Andre lands modeller for å fremme sysselsetting blant personer med nedsatt funksjonsevne
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- NOVA rapport 
This report maps and compares contrasting models for labour market inclusion of persons with disabilities in selected European countries (Belgium, Denmark, Germany, Netherlands, Sweden, and the United Kingdom) and the United States. Building on a systematic review and reanalysis of the existing literature and statistics in the field, and assessments by national experts in the selected countries, the report discusses similarities and differences in the design and operation of national policies to promote labour market inclusion of persons with disabilities. The report examines the experience with different policy instruments, how they have been balanced and their relative impact for labour market inclusion of persons with disabilities in each country. By comparing overall policy packages to enhance labour market inclusion of persons with disabilities in the selected countries, the report identifies strengths and weaknesses in the existing approaches and clarifies the potential for policy learning in Norway. The report distinguishes three subsystems of the overall system to enhance labour market inclusion of persons with disabilities: An income maintenance system (e.g. cash transfers) A services system (e.g. mainly labour market measures; indirectly also services to enable independent living and transport) A social regulation system (e.g. legislation for the work environment, employment protection, non-discrimination and accessibility) A key concern in the report is the relative weight of and interaction between these subsystems within the overall national system. The findings confirm that different countries do not only use different policy instruments; their efforts to enhance employment for persons with disabilities do also have distinct overall profiles. Analysis of the diverse institutional contexts shows how these distinct policy profiles have been influenced by different national policy traditions, public-private divisions of labour and roles of social partners in the design and implementation of the labour market inclusion policy. The comparative analysis presented in the report concludes that the three Scandinavian countries (Denmark, Norway and Sweden) have been characterised by an imbalance among the three subsystems of disability protection (the income maintenance, services and social regulation system). Whereas policy-makers have intended and expected a mutually supportive and interdependent relationship between the three subsystems, the analysis found several indications that the income maintenance and services systems have been more strongly developed than social regulation measures for influencing the preferences and behaviour of the market actors. As a result of this imbalance Norway has achieved more equal standards of living and lower poverty risk for persons with disabilities than most OECD countries. On the other hand, Norway has not performed particularly well in promoting participation of persons with disabilities in the labour market (e.g. judged on the basis of available statistics from OECD), especially when taking into consideration the country’s affluence, comparatively high spending on employment-oriented services and high overall employment rate. Of the Scandinavian countries Sweden appears to have adopted the broadest set of policy measures within all three subsystems of disability protection. Whereas Norway spent relatively more resources on income maintenance, Denmark and Sweden spent relatively more on services. Out of the total expenditures on active labour market measures (ALMM), Norway allocated relatively more resources to income maintenance for persons participating in ALMM, while Denmark and Sweden channelled more resources in the form of subsidies for employers and fees for service providers Also compared to the other countries in the sample (Belgium, Germany, the Netherlands, the United Kingdom) and the United States), Sweden had developed a broader repertoire of policy measures in all three subsystems of disability protection. However, the Non-Scandinavian countries (except Belgium) had adopted stricter social obligations for employers than the Scandinavian countries: The Netherlands has introduced significant economic duties (negative economic incentives) for employers in the income maintenance and services system. The duties have contributed to a reduction in the number of recipients of income maintenance (except for youth claiming disability benefit). Yet, whether and to what extent the reforms have further an increase in the labour market participation for persons with disabilities is uncertain. Especially population groups falling outside the responsibilities of employers appear to have achieved few improvements in their opportunities to achieve paid work in the ordinary labour market. Germany has – in their social regulation system – operated an efficient quota system which imposes clear-cut duties on employers to include persons with disabilities in the labour force. United Kingdom and the United States have to a greater extent than the other countries adopted non-discrimination and preferential treatment