EDF answer to public
consultation on services to
long-term unemployed in the
Member States and at
EU level
May, 2015
35 square de Meeûs
1000 Brussels - Belgium
tel +32 2 282 46 00
fax +32 2 282 46 09
[email protected]
www.edf-feph.org
European Public Consultation regarding the provision of
services to long-term unemployed in the Member States and at
EU level
...................................................................................................................
The European Disability Forum is an independent NGO that represents
the interests of 80 million Europeans with disabilities. EDF is a unique
platform which brings together representative organisation of persons
with disabilities from across Europe. EDF is run by persons with
disabilities and their families. We are a front runner for disability rights.
We are a strong, united voice of persons with disabilities in Europe.
Introduction
Job creation and employment are one of the main objectives of the European
Union to foster economic growth. Several initiatives have been undertaken by
the European Commission (EC) to understand the labour market across the EU
and to develop adequate responses to reduce unemployment. In this context,
the EC launched a public consultation regarding the provision of services to
long-term unemployed in the Member States and at EU level. EDF answered in
consultation with its members.
EDF answer by highlighting the specific perspective of persons with disabilities
in the debate and the need for high quality of services, individualized support in
full compliance with the UN Convention on the Rights of Persons with
Disabilities. This document contains EDF full answer to the online survey
published by the European Commission.
35 square de Meeûs
1000 Brussels - Belgium
tel +32 2 282 46 00
fax +32 2 282 46 09
2
[email protected]
www.edf-feph.org
1. Challenges
In the context of this consultation, long-term unemployed are considered as
those that have been without a job for more than one year, but are actively
looking for a job and are willing to accept if they are offered a job.
Member States have different approaches to preventing and reducing long-term
unemployment in scope, timing and intervention schemes. There are also
significant differences across Member States in the share of long term
unemployed participating in active measures and in the length and coverage of
benefits.
The background document outlines several challenges to address long-term
unemployment.
Q1. Do you agree with the description of the challenges?
Yes
Q2. Are there any other challenges or aspects to address long-term
unemployment that should be taken into account? 2,000 character(s)
maximum
Persons with disabilities are frequently not considered potential members of the
workforce. Perception, fear, myth and prejudice continue to limit understanding
and acceptance of disability in workplaces everywhere. Myths abound, including
that persons with disabilities are unable to work and that accommodating a
person with a disability in the workplace could imply extra costs. Contrary to
these notions, many companies have found that persons with disabilities are
employable as anybody else.
Lack of accessibility and reasonable accommodation is another cause of
unemployment. Accessibility and reasonable accommodation are not only
related to the physical environment. Flexible working hours would benefit
persons with psychosocial disabilities. Additional barriers are face by people in
need of high-level support. For instance, the difficulties with communication and
social interaction that people with autism experience often affect their abilities to
participate in job interviews, understand employers’ expectations and
communicate with managers and colleagues. The same challenge is faced by
35 square de Meeûs
1000 Brussels - Belgium
tel +32 2 282 46 00
fax +32 2 282 46 09
3
[email protected]
www.edf-feph.org
heard of hearing people or visually impaired if they are not provided with sign
language interpretation of assistive technology.
Across Europe, there is a serious lack of adapted education and training that
could enable people with disabilities to gain the vocational, social and
communication skills that are required for work. These barriers to employment
are raised long before a person starts looking for a job. To enable people with
disabilities to gain employment and fulfil their potential at work individualised
and specialised support is needed.
2. Policy features
How do you assess the following policy features to support long-term
unemployed across the EU?
2.1. Integration of service provision
Cooperation between organisations delivering activation support, benefits and
social services resulting in one-stop-shop delivery. Such coordinated service
offer can include for instance activation support (e.g. training or subsidised
employment), benefits (unemployment or social benefits) and social services
(e.g. care or childcare). Collaboration may involve public and private
organisations, including social partners, education and training providers,
NGOs, voluntary organisations and social enterprises.
Q4.1 What is the level of integration of service provision to support the
long-term unemployed across the EU?
1 refers to 'no integration'; 5 refers to 'full integration'
3
Q.5.1 What services are missing in the integrated service provision across
the EU? 2,000 character(s) maximum
Specialised services developed on individual needs. In the case of people with
disabilities and people in need of high level support, such as people with
35 square de Meeûs
1000 Brussels - Belgium
tel +32 2 282 46 00
fax +32 2 282 46 09
4
[email protected]
www.edf-feph.org
intellectual disabilities, specific trainings and accommodation should be provided
when developing and designing employment services.
