix Family-oriented care Autonomous organisation of provision Possible
Public-private mix Family-oriented care Choice between different types of benefits Possible
Taxes
Social insurance
Universal
Universal
- Range or risks
Bodily care, household, social services At least: 90min.need, p. day, additional. criteria
Bodily care, household, social services At least: 90min. need p. day, additional criteria
- Type of support
Cash payments
Mix: Cash payments, homebased, residential services
- Level of support
Defined lump sum
Defined lump sum
Outcomes (2004) - Coverage Beneficiaries: Share 65+
18%
11% (2005)
- Range of risks Level: below 300€ p. month Share beneficiaries
56%
28% (2005)
- Type of support Home-based care Share beneficiaries
29%
38% (2002)
Residential care Share beneficiaries 65+
15% 3.6%
30% 3.4%
24h migrant care Share beneficiaries
5%
2-3%
Ideas - Responsibility - Family/service provision - Autonomy of users - Redistribution Output Mode of funding Institutional designs - Eligibility criteria
- Level of support Home-based services Low frequency Low frequency Residential services High private costs High private costs Sources (outcomes): Schneekloth, 2006; Huber et al., 2006; Federal Statistical Office, 2007; Steffen, 2009; Schmid, 2009; Bachmeier, 2010.
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2.2 Migrant carers: Emergence, societal debates and regulations The emergence of migrant carers within the family context in both Austria and Germany is strongly related to the design and the outcomes of the policy schemes (compare table 1). Both countries have introduced a policy scheme characterised by universally- provided lump sum benefits. Characteristic for the Austrian care allowance scheme is the comparatively high proportion of beneficiaries among older adults receiving benefits compared to Germany but more often on a low level. Contradictory to the differences, in both countries the amount and the type of care needs defined as a threshold to benefits is quite similar, however, related to distinct additional criteria. There is no systematic research available to explain the marked country differences. In both countries, cash benefits dominate, and public, homebased and institutional care provision are used more rarely. The frequency of home-based service provision is quite low and concentrated on the support with basic care provision. The use of institutional care entails considerable private costs (Egger de Campo, 2008; Schmid, 2009).
This results in a largely family-oriented care system with more informal care and a range of semi-formal and grey market activities (Schneekloth, 2006; Da Roit et al., 2008; Egger de Campo, 2008; Enste et al., 2009; Schmid, 2009). Due to the care gap related to comprehensive care needs a new segment on the grey care market has emerged; the provision of 24 hours care within the family context by migrant carers mainly from Eastern European countries, the Czech Republic, Slovakia, Poland, Hungary and Romania (Schmid, 2009; Neuhaus et al., 2009). The proportion of beneficiaries receiving 24-hour care at home from migrant carers among the beneficiaries as a whole is estimated around 5% in Austria and 2-3% in Germany (Bachmeier, 2010; for Germany own calculations based on Steffen, 2009 and Federal Statistical Office, 2009). The different construction of benefits related to the higher level of cash benefits in Austria may facilitate the employment or migrant carers. While in Germany unregulated cash benefits are granted on a low level – up to €685 - aiming at supporting family care, in Austria the higher level of unregulated cash payments – up to approx. €1700 - is independent of the type of care provision.
In both countries, migrant carers are mainly hired to take care of severely care-dependent older adults on higher income levels, where cash benefits can be topped up. The monthly costs for 24-hour care organised by an agency lie in general between €1,100 and €2,000. The care arrangement is motivated by the lower private costs compared to 24-hour formal home-based care provision or residential care or the wish to live in one's own home despite a high level of care dependency (Egger de Campo, 2008; Neuhaus et al., 2009; Lutz, 2009; Schmid, 2009).
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The bottom-up development resulted in country-specific societal debates and introduction of regulations, which can be explained by the role of social actors, ideas and the goal of regulation. In Austria, judgements defining the existing migrant care provision within the family context as illegal and the care scandal during the 2006 general election campaign, with high ranking politicians employing illegally migrant carers, provided the starting-point for intense societal debate and efforts to regulate the arrangements (Schmid, 2009). During the process of policy development regularisation of existing migrant care work was defined as the prime goal by all negotiators, while the legal form to be introduced was controversial (Egger de Campo, 2008). While the representatives of the Chamber of Commerce voted for a model of self-employed carers only, the Social Democratic Party opted for the introduction of regulations related to an employee status within the family framework. The unions and the Chamber of Blue-collar Workers suggested a model whereby the carers would be employed by home-based service providers and publicly subsidised. The Conservative People’s Party focused on the development of different types of regulations related to freedom of choice (Rudda/Marchitz, 2006).
The law introduced combines the different suggestions and relate it to freedom of choice for the users. It offers three alternative modes of regularising the employment of migrant carers based on widely different working conditions (see Schmid, 2009). Namely,
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the status of a self-employed live-in carer
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the status of a carer employed by the family
-
the status of a carer employed by a welfare association
The law specifies access criteria for the beneficiaries – with care recipients assigned to at least level-three care-dependency within the framework of the Care Allowance eligible for the services. To cover the extra cost to families for the mandatory social security benefits, users with a monthly income up to €2,500 receive the entire amount to cover the costs of social insurances and taxes. By autumn 2008 the working conditions of almost half of the estimated illegally employed migrant carers had been legalised. Almost all families chose the selfemployed status, i.e., the cheapest alternative without any working-time regulations enabling to receive 24-hour care provision (Schmid, 2009). The regularisation resulted in the establishment of a work segment wide below the regular labour market standards. This outcome was strongly criticised by the welfare associations, unions and the Chamber for the Blue-collar Workers. It is viewed as a risk for the development of standard employment in healthcare provision and a disadvantage to formal care provision. Nonetheless, the cost
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argument – to lower the cost for the public system – prevailed because it was considered more significant (ÖKSA, 2008).