obligations for employers in their legislation, but what practical effects the prominent role of such legal regulations have had is an issue of disagreement and controversy. Compared to the Non-Scandinavian countries, the Scandinavian countries have been more reluctant to strengthen the role of social – and especially legal – regulation of employers’ behaviour. The report documents and discusses the differences in role played by social and especially legal regulation among the Scandinavian countries: Of the Scandinavian countries Sweden has adopted stronger legal obligations for employers and Sweden has been one of the OECD countries with the strongest legal protection against employment discrimination. By contrast, Denmark has been one the OECD countries with the weakest employment protection and obligations for employers. Together with the Netherlands, Denmark has been the most prominent examples of European countries which aim to combine a high level of social security (generous income maintenance during time spells without paid work) and flexibility for employers to employ and dismiss employees («flexicurity»). The contrasts between the Scandinavian countries in this respect should, however, not be exaggerated. Since 1999 the Scandinavian countries have adopted new social regulations, to a large extent in response to the emerging supranational rights regime to ensure equal opportunities for all, including persons with disabilities, and more specifically in response to the policy developments in the European Union, the Council of Europe and the United Nations, and through more direct policy learning from United Kingdom and the United States. How active labour market measures have been organized and their impact for labour market inclusion of persons with disabilities, depend on patterns of institutional relations in the countries, i.e. relatively enduring features in the interaction (rules, norms, procedures) between welfare policy actors of importance for deliberation, decision-making and implementation of the policies to promote labour market inclusion of persons with disabilities. The Scandinavian countries and the Netherlands have spent more resources on ALMM than other OECD countries. The main trend is that the countries covered in the study aim to develop ALMM that further inclusion in the ordinary labour market and – to the largest extent possible – employment on ordinary conditions. The use of sheltered employment varies extensively among the countries but the main trend is that national authorities aim to move away from permanent sheltered employment to ALMM that may further inclusion in the ordinary working life. The trend should be understood in light of the emerging understanding of persons with disabilities as subjects with rights and not objects of other people’s concern, help and control. The use of wage subsidies has also caused concern that employees employed on a wage subsidy program will crowd out employment on ordinary conditions, e.g. by distorting competition in the market or cause the development of a secondary labour market with less favourable employment conditions and second-rate jobs (e.g. in terms of wages, job contents and career prospects) for persons with disabilities, and little transition to the primary and main labour market. All in all, a substantial challenge for the Scandinavian welfare states is to develop new and more fruitful ways of combining forms of social regulation policy with the most viable parts of their established income maintenance and services systems. The three countries still have a potential for intra-Scandinavian policy learning, as they have different profiles and priorities in their disability protection systems. For the new social regulation policy measures to be effective, the Scandinavian countries need innovative ways of diminishing the recurring fear that the costs associated with making workplaces fully accessible and accommodating them to the requirement of workers with disabilities will represent a disproportional burden for business and individual employers. With their strong tradition of public responsibility for compensating the personal disadvantages associated with having a disability, the Scandinavian countries ought to have a good point of departure for finding ways of socialising or sharing the costs related to ensuring accessibility and accommodation. The project was funded by the Norwegian Ministry of Labour 2010-11.Rapporten gir en systematisk framstilling av modellene for å fremme sysselsetting blant personer med nedsatt funksjonsevne som står utenfor det ordinære arbeidsmarkedet, og erfaringene med disse tilnærmingene i Belgia, Danmark, Nederland, Storbritannia, Sverige, Tyskland og USA. Funnene bekrefter at landene har forskjellige generelle tilnærminger til mulighetene for arbeidsmarkedsdeltakelse overfor personer med nedsatt funksjonsevne («pakker» av tiltak). Hvordan arbeidsrettede tiltak er organisert, og hvilken betydning slike tiltak har i landene beror på institusjonelle forhold i landene, det vil si varige trekk i samhandlingen mellom velferdspolitiske aktører (normer, verdier, arbeidsmåter) av betydningen for utformingen og iverksettingen av politikken for å fremme inkludering i og hindre utstøtning fra arbeidsmarkedet.