- Services that help the disabled persons and their families to reconcile
private and professional life. Adequate personal assistance services,
including personal mentor, job coach assistance at work.
- Accessibility and reasonable accommodation should be provided. This
would include ICT trainings, to develop the digital-competence or training
on how to use the mobile-applications.
- Peer support or peer counselling assist people with disabilities, young
people leaving care or who have started living independently, families at
risk of poverty or families reunited with their children, to become
empowered and self-confident in finding their own way through the work
ing environment. Such support should be provided by professionals and
non-professionals on equal basis between the counsellor and the client
(peers) through sharing of experience and assistance in gaining
autonomyand independence. Peer support is crucial for instance people
with psychosocial disabilities and people who used to live in institutional
settings who lack the knowledge and skills to live in the mainstream
environment.
- Accessible language training courses.
- Training on work planning, time-management, administrative skills, written
and spoken communication, trainings and support to work in team.
- Training on the UN Convention on the rights of persons with disabilities
should be provided to employers and service providers, as well as public
authorities.
Q6.1 What recommendations would you make to improve the integration
of service provision?
Persons with disabilities should not loose their disability specific allowance when
finding a job. These benefits are important to cover the extra costs due to
disability that the persons face. In this way benefit traps would be avoided as
well as the risk of in work poor. Services to the long-term unemployed should be
part of a broad plan of inclusion of persons with disability in the open labour
market and in the society as full citizen on an equal basis with others.
Services to the general population are not always effective to raise employment
of people with disability in particular those in need of high level support.
35 square de Meeûs
1000 Brussels - Belgium
tel +32 2 282 46 00
fax +32 2 282 46 09
5
[email protected]
www.edf-feph.org
Employment strategies should be design in close cooperation with persons with
disabilities, their families and their representative organisations.
Investment in education, including vocational education and training should also
be part of the strategy.
Defining the population of people at higher risk of unemployment and especially
long-term unemployment should be carried out and adequate budgeting and
social expenditure should be dedicated to those who need it the most.
Q7. How important is the integration of service provision in the support for
long-term unemployed?
Not important at all
Not important
Neutral
Important
 Very important
2.2. Individualised services to long-term unemployed
Tailoring services to address individual needs of those unemployed for more
than one year.
Q8. How relevant is it that services for the long-term unemployed are
individualised?
Not relevant at all
Not relevant
Neutral
Relevant
 Very important
Please, explain why:
We may observe an important employment gap between people with and with
out disabilities in all Member States. At European level, about 45,5% of persons
with disabilities are employed compared to 71,means that there is a potential for
35 square de Meeûs
1000 Brussels - Belgium
tel +32 2 282 46 00
fax +32 2 282 46 09
6
[email protected]
www.edf-feph.org
increasing the employment rate of people with disabilities. The recent evolution
indicates a decrease of the employment rate for both persons with and without
limitations. The employment rate of persons with disabilities decreased from
45,8% in 2008 to 45,5% in 2010. The employment rate of people with a
moderate disability is correlated with the employment rate of persons without a
disability. On the contrary, the employment rate of people with a severe
disability is loosely related to the employment rate of people without disabilities.
This means that measures that are aimed to affect the general population are
not expected to have a significant impact on people with a severe disability.
Source: Academic Network of European Disability experts (ANED)
Q9.1 To which degree are support services to long-term unemployed
adapted to individual needs across the EU?
Not individualised at all
Not individualised
 Somewhat individualised
Mostly individualised
Fully individualised
Q10.1 Does individualised service provision apply to most long-term
unemployed across the EU?
 Yes
No
Q11.1 How is the access to training for long-term unemployed across the
EU?
Not sufficient at all
 Not sufficient
Somewhat sufficient
Mostly sufficient
Fully sufficient
Q12. How efficient is the training of long-term unemployed in providing the
skills needed to re-introduce them effectively into the labour market?
Not efficient at all
35 square de Meeûs
1000 Brussels - Belgium
tel +32 2 282 46 00
fax +32 2 282 46 09
7
[email protected]
www.edf-feph.org
 Not efficient
Neutral
Efficient
Very efficient
Q13.1 Is there adequate start-up support for self-employment to long-term
unemployed across the EU?
Yes

 No
Q14. What recommendations would you make to improve individualised
services to long-term unemployed?
2,000 character(s) maximum
- Vocational education and training and occupational services should be
part of individualised working plans. These plans should be regularly
revised and updated. They should have the objective of reintegrating the
person into the open labour market.
