A Comparative Analysis of Family Policy in France, Germany and the United States
Jill Strait
The United States (U.S.) is commonly compared to Europe in terms of its political and social cultures. There are many characteristics that the U.S. and Europe share such as government stability, democratic values, and relative economic prosperity. Yet when closely examining the political cultures, key differences arise, even within European countries themselves. One specific difference is in regards to family policy. The U.S. differs greatly with Western European countries on the social programs that are available for families. France and Germany will be used as case studies to exemplify similarities and differences within Europe and with the U.S. on family policy issues. While both countries' programs are reflective of Western European thought, they approach the issue in different ways. In all three counties it will be shown how family policy is influenced by the countries' political culture and how that accounts for differences within policies.
A country's political culture is shaped by its history, religion and values. In France, its turbulent and often violent history of revolutions has served as the basis for its political culture today. French political thought is rooted in the notions of equality, liberty and fraternity. Even today citizens have a general distrust of government and politics. Yet at the same time they crave order and authority. The role of the state, "etatism" is important in French society and people are accustomed to a pro welfare state.
There is support for many different social programs in France and people have general respect for the bureaucracy. Individualism is also an important value to the French. People want to feel empowered and like they are in control, even if it comes through government support. This is especially true in terms of its family policy. The state gives aid, not so woman can feel dependent or weak, but rather to empower them to be self-sufficient and have careers of their own.
Germany's political culture was greatly impacted by the creation of East and West Germany following World War II and the subsequent reunification that occurred in 1989. Different political cultures existed in the East and the West. The East Germans were use to a socialist state that included many social programs. They were accustomed to state paternalism and relative economic security. The East also had greater feminist values. In the West, people had a strong commitment to the rule of law and saw to the protection of civil liberties. Whereas the East adopted some feminist ideology, the West remained fairly traditional in their values, especially concerning the role of women within society.
The United States shares a similar historic background to France, as they both participated in revolutions during roughly the same time period. Because of that they share the same values as the French in liberty and equality. The U.S. places a high value on individual autonomy and there is a belief that anyone can succeed in the U.S. on their own if they work hard enough. The U.S. is a very strong capitalist society that is pro-business and puts up resistance to many social welfare programs. This accounts for the overall lack of family policy programs within the United States.
European countries consistently surpass the U.S. on the amount of money that is spent each year on social programs. Within European countries, France is the leader in social spending because of the increased importance placed on social programs by both the people and the government. France spends 29% of its Gross Domestic Product (GDP) on social programs. By comparison the U.S. spends only half that amount, using 14% of the GDP for social programs (Chrittendon, 2001). A large portion of this money for social programs is used specifically for family policy programs that directly benefit mothers and children.
France
France has one of the most comprehensive family policy programs in the world and is the top spending country on these programs. All mothers, regardless of marital status, age or race receive a package of benefits that includes healthcare, cash allowances, and a public nursery school system. This not only provides for the betterment of children's lives but also creates a climate that encourages women in the workplace.
There is an overall value of family that exists within French society and politics that serves as motivation for many of their family programs. Parents are encouraged to spend time with their children and to better their family life. In 2000 the work week was shortened from 39 to 35 hours per week so parents would have more time to spend with their family (Chrittendon, 2001). This also means that fewer children are coming home from school to empty houses and spending the late afternoon unsupervised. This respect for family life is seen in many other government programs and policies.
There are a wide variety of motherhood benefits that women start receiving from the moment of conception. All women have mandatory medical checks that must take place before and after birth. Women also receive increased medical benefits during the final four months of pregnancy. These medical benefits extend to the child after birth until the age of 20 (European Commission, 2004).
Another benefit is that French women are entitled to yearlong paid maternity leave so they can spend quality time with their newborn (Chrittendon) receive up to 1,000 Euros. When the child is between the ages of 3 and 6, up to 500 Euros may be received (European Commission, 2004).
There is also a Single Parent Allowance that is available. This guarantees a minimum family income for single persons with one child or more. A single parent receives 502 Euros a month, plus an additional 167 Euros per additional child they have (European Commission, 2004).
A Special Education Allowance is available for children who are handicapped or have special needs. Payment is subjected to a mean test, but children who qualify can continue to receive benefits until they are 20 years old. The amount can range between 80 to 897 Euros per month. More money is allotted if a parent cannot work because of the child's disability, or if third person assistance is needed (European Commission, 2004).
Two other benefits include the New School Year Allowance and the Family Supplement. The New School Year Allowance makes sure children start off the school year with necessary supplies. Families receive a certain amount for each child who is between the ages of 6 and 18 years old. A Family Supplement program gives additional money to parents with at least three children between the ages of 3 and 21 years old (European Commission, 2004).
