A Comparative Analysis of Child Maintenance Schemes in Five Countries
| Author | Christine Skinner,Jacqueline Davidson,Mia Hakovirta |
| DOI | 10.1177/138826271201400407 |
| Published date | 01 December 2012 |
| Date | 01 December 2012 |
| Subject Matter | Article |
CHILD MAINTENANCE SCHEMES
IN FIVE COUNTRIES
Christine Skinner*, Mia Hakovirta**
and Jacqueline Davidson***
Abstract
The aims of this special issue were twofold: to provide international research evidence
of child maintenance schemes in five countries and to produce a comparative analysis
of that research, to show how child maintenance outcomes differ across countries.
The research data were col ected using a vignette technique. This set up two fictional
families, specifying sets of characteristics in order to explore how child maintenance
schemes deal with key factors. Decision processes and payment outcomes are explored
for applicants who are, for example, lone parent families on low incomes, divorcing
families on middle incomes or reconstituted cohabiting families where a new child
is born to the non-resident parent; the effects of changes in employment status and
shared care arrangements are also considered. This final paper provides a comparative
analysis of the vignettes to show how child maintenance outcomes differ across
countries, and summarises the key themes that emerge from the individual country
papers. Ultimately, the comparative analysis demonstrates that we have only scratched
the surface in understanding similarities and differences international y across child
maintenance schemes. This is partly because of the complex interaction between child
maintenance schemes and social security systems, which is not always transparent.
Keywords: child maintenance; guaranteed maintenance; shared care; social assistance
benefits; vignettes
*
Dr Christine Skinner is a Senior Lecturer in Social Policy, University of York. Address: Department
of Social Policy and Social Work, University of York, Heslington, York, YO10 5DD, UK; phone:
+44 1904–321251; e-mail: christine.skinner@york.ac.uk.
**
Dr Mia Hakovirta is a Senior Lecturer in Social Policy in the Department of Social Research,
University of Turku. Address: Department of Social Research, University of Turku, FI-20014,
Finland; phone: +358–2–333 5898; e-mail: miahak@utu.fi.
***
Dr Jacqueline Davidson was, until recently, a Research Fellow in the Social Policy Research Unit,
University of York.
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A Comparative Analysis of Child Maintenance Schemes in Five Countries
1. INTRODUCTION
This final paper in this special issue provides a comparative analysis of the vignettes to
show how child maintenance outcomes differ across countries and it summarises key
themes emerging from the country papers. To enable transparency and comparability,
we asked all authors to cover the same ground in their country papers, and to use the
definitions provided in a common glossary (see Skinner, Davidson and Hakovirta
in this volume). Whilst this helped expose the similarities and differences between
calculation methods for determining the level of child maintenance, the cultural and
institutional variance in child maintenance schemes and how these are historically
and ideologically grounded in country contexts remained more difficult to ascertain.
The paper is presented in three sections. The first section discusses the policy aims,
because these are crucial to the operation of child maintenance schemes. In doing so,
it considers the primacy afforded by the different schemes to the reduction of poverty,
and, given the importance of this as a potential outcome, it also looks at how child
maintenance interacts both with social assistance benefits and with cost recovery
methods used by the state to minimise social security expenditure.
The second section considers the provision of advice and support services in
the different countries and the issue of non-compliance, as well as societal attitudes
towards child maintenance. We argue that these are important considerations because
it might be thought that compliance was strongly related to the perceived legitimacy
of child maintenance policy and to societal norms regarding the payment of child
maintenance.
The third section provides a detailed comparative analysis of the vignettes that
show the levels of child maintenance set by the formal determination procedures
for two fictional families. The analysis compares the different child maintenance
outcomes that are achieved by using purchasing power parities in US dollars ($ppp)
to standardise the value of child maintenance in the different currencies. In addition,
the important but tricky question of who is expected to pay (the state or the parent) is
considered. Other important questions, such as what happens to the amount assessed
when the non-resident parent has another child or when there is equal shared care,
are also tackled.
2. POLICY AIMS, POVERTY, INTERACTIONS WITH
SOCIAL ASSISTANCE BENEFITS AND COST RECOVERY
2.1. POLICY AIMS
The task of pinpointing the key aims of child maintenance policy was not
straightforward in any of the five countries included in this special issue. Aims can
change considerably over time (see Skinner in this volume) and can often be implicit
European Journal of Social Security, Volume 14 (2012), No. 4
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Christine Skinner, Mia Hakovirta and Jacqueline Davidson
(see Hakovirta and Hiilamo in this volume). Additionally, policy frameworks can
overlap with family law provisions which are often devoted to making suitable care
arrangements for children. The aims of child maintenance policy may, therefore,
also encompass a care aspect in relation to post-separation parenting. In the UK,
this has become explicit under the 2012 proposals, whereas in Finland this emphasis
emerged much earlier, in the 1980s, when policy focused on ‘shared custody’ and on
contact between the child and the non-resident parent. Similarly, Iceland’s system
now aims to give equal weight to mothers and fathers regarding custody and contact
with the child and indeed, shared custody has been the default option since 2006.
However, ‘shared custody’, in which parental responsibility is shared equally when
parents are separated, is a legal status in Finland and it does not reflect the amount
of time children actually spend living with each of their parents. Caution should be
exercised as there is a range of different terminologies to describe these care patterns
and legal statuses and the same label may mean different things in different countries.
To understand fully how family law (in relation to care arrangements) overlaps with
child maintenance schemes requires more detailed study than was possible for this
special issue. We do however consider equal shared care in the next section.
Most importantly, we have also found that child maintenance policies can interact
in complex ways with social assistance benefits and social security systems. This
juxtaposition makes it difficult to identify where child maintenance policy aims
begin and end and where they might overlap with those of social security policy. For
example, the aim of reducing child poverty might be a common aim of both systems,
or it might exist only in the social security system (see section on poverty below).
It seems however, that at the heart of all child maintenance policies is the aim of
encouraging private financial responsibility.
2.2. PRIVATE RESPONSIBILITY
Encouraging private financial responsibility is an aim common to all five countries,
but the rationale underpinning this aim is implicit and may differ between countries.
On the one hand it could be about meeting children’s needs in a purely financial
sense but, on the other, it could be ideologically based, emphasising that separated
parents are never allowed to renege on their parental responsibilities. In the US
for example1, once a child maintenance order is made, no other subsequent family
obligation to new biological or step children is taken into account. Thus the initial
child maintenance order is not reduced by these new family responsibilities, even
if they include a natural child of the non-resident parent. The US schemes therefore
aim to protect children with a child maintenance order from any subsequent family
transitions that the non-resident parent might make (see Meyer et al. 2011). Finland
and Iceland are also concerned to maintain parental obligations to children, and
1
This holds true for the state of Wisconsin, and some other states, but not all.
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A Comparative Analysis of Child Maintenance Schemes in Five Countries
both countries have historically emphasised the on-going obligation of the non-
resident parent to contribute financially, whilst stressing that the parent with care
should be responsible in other ways, for example by meeting children’s everyday
housing and care needs. The Netherlands on the other hand, seems to adopt an
approach based on both parents continuing to have a shared financial responsibility
to meet the costs of children through child maintenance payments. The UK is
encouraging more joint responsibility through ‘private family-based agreements’,
but simultaneously it has let go of the explicit policy goal that child maintenance
should help reduce child poverty. Arguably, therefore, the UK has become more
concerned with promoting responsibility than with ensuring that child maintenance
helps meet children’s financial needs. The aim of poverty reduction is now discussed
in more detail.
2.3. POVERTY
The country papers have shown that protection against poverty...
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