- Training on personal development to restore self-motivation and selfesteem, and phrasing short- and long-term goals. Individual and group
training like coaching, supervision, mentoring
- Training on ICT, foreign languages
- Assistive technology would support accessibility at the work place. They
are currently not available, only few project call for procurement of
assistive technology free of charge. However access to the funds is very
difficult for small companies and requires guarantees which the employer
cannot always provide
- Internship and volunteering programmes should be accessible for persons
with disabilities
2.3. Mutual responsibilities
Setting minimum standards for the activation of persons unemployed for more
than one year with mutual binding commitments from both the individual and the
organisations delivering services. These commitments could be formalised
through individual action plans or other forms of written agreements.
35 square de Meeûs
1000 Brussels - Belgium
tel +32 2 282 46 00
fax +32 2 282 46 09
8
[email protected]
www.edf-feph.org
Q15. How relevant is the mutual responsibilities approach for
interventions for the long-term unemployed?
Not relevant at all
Not relevant
 Neutral
Relevant
Very relevant
Q16.1 Do the services provided to long-term unemployed across the EU
include the binding commitment from both the long-term unemployed and
the organisation delivering?
 Yes
No
Q17.1 How efficient is the enforcement of mutual responsibilities across
the EU?
Not efficient at all
Not efficient
 Neutral
Efficient
Very efficient
Q18. Should all services provided to long-term unemployed be subject to
mutual responsibilities?
Yes
 No
Q19. What recommendations would you make on the application of a
mutual responsibilities approach?
In some cases, persons with disabilities or low skilled employees could found
themselves forced into low-paid work. This is due to lack of accessibility and
reasonable accommodation provided to them in the open labour market.
35 square de Meeûs
1000 Brussels - Belgium
tel +32 2 282 46 00
fax +32 2 282 46 09
9
[email protected]
www.edf-feph.org
2.4. Adequate incentives and services for employers to employ long-term
unemployed
It includes direct support to employers who recruit, train or offer short-term work
experience to long-term unemployed. The support offered includes subsidised
employment, tax or social contribution reductions and post-placement support
and more general support to broad groups of employers (e.g. awareness
building among employers on hiring of long-term unemployed).
Q20.1 Do you know if there are incentives and services that are available
to employers to employ long-term unemployed across the EU?
 Yes
No
Q21.1 Are the incentives and services to employers at EU-level sufficient
to support the labour market integration of the long-term unemployed?
Not sufficient at all

 Not sufficient
Neutral
Sufficient
Highly sufficient
Q22. What recommendations would you make to improve the efficiency of
the services delivered to employers?
Raising awareness on opportunities to receive subsidies for employing long
term unemployed, including persons with disabilities, under the state aids
regulation and simplifying the procedures to access the funds.
Raising awareness and implementing public procurement directive in a way to
promote employment of people with disabilities.
Financial support using European Structural and Investment Funds, both
European Social Fund and European Regional Development Fund, to provide
training, employment and accessibility for persons with disabilities.
35 square de Meeûs
1000 Brussels - Belgium
tel +32 2 282 46 00
fax +32 2 282 46 09
10
[email protected]
www.edf-feph.org
Awareness raising among private and public employers about employment of
persons with disabilities, in particular women with disabilities and mothers of
children with disabilities (including on their potential, negative stereotyping,
accessibility needs and reasonable accommodation) by means of appropriate
state aid and training funded under the European Social Fund, and developing
benchmarking tools for the exchange of in formation and best practices across
the EU.
Enhancing civil dialogue with NGOs, trade unions and organisations of
employers by involving them in all steps of decision-making and implementation
processes with regard to the Employment Equality Directive.
The Commission to promote collective bargaining among social partners to
create an inclusive labour market for persons with disabilities. Special attention
should be paid to accessibility, reasonable accommodation and nondiscrimination;
The European job mobility (EURES) portal to be made fully accessible to
persons with disabilities, with specific sections dedicated both to persons with
disabilities travelling and working abroad as well as to girls and boys with
disabilities who travel or move to another EU country with their families;
Monitoring of the employment rate of persons with disability with a specific
indicator.
The inclusion of accessibility in the Council’s recommendations for quality of
traineeship in the EU.
3. EU-level action
Current EU-level action includes support to Member States in addressing longterm unemployment policies through mutual learning and the European
Semester process. Furthermore, ESF supports Member States' investment
priorities related to long-term unemployment and the reform of labour market
institutions.
35 square de Meeûs
1000 Brussels - Belgium
tel +32 2 282 46 00
fax +32 2 282 46 09
11
[email protected]
www.edf-feph.org
Q23. In your view, is there a need for further EU level action, targeted at
raising awareness and keeping political momentum for improving
effectiveness and efficiency of Member States' actions when tackling longterm unemployment?
