The National Network for Children welcomes Eurochild’s consultation and efforts to keep child poverty high on the political EU and Member States agenda. We see this also as an opportunity to promote stepping up prevention through support to families and an approach where poverty is never the only reason for removing a child from his or her family. Our response is structured according to the consultation questions and input is also provided in the Summary of country-specific recommendations 2012 table where all relevant for Bulgaria recommendations are listed.
Questions and answers
Question 1: What has been your government’s response to the CSRs issued to it in 2012? Which ones have been implemented and how? Has the civil society been engaged in a meaningful way?
Answer 1: The review of the National Reform Programme in its part related to poverty reveals a serious gap between existing policies, aims and objectives. It’s not clear to what extent the policies will support the accomplishment of the objectives – the approach seems to be coming up with a few objectives, putting some policies and this is hoped to lead to the achievement of the goals. This could be also observed in the NPR up-date as of April 2012 where the report on the CSR 5 is a mere summary of activities with amounts of money spent rather than analysis of the achieved results , presentation of key challenges and measures undertaken to overcome them. If child poverty is to be tackled in reality and child well-being promoted in practice, a shift in the reporting process is required so that Member States focus on outputs and impacts rather than inputs. At the same time, Bulgaria seriously lags behind the achievement of the targets and the CSR. For example, only 45 % of the measures planned for 2011 are implemented according to a presentation by Ministry of Finance in March 2012.
Here’s a brief summary of key and relevant to child poverty activities undertaken by the Bulgarian Government as part of its efforts to address the CSRc and the National Network for Children comments:
- A National Strategy for Reducing Poverty and Promoting Social Inclusion (2012−2020) has been elaborated and approved by the Council of Ministers (CoM) on 6th Feb 2013. The Strategy has been drafted with the participation of all interested parties and presents the current status, national targets, key challenges, target groups, priorities and measures. However, there isn’t a comprehensive and detailed action plan to support its implementation. The strategy states that bi-annual action plans are envisaged which will be approved by the CoM and will put concrete measures and activities, indicators, responsible authorities, funding, etc. The Ministry of Labour and Social Policy is envisaged to co-ordinate the process and report on the bi-annual plans implementation.
NNC was part of the consultative process and sits on the working group however our suggestions for more comprehensive measures regarding families were not taken on board. We are also concerned that without a comprehensive action plan, targeted financing (versus the usual ‘within the existing budget’ which means that only routine programmes and activities will be funded) and clear monitoring and evaluation framework the strategy risks to become a meaningless document and won’t serve its purpose to reduce the gap between rhetoric and policy implementation into practice thus increasing the risks to almost half of the children’s population in Bulgaria.
- The National Strategy for Demographic Development has been updated for the period 2012−2030. We are not aware if a consultative process was undertaken which means that if there was such it was done only through the web-site of the respective authority and no pro-active and proper consultation has taken place.
- The draft Law on Child, which guarantees the rights of all children and not only of children at risk, was in process of public consultation when the process was put on hold as a result of religious parents’ organisations opposition and lack of political will to mainstream children’s rights in general and the right to participation in particular. This is very concerning and NNC has planned to undertake a campaign to raise awareness on children’s rights and general public support.
- The Government continued implementing the “Vision for the Deinstitutionalisation of Children in the Republic of Bulgaria” National Strategy, however the main focus is on building small group homes for children with disabilities, development of foster care and restructuring 8 infant homes. NNC recommendations for improvement of the quality of the process (investment in prevention, early intervention and family support; mechanism for ring-fencing the saved money, increasing the capacity of Child protection departments’ social workers etc.) were not implemented and with the current political situation in the country, there’s a growing concern that the process might be jeopardized.
- The creation of integrated social, healthcare and educational services for homeless people is a key measure for poverty and social exclusion reduction. The Government reports that the number of temporary placement centres as of 31.12.2011 is 10, with a capacity of 613 places, of which 543 occupied. NNC is concerned that housing children and their families in temporary accommodation must only be used in exceptional cases, since it does not provide the stability that the children require to achieve their maximum potential. We have advocated for a development of a housing policy at both national and local level and stimulation of measures in this direction supported with EU structural funds.
- The National Youth Programme (2011−2015) was elaborated and adopted in 2011. It is based on the reported needs of young people on the grounds of the conclusions and recommendations made in the assessment of the Youth Activities Programme (2008-2010) and the “Youth Information and Consultative Centres” National Programme (2007-2010). The new programme envisages EUR 3.1 million for financing of projects for youth activities under 4 sub-programmes, i.e. development of the network of youth information and consultative centres, national youth initiatives and campaigns, youth volunteering and development and recognition of youth’s work. NNC welcomes the youth development programme and financing for its 4 components but is concerned that more comprehensive measures are needed to address the youth unemployment in Bulgaria which is the highest in Europe.
- In January 2012 the Council of Ministers approved the National Strategy for Roma Integration (2012−2020) and the Action Plan for the Implementation of the National Strategy of the Republic of Bulgaria for Roma Integration (2012−2020). The Strategy, which is a policy framework document outlining the guidelines for implementing the Roma social integration policy, was unanimously approved by the National Assembly in March 2012. NNC’s member AMALIPE states that the Strategy “further develops the strengths of the previous Roma integration documents,” but also faults the document for not demonstrating sufficient funding and budgeting, noting that 71 of 120 activities in the Action Plan are not budgeted (Amalipe Feb. 2012). The strategy also lacks a well established monitoring and evaluation system which leads to the conclusion that despite the numerous Government plans and initiatives, implementation is limited and sporadic at best and that resource allocation is inadequate to meet the expectations and stated objectives.
