Most countries recognize the costs of children to some extent in their social security systems (Bradshaw et al. 1993; Wennemo 1994), and where universal child benefits or family allowances are provided, lone mothers are entitled to receive these. Eligibility for these benefits is thus on the basis of their status as mothers or as carers for children, not specifically because of their status as lone mothers. Similarly, where schemes of means-tested child benefits or family allowances exist, these include lone mothers on the basis of their status as poor families. Of the fifteen countries included in the study by Bradshaw et al. (1993),1 eleven had a universal family allowance scheme and ten had one or more means-tested schemes for families with working parents. However, although the eligibility of lone mothers to these benefits is through their status as mothers and/or poor families, some countries offer additional payments to lone — parent families. This is true in Denmark, France, Greece, the UK and Norway for universal schemes and in Greece and Australia for means-tested schemes (Bradshaw et al. 1993). In addition, the level of support offered to lone parents through these schemes will vary according to the structure of the benefit; for example, schemes that exclude first children (as in France) or pay more for large families (as in the Benelux countries) will pay proportionately less to lone parents, who usually have smaller families than couples.
Designated benefits for lone mothers, where entitlement is specifically related to status as a lone parent, are relatively uncommon, except in the case of widows. Widows’ benefits and pensions are usually provided as contributory benefits, on the basis of the husbands’ contributions, and are intended to replace his earnings. Entitlement to these is, therefore, on the basis of the status of wife. Most countries make such provisions, although this is no longer true in Denmark, and the UK restricts these benefits only to widows with children.
There are, however, other examples of benefits specifically for lone parents: Australia, Ireland, Norway and France all provide a ‘lone — parent benefit’ of some sort. Eligibility relates to the status as lone parent, although the structure of these benefits varies quite significantly across the different countries. In Australia all benefits are means-tested but separate benefits are available for different categories of claimant, including lone parents (the ‘supporting parent’s benefit’). Similarly in Ireland both social insurance and social assistance benefits are divided into separate benefits and lone parents have special entitlements in both schemes (the ‘deserted wives benefit’, the ‘deserted wives allowance’ and the ‘lone-parent benefit’). In Norway the ‘transitional benefit’ is paid to lone parents for one year after becoming a lone parent or until the youngest child is aged ten. It is means-tested but does not cease on cohabitation. In France the ‘allocation de parent isole’ performs something of a similar role; it is paid for one year after separation if the children are aged over three or until the youngest child reaches the age of three (and for an unmarried mother the benefit would start with the birth of the child and continue for three years).
What these designated lone-parent benefits have in common is that they all allow lone mothers to stay at home and care for their children, up to minimum school-leaving age in Ireland and Australia, up to age ten in Norway, and up to age three in France. They are thus intended as wage replacement benefits, to allow lone mothers to be full-time mothers. It is, of course, not essential that a designated benefit be created to fulfil this objective; in the UK income support is payable to lone parents, without requiring them to be eligible for work, until the youngest child reaches the age of 16. In the Netherlands, lone mothers are also supported at home through the social assistance scheme (Hobson 1994). However the use of designated benefits does make more visible this function of supporting lone mothers as mothers at home.
It is clear that the most common way to support lone mothers is not through designated benefits, but through the provisions that exist for all families with children. For non-employed lone mothers this will usually mean social assistance benefits, for employed lone mothers universal family allowances and in-work means-tested benefits. It would thus be expected that support for lone mothers would be highest in those countries where support for families with children is highest, and lowest where such general support is low. A number of studies suggest that this is indeed the case; for example, Kahn and Kamerman (1983) found this in their study of family support in the late 1970s. Bradshaw et al. (1993) also find this. They calculate levels of support for children by taking cash benefits, tax allowances, health, education and housing benefits. They include a variety of different family types at various levels of earnings. Different countries are more or less generous to different types of family (some support large families better than small, or low earners better than higher earners and so on). Table 5.2 reproduces their ‘league table’, which is the summary
measure of support to families. I have grouped the countries into three bands in order to highlight the way in which general support for children and support for lone parents is highly correlated. Those who are most generous to all families are also most generous to lone parents—Luxembourg, Norway, France, Belgium and Denmark. Those least generous to all families are least generous to lone parents— Italy, the USA, Ireland, Spain and Greece. The pattern also holds if employed and non-employed families are considered separately. Thus, what is important for lone mothers is the level of state support offered to all families with children: it is their claims as mothers, not as lone mothers, that are important.
PRIVATE TRANSFERS: MAINTENANCE AND CHILD SUPPORT
The introduction of child-support legislation in the UK has been one of the most controversial policy developments of recent years and indeed significant changes have been announced in the scheme after only about eighteen months in operation (Department of Social Security 1995). One of the key objectives of the scheme is to reduce discretion in the award of child maintenance. Thus, instead of the courts fixing maintenance in each case individually, the award is made according to a formula, and responsibility for setting, collecting and enforcing awards is the task of an administrative agency. With high levels of separation and divorce this shift to an administrative system can be seen as an attempt to come to grips with family breakdown as a mass phenomenon (Goode 1993; Garfinkel and Wong 1990). In addition, as the name suggests, child- support schemes usually deal only with the issue of support of children. Settlements between spouses (or partners) are not included but, in most of the countries concerned, child support has followed the establishment of ‘clean-break’ divorce (i. e. where there is no ongoing financial obligation between divorcing partners).2 Thus child-support schemes seem to continue a process whereby marriage no longer gives rise to long-term financial obligations but parenthood does (Eekelaar 1991; Fox Harding, Chapter 7 in this volume).