Yes, the EU should define general principles for an effective activation
framework and recommending guidelines for measures to be used in Member
States
 Yes, the EU should recommend a set detailed guidance for the
introduction and development of an "individual activation offer",
bringing together the policy features described above into a
coordinated package of services. The guidance would include
required parameters to ensure effective outcomes, based on the
general principles for an effective activation framework
No, there is no need for further action at EU level
Q25. What consequences does this action have for the effectiveness and
efficiency of Member States' actions when tackling long-term
unemployment?
- increased coordination among countries with a direct positive impact on
the enjoyment of freedom of movement by people with disabilities across
the EU
- inclusion in the labour market of all citizens, irrespectively of the ir
disability or place of residence
- adequate implementation and enforcement of existing EU legislation
- facilitate the implementation of the UN Convention on the rights of persons
with disabilities in particular with regards to the right to work and
employment for people with disabilities, in particular people in need of high
level of support
- support MSs in reaching the common objectives set in Europe 2020
Strategy and the target of increasing employment rate up to 75%
- provide specialised guidance and objective perspective on what is are the
skills of persons with disabilities, including fighting against stereotypes and
stigma
35 square de Meeûs
1000 Brussels - Belgium
tel +32 2 282 46 00
fax +32 2 282 46 09
12
[email protected]
www.edf-feph.org
Q27.1 Please give your opinion on the following options as regards
possible changes in the activation support for the long-term unemployed
as part of common EU standards:
Very
Undesirable No
Desirable Very
undesirable
preference
desirable
No change to
X
current provision
Increasing the
X
participation
rate in activation
measures to longterm unemployed
on unemployment
benefits
Extending the
X
duration of
activation
measures to longterm unemployed
on unemployment
benefits
Increasing the
X
number of
activation
measures to
long-term
unemployed on
unemployment
benefits
Increasing the
X
participation
rate in activation
measures to longterm unemployed
on social
assistance/other
35 square de Meeûs
1000 Brussels - Belgium
tel +32 2 282 46 00
fax +32 2 282 46 09
13
[email protected]
www.edf-feph.org
benefits (other
than
unemployment
benefits)
Extending the
duration of
activation
measures to longterm unemployed
on social
assistance/other
benefits (other
than
unemployment
benefits)
Increasing the
number of
activation
measures to longterm unemployed
on social
assistance/other
benefits (other
than
unemployment
benefits)
Introducing an
individual
activation offer for
the long-term
unemployed
Introducing
mutual
responsibilities for
both long-term
unemployed and
35 square de Meeûs
1000 Brussels - Belgium
X
X
X
X
tel +32 2 282 46 00
fax +32 2 282 46 09
14
[email protected]
www.edf-feph.org
organisations
delivering
services to them
Providing a single
point of
contact/one stop
shop for longterm unemployed,
irrespective of the
form of benefits or
support services
provided
X
Q28. Please rank the following categories of long-term unemployed
according to how important it is that they are eligible for intensive
support, e.g through an "individual activation offer"
Long-term unemployed that are:
Please note that you can only choose one category per level of priority. It is not
possible to assign two or more categories with the same level of priority.
Lowest
Low
Medium
High
Highest
priority
priority
priority
priority
priority
Aged under
X
24
Aged 25-35
X
Aged 35-45
X
Aged 45-55
X
Aged over
X
55
Long-term unemployed that are:
Please note that you can only choose one category per level of priority. It is not
possible to assign two or more categories with the same level of priority.
Lowest priority Medium priority Highest priority
Low skilled
X
35 square de Meeûs
1000 Brussels - Belgium
tel +32 2 282 46 00
fax +32 2 282 46 09
15
[email protected]
www.edf-feph.org
Medium skilled
High skilled
X
X
Q29. Do you have any other comments?
Persons with disabilities are protected against discrimination in employment and
occupation by the Employment Equality Directive. However, the effectiveness of
this Directive is limited due to its problematic implementation today in the EU.
This is caused by the extremely low level of awareness about disability rights
and inadequate understanding of the law, particularly of the concept of
reasonable accommodation, by most parties affected by the Directive, including
judges, persons with disabilities and employers. Serious financial, procedural
and information barriers to seek redress from discrimination and inadequate
procedures for victims’ support and representation are undermining the impact
of the legislation.
The Commission has created an online portal for mobility of workers across the
EU, which provides comprehensive information for workers and employers,
including information on living conditions in another country.
Unfortunately the portal is not fully accessible and provides little specific
information for workers with disabilities and for workers with children with
disabilities.
