The National Network for Children (NNC) welcomes the efforts for improvement of the legislative framework related to the right of families to social support through benefits and social services.
As an association of 103 non-governmental organizations working for development and implementation of quality policies and services for children and families, we have always emphasized upon the need for better and targeted support for the most vulnerable through optimization of the family benefits for children. Our principal position is that the result of the income test cannot be criteria in itself about the need of a family for support. The benefits should be granted following an individual assessment of the concrete situation of the family which looks not only at the parents’ income but also all other factors associated with the abilities of the family to look after its children. In this regard, we believe that a comprehensive reform in the social assistance system is necessary which should be based upon the principle that the social benefits should be linked with social work.
We welcome the concrete suggestions for changes in the draft law for amendments and additions to the Family Allowances for Children Act and consider them as a step in the right direction.
We fully support the texts of § 2, § 3 и § 4, which remove the income test for family allowances for children who are looked after by one parent and agree with the motives pointed out in the document. The National Statistical Institute data about the relative share of poor by types of households, undoubtedly show the significant vulnerability of a child who lives with one parent (42, 3% poor households) versus a child who lives with both parents (13, 7% poor households).
In connection with this, we suggest the Family Allowances for Children Act to guarantee the receipt of one-off allowance upon birth of a child according to art.6, p.1 from his/her legal representatives when the mother dies at the time of the birth. Despite the regulation under art.6, p.5 which envisages the possibility for the allowance to be granted to another legal representative of the child, in practice there are cases of families who are deprived of this allowance because the “Social assistance” directorates consider the mother as the only possible recipient of the allowance.
We also pleased to see the provision of a monthly allowance until the child turns 18 years old in the cases where the secondary education is completed before this age. With regard to art.7, p.10, we suggest the text to clarify that the support will be granted until 18 years as this doesn’t become clear from the current text.
We also welcome the fact that the legislator acknowledges the importance of the inclusion of children with severe disabilities in the mainstream educational process through additional assuagement of their families with a guaranteed targeted support for first grade students.
We use the opportunity to underline that the road to inclusion is a long one and goes through provision of a sufficient supportive environment and a flexible response to individual needs of every child.
Without doubt, the envisaged amendments expand the Family Allowances for Children Act (FACA) scope and provide better support for families. However, the current text of the Act lacks possibilities for support of children, places in social services from residential type. There are such services for children in the country which do not contradict the (FACA) requirement that the allowances are provided to families of children who is not “placed in a specialized institution for children fully supported by the state”. In this regard, we suggest children, placed in such social services to be allowed to use all adequate allowances in line with this Act as well as the children, placed in extended and foster under art.26 from the Child Protection Act.
We hope that the new Family Allowances for Children Act will strengthen the implementation of a better policy for support of the Bulgarian children and families. We are available for participation in discussions and working groups regarding the consultation of the amendments and the additions of the current Family Allowances for Children Act.