Also in Germany the bottom-up solution established mainly by middle-class families has caused an intensive societal debate and inspired new policies. Already in 2002 on a temporary basis and permanently since 2005, a legal recruitment scheme was implemented to hire domestic workers to families with care dependent members from eastern European countries. In 2002, the proportion among beneficiaries living at home employing migrant carers was still low with 2.4% according to a representative inquiry and increased since then to an estimated 5% (Runde et al 2003; own calculations based on Steffen, 2009; Federal Statistical Office, 2009). The introduction of the legal recruitment scheme was related to a debate on immigration policy and was accelerated in the aftermath of a police raid, when migrant workers from Eastern European countries were found in private households (Shinozaki, 2009). The goal of the regulations was to enable the legal employment of immigrants from defined countries providing domestic services based on regular working conditions and not – as it was the case in Austria – to legalise an existing care practice. According to the authority responsible for placements, 3,032 domestic workers were officially employed on this basis in 2007, which can be compared to the estimated 120,000 migrant carers providing care within the family context. Quantitatively, the scheme proved to be largely ineffective (Lutz, 2009).
Since EU enlargement, regulations related to the single market project are often used in the debate by the agencies or the users to legitimise this type of care provision. The right of free movement for services within the single market project, which allows the temporarily provision of services on a self-employed basis, has been often brought forward. However, in November 2008 the local court in Munich defined the practice as illegal due to the non selfemployment character of the activity and imposed a fine on the broker (a ruling confirmed by the higher regional court in Bamberg in 2009). The Posting of Workers Directive is also put forward as a legal basis. According to the law, families are obliged to follow Germany's labour laws, but these do not fit well with 24-hour care arrangements (Caritas 2006; Neuhaus et al., 2009). This largely illegal situation in Germany is an open secret but it is also – covertly – accepted as it is recognised that it reduces public expenditure for residential care provision (Lutz, 2009). Influential actors continue to demand that an affordable legal service offer be introduced and are opposed to legalising current practice. More recently, diverse Protestant and Catholic welfare associations have demanded that the situation of migrant care workers
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be regularised (Neuhaus et al., 2009). Some policy development may indicate the gradual acceptance of a low-wage area below regular labour market standards: First, the minimum wage introduced in long-term care provision in August 2010 excludes the family context. Second, since the end of 2009 domestic workers employed by the recruitment scheme may even legally conduct long-term care provision instead of domestic services only. Third, the Austrian approach is discussed as a model in the media or at scientific workshops. The further policy development in the area is still an open question.
3. Conclusion: Universalism, migrant carers and the role of actors and ideas Within the article two policy developments - the introduction of long-term care schemes and regulations of migrant care work - are compared between Austria and Germany. With the analysis country-specific policy outputs are revealed and explained by the country-specific processes of transformation of ideas into policy designs in the course of policy-making. In addition, the analysis relates the emergence of migrant carers within the family context to outcomes of the policies from the perspective of the users as well as shows the consequences of the regulations of migrant work for working-conditions. In both countries, universally-oriented long-term care schemes have been established until the middle of the 1990s. Despite universal access, cost containment should be achieved by the creation of a new type of universalism, i.e. first, by the definition of the level of support – which leaves a considerable amount of private responsibility – second, by the introduction of unregulated cash benefits, which are insufficient to pay for formal care provision, and, third, by the definition of certain thresholds of care needs.
In both countries, the schemes were defined in close cooperation between politicians on central, regional and local levels, as well as societal actors. In Austria, due to the influence of the disability movement with its emphasis on autonomous care provision and the federal states highlighting family care a care allowance scheme was introduced, although not the comprehensive cover for which the disability movement campaigned. In Germany, the need to raise new funds for care provision set the mode and level of funding firmly at the centre of the debate. Moreover, the introduction of a mix of benefits is related to the ideas of care quality, the risk of economisation of family care and the demand to relieve the economic burdens on the local levels. Two types of cross-border impact can be found. The UN with its emphasis on the situation of disabled people offered their organisations in Austria wide scope to act. In both countries, expert reports on care policies in other countries are used by actors to strengthen their own arguments.
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Designs, underlying ideas and outcomes of the schemes led to the emergence of migrant carers within the family network as a way to close the care gaps. Unregulated cash benefits enabled the hiring of carers working far below the national standards. The more generous cash benefits in Austria may explain the higher proportion among the older adults using this type of care provision. This bottom-up solution inspired a political debate and the introduction of regulations. In Austria, in 2007 a scheme was introduced enabling the regularisation of the existing practice. Related to the idea of freedom of choice different modes of regularisation have been described within the law, resulting in the establishment of a legal work segment wide below labour market standards. In Germany, the regulations defined in the recruitment scheme are oriented towards regular employment conditions but proved to be quantitatively ineffective. Moreover, regulations related to the single market project do not cover the work arrangements. Whether there will be an adaptation of regulations to the existing practice as it was the case in Austria is an open question.
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Biographical Note: Hildegard Theobald Vechta University Centre for Research on Ageing and Society 49377 Vechta Germany Phone: +49 4441 15551 Fax: +49 4441 15621 hildegard.theobald@uni-vechta.de
Short CV 2007: Professor of Organisational Gerontology, Vechta University; 2006: Visiting professor at the University of Aarhus; 1998-2006: Research Fellow Social Science Research Center Berlin (WZB) 1997: PhD Political Science, FU Berlin 1991-1997: FU Berlin and Stockholm University 1989-1990: Research stays in Stockholm 1989: Diploma in Psychology, University of Heidelberg.
Main research areas: International comparative welfare state research (social/ long-term care), policy transfer and europeanization, professionalisation, formalisation of care work and work organisations, social and gender inequality. .
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