Child-support schemes exist in the USA, Australia, Canada and New Zealand as well as the UK. They seem to be a feature of English-speaking countries or, as the Australian committee reviewing the workings of their child-support scheme put it, they reflect an ‘Anglo-Saxon’ approach to policy in this area (Child Support Evaluation Advisory Group 1992). These schemes do differ quite significantly in their structures, rules and organization, and these differences affect both the way they operate in practice and how they are viewed in different countries. For example, the Australian and the UK schemes have had rather different outcomes (Millar and Whiteford 1993; Millar 1996). However, what binds these child-support schemes together as a distinctive approach is that they involve the state acting to set and enforce family obligations between parents and children.
This Anglo-Saxon model is not the only approach to providing financial support for the children of separated parents. In Europe, and especially Scandinavia, there is a different approach that has been in operation in those countries for some years—the ‘Scandinavian’ model (Child Support Evaluation Advisory Group 1992).3 These schemes use maintenance ‘advances’ or ‘guarantees’ to ensure that lone parents actually receive child-support payments and then seek to recoup the costs of these from the other parent. Schemes of this type operate in Sweden, Denmark, Finland, Norway, Belgium, Germany and France. As with child support, the ways in which the schemes work—their coverage, eligibility criteria, duration, level of support given and so on—differ from country to country. Some (for example in Sweden and Denmark) have wide applicability while others (for example in France) are restricted to only certain groups of lone parents. The Swedish scheme can be taken as an exemplar of this approach.
The Swedish child maintenance system starts in the courts or, if the parents can agree, with their settlement, which is ratified by the court. The amount of child maintenance awarded is thus fixed according to individual circumstances and bargaining power but the Department of Social Welfare issues guidelines on how to calculate awards. If payments are then defaulted the lone parent can apply for a maintenance advance from the Department of Social Welfare, which the Department pays and seeks to recoup from the absent parent. Unmarried mothers can also apply for a maintenance advance without having to have a court award. The maintenance advance is flat-rate, tax free and paid regardless of the employment and family circumstances of the custodial parent. Use of the scheme seems quite widespread: in 1985 about 68 per cent of lone parents were receiving an advance, as were about 10 per cent of two-parent stepfamilies. In 1990 maintenance advances were paid for about 15 per cent of all children in Sweden (these figures all from Gustafsson and Klevmarken 1994:104). Of the total amount paid out in 1984 about 32 per cent was recouped from the absent parent, but this total includes cases where there was no requirement for repayment. If these are excluded then the amount recouped rises to about 78 per cent (Statistical Report of the Nordic Countries 1987). However, Gustafsson (1990) reports that the proportion of the advance collected from parents relative to the total paid out was falling throughout the 1970s, although the reasons for this are not clear.
This Scandinavian approach is very different from the Anglo — Saxon model in terms of both underlying philosophy and outcomes. The Anglo-Saxon model places the emphasis on the private responsibility of parents for their children. The state plays a secondary, essentially enforcement, role. This reflects a view that stresses private and individual responsibility backed up, but not taken over, by the state. The success of this approach, in terms of generating incomes for lone parents and their children, thus depends very much on two factors: on how effective that enforcement is and on the capacity of absent parents to pay. The Australian experience suggests enforcement can be significantly improved if sufficient resources are put into doing so. However, the American experience, which is of much longer standing and with more powers of enforcement, only produces collection rates typically in the region of 40 to 45 per cent (Child Support Evaluation Advisory Group 1992), so there are likely to be high administrative costs associated with keeping up payment levels. In terms of capacity to pay, both Australian and American research suggest that separated parents can pay more in child support than they have typically done in the past and still achieve an adequate standard of living. Nevertheless, such payments can rarely be more than a contribution to the incomes of lone parents—few men earn enough to support two households fully—and so even if 100 per cent compliance could be achieved this ‘private responsibility’ model can only achieve so much in relation to providing adequate support for children.
The Scandinavian model, by contrast, places much greater emphasis on collective support for children and the state plays a primary role in guaranteeing that support. Thus the maintenance obligation has become, in effect, a flat-rate benefit for children living with just one parent. The success, in terms of generating income for lone parents and their children, is therefore not dependent on either the willingness or the capacity of the absent parent to pay but on the level of resources that the government is willing to put into it. In addition, whereas the Anglo-Saxon child-support model acts to enforce the financial dependency of individual women upon individual men, the Scandinavian advanced maintenance model breaks this link; the income of the lone mother does not depend on the actions of the separated father.
Approaches to child maintenance thus cannot be separated from the more general approaches to the support of children in different countries and the extent to which this is seen as a collective or as a private responsibility. This point will be addressed again in the final section, but first we need to look at the third potential source of income for lone mothers: their own employment.