- The draft Law on Pre-school and School Education which envisaged major reform in the educational and training systems was not approved by the National Assembly thus not implementing one of the EC specific recommendations. Given the current political situation i.e. a Temporary Office Cabinet and elections in May 2013 it’s not clear if this law will become a reality.
- The “New Chance for Success” project of Ministry of Education, Youth and Science for the inclusion of persons aged over 16 years in literacy training and studying the educational content for 5−7 class is being implemented since March 2011 under measure “Launching programmes for “second chance” schools – further opportunities for literacy and professional development of drop-outs”. The validation of the training results provides opportunity for the continuation of the education in the next class of formal education or in professional qualification training. It’s not clear how this support for integrating low-qualified young people on the labour market will be sustained given that it was regulated in the draft Law on Pre-School and School Education which wasn’t approved by the National Assembly.
Question 2: How should this year’s CSRs be formulated to address the main gaps in the national policy on children’s poverty well-being? Please identify particularly problematic national policy areas that are currently not in accordance with the European Commission Recommendation. By demonstrating how the national policy lags behind the new Recommendation, you will equip the Commission with powerful arguments to put pressure on your governments.
Given the complexity and the No. of measures included in the NRP, NNC believes it’s unlikely the Commission to formulate more than 1-maximum 2 related to child poverty country specific recommendations. Therefore, we have prioritized two very specific to us and the work of our members’ issues and listed other relevant recommendations below them.
- NNC advocates for a CSR related to Stepping up prevention through support to families and development of a family policy
Rationale: Parenting support in Bulgaria is not developed in a systematic way. It very much remains an emerging, fragmented policy field, too often left to the initiative or good will of community organisations. There’s acute and urgent need to develop a family policy with clear aims and objectives, targeted funding and monitoring and evaluation framework. We believe this will help support and empower parents in their role as carers and educators, by acting before it is too late and thus contributing to fighting child poverty. The study tour to Sweden and Denmark organized by Eurochild in April 2010 has shown that a well defined family policy and investment in parents can have a positive impact on children’s well-being and help parents’ better cope with the stress arising from a difficult financial situation. By relieving pressure on families, they can also help prevent violence. The family policy should also aim to prevent in-work poverty and create adequate incomes to ensure that no child experiences poverty, support job retention and guarantee affordable, flexible and high-quality childcare.
- NNC advocates for a CRS related to the Development of quality, alternative care through increasing the child protection department social workers capacity
Rationale: This is a major challenge for all reforms related to children in Bulgaria –deinstitutionalisation, juvenile justice, inclusion of children of Roma origin and children with disabilities, etc. There’s an acute shortage of well trained and experienced social workers (570 people as of end Dec 2012) where one social worker deals with 284 cases as average per year according to the recently adopted Road Map for the implementation of the Concept for the reform of the juvenile justice system in Bulgaria. If children and families who live at poverty or are at risk of such are to receive adequate and effective support, then an investment in social workers in terms of numbers, training and support is vital. This will also contribute to a more preventative approach in child protection where poverty should never be the only reason for removing a child from his or her family.
The other NNC recommendations are as follows:
– Develop in partnership with civil society organizations a comprehensive health strategy supported by a detailed action plan which to ensure the right of children to adequate health care and address the physical and mental health of children living in poor socio-economic conditions. This also has a huge bearing to Roma children and families’ giventhat the life expectancy rate for Roma is 10 years less than that of ethnic Bulgarians. 
– Ensure access to affordable permanent accommodation through the development of a housing policy and encouraging measures (including supported with EU structural funds) to support the development of quality and available social housing to all groups of population prioritizing large families and families from ethnic origin.
– Develop a strategy for prevention of school drop-out and ensure quality and access to school is improved. NNC believes that lack of attendance is principally caused because of discrimination, poor quality instruction, lack of accessibility, overcrowding and lack of resources. This is particularly relevant to children of Roma origin given that most of the 45,000 students who drop out annually are of Roma ethnicity.
– Allocate appropriate resources for the National Roma Inclusion Strategy action plan implementation to address current gaps where 71 of 120 activities are not budgeted.
– Require Member States to carry out ex-ante and ex-post social impact assessment of austerity measures, to ensure they do not increase child poverty and social exclusion.
– Revise reporting process and provide a template so that Member States report on achieved results and impact rather than activities and inputs.
Question 3: What evidence/arguments can you think of to convince the Commission to formulate a specific Country-Specific Recommendation on child poverty?
Answer 3: See rationale below key proposals for CSRc above.
1) Bulgarian National Reform Programme up-date
2) Eurochild overall assessment of the EC recommendation “Investing in children: breaking the cycle of disadvantage”
3) Report of the Independent Expert on Minority Issues: Addendum. Mission to Bulgaria (4 to 11 July 2011), United Nations, 3 January 2012
4) Towards Following Steps Necessary: Assessment of the National Strategy of Republic of Bulgaria for Roma Integration, Amalipe Center for Interethnic Dialogue and Tolerance, February 2012
5) Setting the context: the Roma in CEECS, UNICEF
6) NNC statements and analysis related to child poverty and social exclusion http://nmd.bg/pozitsiya/
25 March 2013
 Unfortunately, there’s no available official data for the progress as of Dec 2012.
 51.8% of the children in Bulgaria are living at risk of poverty and social exclusion. 78.2% of the families with three or more children are poor (living with less than 140 Euro per person monthly).
 Amalipe Center for Interethnic Dialogue and Tolerance. February 2012. Towards Following Steps Necessary: Assessment of the National Strategy of Republic of Bulgaria for Roma Integration.
 United Nations (UN). 3 January 2012. Human Rights Council. Report of the Independent Expert on Minority Issues: Addendum. Mission to Bulgaria (4 to 11 July 2011).
 Setting the context: the Roma in CEECS, UNICEF