In addition to all of the cash benefits that mothers receive, there is also a structured system of childcare in France. France has a public nursery school system that 99% of 3 to 5 year olds attend at little or no charge. There are also special subsidy programs in place, such as the Child Home Care Allowance, that pays for children to be cared for in home settings. The public preschool system cost approximately $7 billion to operate in the mid-1990s. Yet much of this cost was offset by the increased tax revenues from mothers being able to work because their children received childcare (Chrittendon, 2001).
The family policy programs in France make it much easier for mothers to return to the workforce. Because of the childcare system more women can return to work and earn money for themselves, which means they can provide more for their children.
Working mothers often experience what is known as the "mommy tax." The mommy tax is composed of income that is lost due to childbirth. This not only includes the cost of having children, but the loss of money on the job from not working, cutting back hours, or having to choose a different career altogether. France has one of the lowest "mommy taxes" in the world. The easiest way of measuring this is by looking at earning differentials between working mothers and working non-mothers. In France there is only an 8 to 10% earning differential, the U.S. has a 20% difference and Germany's is as high as 50% (Chrittendon, 2001).
The high maternal income and vast array of social programs means that French children are simply better off than most children around the world. France has one of the lowest child poverty rates, which is only 6% compared to 17% in the U.S. (Chrittendon, 2001).
Germany
Germany's family policy program has been greatly impacted by reunification. There were striking differences in the policies that existed in Eastern and Western Europe. Today much of Germany's family policy is rooted in the ideology of the Christian Democratic Party, which promotes traditional roles of women and mothers within society. While Germany still has a wide array of social programs available for its people, the country has taken a different approach to family policy issues than France. Unlike France, Germany's policy is not as centered around childcare, but rather is about providing benefits to mothers so they can stay home with their children.
It is argued that East Germany had labor policy rather than family policy and that its main concern was with building up a socialist nation. Their family policy promoted labor participation for women, and also fertility in order to expand the labor force (Hara, 2003). In the East, women composed 49% of the labor force, a high proportion of those being mothers, while in the West women only composed 38% of the labor force (Duggan, 2003).
In East Germany women enjoyed many of the same comprehensive benefits that were seen in France and many other European countries such as Sweden. These benefits included yearlong paid maternity leave, housing subsidies, and public childcare. In 1989 80 to 95% of children under the age of 10 were in free daycare or school (Henneck, 2003). In fact, the state in East Germany absorbed 87% of all expenditures spent on children; the state only absorbed 34% in the West (Duggan, 2003).
This made it easy for women to be mothers and work at the same time. At that time 91% of women in the East were mothers, compared to 80% in the West (Chrittendon, 2001). Not only was there a higher proportion of mothers in the East, but also a higher percentage of mothers who worked. In the East, 62% of married mothers and 89% of single mothers held jobs. In the West only 29% of married mothers and 45% of single mothers worked (Henneck, 2003).
After reunification the East noticed dramatic changes in the family policy and social programs that they were accustomed to. Childcare dropped between 60 to 94% (depending on the age of the child). In 1990 housing and job subsidies were phased out and by the mid-1990s Eastern women made up 65% of the unemployed. Any remaining childcare provisions shifted from central to local government control and distribution (Henneck, 2003).
Yet overall, German mothers still receive a variety of benefits. Like France, mothers also receive monthly cash allowances, although overall the amount is lower, especially when looking at families with multiple children.
Germany's monthly cash allowance benefits per child:
1
st and 2nd child - 138 Euros3
rd child - 153 Euros4 + children - 179 Euros (European Commission, 2004)
Tax breaks and exemptions are also available to families. For two-parent families with an income les than 53,655 Euros or single parents with an income less than 34,772 Euros are eligible for certain benefit payments. For the 24 months following birth they can receive 304 Euros per month, or 460 Euros per month for a 12-month period (Family Policy: Germany, 2000).
Parents receive up to 14 weeks of paid leave at a 100% of their net earnings. Eight of these weeks can be taken postnatally. This leave is not only limited to the mother but can be alternated between the mother and the father up to three times until the child is three years old. For each child that is under the age of 12, parents also receive up to 10 days of leave a year to care for sick children. During leave parents also have the legal right to work part-time up to 30 hours per week. Many parents do this and work part-time, so both parents can take their leave simultaneously (Family Policy Germany, 200).
Unlike France, little money is put into childcare programs. While legislation was recently passed allowing all 3 to 6 year olds to be placed in daycare, the program lacks key elements. The daycare is still relatively expensive, no lunch is provided and the day only lasts five hours so it conflicts with mothers' work schedules. This is extremely different than France's subsidized system that is meant to ensure quality of education, to the point that even stay-at-home moms send their children to public nursery school (Henneck, 2003).
Germany is still very traditional in many aspects concerning family policy. Society still prefers two-parent families and to have the mother stay home with the kids instead of working. The focus of the family policy program is to encourage mothers to stay home instead of returning to the workplace. That is why more money is put into paid leave than childcare provisions. Yet, in a 2001 poll of German women, 71% of German mothers with children under the age of 3 said they would like to work at least 15 hours per week but they have no one to care for their children (Eddy, 2003).