The EU identified reduction of unemployment as a priority at least until 2020. On
the basis of European Union Statistics on Income and Living Conditions 2012
(EU-SILC), the employment rate of persons with disabilities is about 24
percentage points lower compared to persons without disabilities (25 pp in 2011
and 26 pp in 2010). About 47.9% of persons with disabilities are employed
compared to 71.5% of persons without disabilities (the Europe 2020 target for
EU is 75%). The employment rate of women with disabilities is lower than that of
men with disabilities. Also mothers of children with disabilities face
discrimination with regard to hiring procedures, salary and social security
payments. This has a direct impact in influencing national economic reforms to
fight poverty and exclusion and reduce unemployment and schools dropout
rates.
An important factor affecting the employment, but also the unemployment and
inactivity rate, is the degree of disability. At EU level severely disabled persons
are at higher risk of exclusion from the labour market than moderate or non-
35 square de Meeûs
1000 Brussels - Belgium
tel +32 2 282 46 00
fax +32 2 282 46 09
16
[email protected]
www.edf-feph.org
disabled persons. This means that measures aimed at the general population
will not impact on persons with severe disabilities.
The Council of the European Union adopted recommendations for quality of
traineeship in the EU[viii]. Young people with disabilities however are
disregarded in particular, as accessibility is not included among the criteria to
provide a high quality traineeship programme in the EU.
The EU upon ratifying the UN CRPD made a reservation with respect to Article
27, 1 in so far as it allowed Member States to make an exception for the armed
forces. The 2010 Employment Equality Directive states that “Member States
may provide that this Directive, in so far as it relates to discrimination on the
grounds of disability and age, shall not apply to the armed forces”.
The generalised exception of application of the Employment Equality Directive
to the armed forces is discriminatory and runs against the object and purpose of
the UN CRPD.
The European Court of Human Rights in the case Glor vs. Switzerland, ruled
that banning persons from service in the army on the basis of disability
represents discrimination contrary to Article 14 of the European Convention on
Human Rights and Fundamental Freedoms.
EU Regulation 651/2014 (general block exemption regulations regarding state
aid) allows national governments to give state aid to employers for covering the
costs of employing and training persons with disabilities. The potential impact of
this is very positive if awareness is raised about the disability specific provisions
and there is adequate monitoring of its implementation.
We call for:
Awareness raising among private and public employers about employment of
persons with disabilities, in particular women with disabilities and mothers of
children with disabilities (including on their potential, negative stereotyping,
accessibility needs and reasonable accommodation) by means of appropriate
state aid and training funded under the European Social Fund, and developing
benchmarking tools for the exchange of information and best practices across
the EU;
Enhancing civil dialogue with NGOs, trade unions and organisations of
employers by involving them in all steps of decision-making and implementation
processes with regard to the Employment Equality Directive;
The Commission to promote collective bargaining among social partners to
create an inclusive labour market for persons with disabilities.
35 square de Meeûs
1000 Brussels - Belgium
tel +32 2 282 46 00
fax +32 2 282 46 09
17
[email protected]
www.edf-feph.org
Special attention should be paid to accessibility, reasonable accommodation
and non-discrimination;
The European job mobility EURES portal to be made fully accessible to persons
with disabilities, with specific sections dedicated both to persons with disabilities
travelling and working abroad as well as to girls and boys with disabilities who
travel or move to another EU country with their families;
Monitoring of the employment rate of persons with disability with a specific
indicator, and including information in the Annual Growth Survey when defining
the priorities of the National Reform Programmes and Country-specific
Recommendations;
The inclusion of accessibility in the Council’s recommendations for quality of
traineeship in the EU;
The withdrawal of the general reservation on non-discrimination in employment
in the armed forces to the Convention;
The European Commission to monitor the use of the European Social Fund to
promote employment and training of persons with disabilities. Organisations of
persons with disabilities should be regularly invited to the meetings of the Social
Fund Committee to ensure meaningful participation in the monitoring of the
Fund.
Acknowledgments
This position paper has been prepared in consultation with EDF members and
experts. EDF would like to thank the National Council of Federations of People
with Disabilities (FESZT) and all those that have actively contributed to the
drafting of this paper.
Contact person at the EDF secretariat:
Simona Giarratano, Social Policy Officer
Tel: +32 (0) 2 503 12 27, Email: [email protected]
Should you have any problems in accessing the documentation, please contact
the EDF Secretariat. (Tel: +32 (0) 2 282 46 00, Email: [email protected]).
35 square de Meeûs
1000 Brussels - Belgium
tel +32 2 282 46 00
fax +32 2 282 46 09
18
[email protected]
www.edf-feph.org