Introduction

The introductory chapter to this book defined workfare programmes or schemes as those which ‘require people to work in return for social assistance ‘benefits’. Contributors who, in Chapters Two through Eight, have sought to describe the most ‘workfare-like’ programmes in operation in each of the seven countries have used this definition as a starting point. This chapter considers differences and similarities in these programmes.

In order to simplify comparison, the focus in this chapter is on just one example of a workfare programme from each country. The programmes chosen represent the purest current form of workfare in that country – the programmes which exhibit the strongest ‘compulsory element’, the greatest ‘work-relatedness’, and which are most clearly targeted at social assistance clients. A more representative picture of the range of related policies in operation in each national setting is obtained through reading Chapters Two through Eight.

Programmes chosen to represent the six European countries are: RMIbased insertion (France); Help Towards Work (Germany); the Jobseeker's Employment Act (JEA) for young people (the Netherlands); local authority schemes resulting from the 1991 Norwegian Social Services Act (Norway); activation (Denmark); and, the New Deal for Young People (the UK).

In Germany, France and Norway national legislation is reinterpreted locally to such a degree that a different programme might be considered to exist in each locality. To accommodate this, an ‘overall’ picture of the programme (or set of schemes) is given from a national viewpoint and the extent of intra-national variation is indicated. Three programmes for claimants of Temporary Assistance for Needy Families represent the US (New York City, Wisconsin and California); these are described in Chapter Eight. The programmes compared here are not representative of the totality of programmes in each country – the three US programmes represent three of the most developed forms of workfare in the US.

This list does not include any of the ‘opt in’ programmes for young people who are not otherwise entitled to state support, such ‘opt-in’ programmes have been described in chapters on French and British workfare (Chapters Two and Seven). While there is a sense in which these can be understood provide a very stark choice for potential participants, as there is no benefit alternative, they are difficult to compare to programmes which have a stronger relationship to social assistance.