This leads directly into the declining birthrate that Germany, along with the rest of Europe, is currently facing. Germany has the second lowest birthrate in Europe after Italy. In 2003 the German woman had an average of 1.34 babies. In the U.S. the average woman has 2.1 babies. Lawmakers in Berlin are so concerned about the declining birthrate that they pledged $4 billion towards programs to encourage births (Eddy, 2003).
Many feel that Germany's family policy is to blame for the low birthrates. Women are opting out of motherhood in order to work. It is difficult for German women to do both and motherhood is continually being viewed as a burden. The government has done nothing to help women, but rather has continued to encourage women to stay at home. "Germany is forcing women into that choice," said Avivah Wittenberg-Cox, career coach for European Women in management positions. Many people share Avivah's sentiments and believe that without more family-friendly incentives such as tax breaks, child care subsidies and better public transportation that women will continue to choose work over motherhood (Eddy, 2003).
United States
Compared to Western Europe, the United State's family policy is almost non-existent. There is no comprehensive universal coverage for all mothers, and any social programs that do exist are geared solely towards needy families. Tax breaks and some Federal programs are specifically designed to assist low-income families while ignoring the other mothers and children.
There is a large percentage of working mothers in the U.S., 59% of women with children under the age of 1 hold jobs. Despite the high percentage of working mothers, there is no public system of child care. 55% of women still put their children in non-parental care simply because they have no other choice. Childcare costs soak up a quarter of the total income that low-income families bring in and only 10% of families in the U.S. receive any type of childcare subsidies (Henneck, 2003).
One of the few Federal programs that does exist is the Temporary Assistance for Needy Families Program (TANF). This program is designed to assist needy families whose children are cared for at home. It is a block grant program that provides states with Federal funds that total around $12 billion. The program heavily promotes job preparation and work. Parents must meet work requirements to receive benefits, unless the child is under 6 years old and care cannot be provided. There is a five year limit to this program (Office of Family Assistance, 2004). Families can receive child tax credits up to $1,000 per dependent child. But there are limits based on income on who receives tax breaks (Internal Revenue Service, 2004).
There is no federal legislation in the U.S. that guarantees mothers paid maternity leave. In 1999 Clinton encouraged the Department of Labor to draft reforms that would extend unemployment insurance to mothers who were out of work due to childbirth. This initiative passed in June, 2000 and sparked debates about what, if anything, mothers should receive during maternity leave (Gornick, 2001).
The Family and Medical Leave Act does provide some mothers with maternity leave privileges. Companies with 750 or more employees are required to offer up to 12 weeks of unpaid maternity leave with continued health insurance. Yet half of working women are not even eligible for this because they work for small companies with fewer than 750 employees. Many women who can technically take leave don't. 64% of women who didn't take leave said they couldn't financially afford to take the time off (Henneck, 2004).
States are beginning to pass their own parental leave legislation. In 2004 California enacted a Paid Family Leave Law. This allows employees who pay into the state disabilities insurance program (includes 13 out of 16 million workers) to receive six weeks of job protected leave at about half salary (up to $728 per week). Employees also have the option to quit their job and still be eligible to collect unemployment benefits. New York and New Jersey also have partial pay parental leave programs. Montana, Minnesota and Missouri all have enacted at home infant care programs (Henneck, 2003).
Key differences can be seen between family policy legislation in the United States and Western Europe. Following other trends of social spending, it is no surprise that the U.S. puts little into family policy programs. Yet it is also important to note the key differences that exist between France and Germany and not be quick to lump all Western European countries together when it comes to family policies. Although both countries offer social benefits and programs to mothers, the countries have different ideologies that change the approach to this same issue. France continues to put more money into child caring services in order to facilitate the working mother, while Germany puts more money into parental leave programs to encourage mothers to stay at home. While Europe will continue to face the concern over the decline in birthrate that stems from family policy legislation, the U.S. will continue to debate over the extent to which the Federal Government should assistant mothers and families.
References
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Duggan, L.(2003)East and West German Family Policy Compared: The Distribution of Childrearing Costs. Comparative Economic Studies. 45:1,63
Eddy, M. (2003) The World: Family Policies, Birthrate Falling Short; Germany's fertility rate is among Europe's lowest, despite subsidies for parents. Los Angeles Times. p.A.10
European Commission. (2004) Germany: Family Benefits. Social Security and Social
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http://europa.eu.int/comm/employment_social/missoc2001/d_part9_en.htm
Family Policy: France. (2000) International Reform Monitor
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Internal Revenue Service. (2004). Child Tax Credit. http://www.irs.gov/newsroom/article/0,,id=106182,00.html
Office of Family Assistance. (2004). Temporary Assistance for Needy Families. U.S. Department of Health and Human Services. www.acf.dhhs.gov/programs/ofa