Joint reaction of Association of Youth with Disabilities of Montenegro and Institute Alternative

The allegations of Deputy Minister of Labour and Social Welfare published in the article of Daily news „Pobjeda“ entitled “Equal Opportunities for all”, has challenged AYDM and Institute Alternative to once again argue the reasons why is necessary to make a new Proposal of the Strategy for Development of Social and Child Protection for the period 2013-2017.

In the introductory part of the text reads: “The Ministry of Labour and Social Welfare concluded on Monday a public discussion on a three-year strategies on development of social and child protection and on social protection of elderly people”. However, AYDM claims that the Ministry issued a public call for consultations which lasted for 15 days from the May 27th, when the public call was made. During the consultations, Ministry held just one round table, on June 4th in Podgorica, although the Working Group had agreed to hold a round table for the northern region of Montenegro, in Bijelo Polje. This situation along with the tight deadlines for consultations breached the practice of making consultation process fully transparent and accessible to all.

AYDM disagreed with the statement that the proposed Strategy is based on the norms and standards of international documents and conventions, since these documents have arised from serious and thorough analysis of the situation and needs, which certainly have dropped out during the drafting of the proposed Strategy.

Proposal of the Strategy does not contain a report on the impact of the previous Strategy and identifies neither problems nor results that have arisen during the implementation of the previous strategy.

IA submitted similar comments on the proposed Strategy to the Ministry, in which it concludes that long-term results of the social and child protection reform are not envisaged, especially when it comes to the development of social services. IA considers measures for achieving the specific goals inadequately explained and expected effects of their implementation unsubstantiated.

Also, it remains unclear how it is expected “from this strategic document to provide an adequate level of social and child protection, create equal opportunities for all citizens, prohibit social exclusion and discrimination,” when certain vulnerable groups (e.g. homeless) are not even mentioned in the document. In its comments, IA pointed out that the Strategy does not include the analysis aimed at establishing the records of homeless people. It does not provide separate measures which would improve the status of this population either.

The proposed Strategy states that the main deficiencies of the existing system, are primarily caused by:

a) the lack of indicators for identification of vulnerable and social groups and other subsets;

b) the lack of system for monitoring the needs of socially vulnerable groups as well as the lack of records of undertaken protection measures.

Apart from these indicators defined by the Proposal of a Strategy, there are no qualitative indicators for the monitoring of the Strategy’s implementation or information that any analysis to identify the needs of population is done, although this activity was included in the previous Strategy.

AYDM and IA believe that the Ministry should also especially pay attention to defining these indicators in order to meet the needs of the population and substantiate the claims that this document provides equal opportunities for all.

AYDM and IA consider that the statement of the Deputy Minister- that “strategy must be adopted as soon as possible“ – is not eligible if we bear in mind that the new Strategy should have been adopted by December 2012. In addition, we believe that aligning the strategy with the legal framework is not “just a formality“ as the Deputy Minister stated, regarding the fact that the proposed Strategy is completely based on the provisions of the Law from 2005. The long-term priorities in the field of social welfare are thus based on the provisions of the Law which is to be abolished soon. That questions the whole approach during the Strategy drafting process. Superficial approach during the Strategy drafting is also reflected by the fact that the deadlines for the implementation of the measures proposed in the action plan is utterly inconsistent with the terms provided in the new Law on Social and Child Protection.

According to the claims stated in this release, IA and AYDM once again urge the Ministry of Labour and Social Welfare to make a new Proposal of the Strategy aligned with the new Law. If the Government adopts the current proposal as the new national strategic framework, it will undermine the true intentions of the Ministry of Labour and Social Welfare, to enhance social and child protection reform and improve the quality of life of the citizens of Montenegro, especially of vulnerable groups.


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