Proposed Strategy for development of Social and Child Protection relies on the abolished law and thus questions the long-term reform efforts in this area. Proposed Strategy reflects a superficial approach and the indifference of the state in defining long-term priorities in social and child protection.
In order to pinpoint certain inconsistencies, remind on the forgotten but planned measures and activities and give guidelines for further work on the new strategic framework, IA submitted comments on the proposed Strategy to the Ministry of Labour and Social Affairs.
IA pointed out the mismatch of the legislative and strategic frameworks. Exception from the practice to first adopt a strategy and define long-term priorities, and then the Law as a concrete measure, makes even more meaningless the fact that the proposed strategy relies on outdated terminology and provisions of the Law from 2005. The Ministry of Labour and Social Welfare, as the proponent of the Strategy, thus brings unnecessary confusion and raises doubts whether its true intention is to enhance the social welfare reform and improve the quality of life of the Montenegrin citizens, especially of vulnerable groups.
The role of the Institute for Social and Child Care, whose establishment is envisaged by the new Law on Social and Child protection is not sufficiently promoted in proposed Strategy as the future coordinating body for the development of social services network. Moreover, the proposed Strategy does not even acknowledge the social services as a special right in social and child protection system, although the emphasis of the reform is on of the development of non-institutional forms of protection.
Proposed measures to achieve specific objectives of the strategy are not adequately explained nor the expected effects of their implementation justified.
While justifying some of the proposed measures, proposed Strategy calls on expert analyses, which are not publicly available and the public is not even aware that they are carried out.
The deadlines for the implementation of the proposed measures in the action plan are completely incompatible with the deadlines for the preparation of the by-laws deriving from the new Law on Social and Child Protection.
Proposed Strategy for development of Social and Child Protection needs to be withdrawn in order to create the Strategy aligned with the objectives of the reform and based on the new legislation and deadlines provided by Law. As the exception from the practice to first adopt a strategy has already been made, then further extension of the deadline for the adoption of the Strategy would not cause any damage if the proponent has a genuine intention to enhance social and child welfare reform.