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Zsolt Temesváry

Policy Transferability

What does the transferability of various policies mean? Is it possible to transform one

policy into another in a way that preserves its original characteristics and design, or at least

does not lose its general functions? It is quite hard to answer such questions without knowing

the general features of policy adaptability. This section aims at analyzing the general

characteristics of “policy learning” and in a wider context the process of “policy borrowing

and lending”. We look for models, theories and practices relating to the conditions of

transferability and adaptability of various policies. Furthermore, we try to describe and

understand the whole process of “policy borrowing” from the starting point of detecting good

practices to the final stage of introducing new policies in place of former ones. First, we

describe the various theories and approaches related to the transferability of policies. We

summarize the simple models of “policy learning” and models of “how to acquire good

practices”. We also analyse more sophisticated approaches on the subject such as the theory

of “policy borrowing and lending”. Second, we examine the borrowing and lending process

of social policies in a historical context, with particular emphasis on modern welfare states.

Third, we try to identify how the theory of policy borrowing can be applied to the worldwide

proliferation of conditional cash transfers.

The globalization of policies

Globalization is a phenomenon which, at least from a practical perspective, describes

the international flow of various technologies, products and labour. But how can we add

issues like knowledge, learning and intellectual property to this list? Once we identify

practices which work well in one country, how do we know whether they will work in another

country as well? Can we build up a ‘world class model’ as a panacea for the social problems

of various states or regions? In other words, do similar conditions demand similar responses?

Banks et al. (2004) gave a two-fold definition of globalisation in social policy. On the

one hand, it means an undisputed pressure on nation states to change former policies inside

their borders and to join international trends. On the other hand, globalisation also facilitates

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the easier transferability of various policies among countries or regions. There are many

factors which contribute to the internalisation of policies. The first and the most relevant of

them is the technical factor. Rapid development in the communication sector created new

technical possibilities (by analyzing and learning new methods), and thus new options for

policy transfer. International conferences, workshops, study tours and the English language

academic literature have all helped to make national policies available to other countries for

adaptation. The second component of policy internalisation is the methodological factor. In

the past ten years, researchers have increasingly relied on comparative analysis (a method of

studying foreign policies and then comparing them to each other) as a way to evaluate

international trends and regimes. Comparability allows experts to examine various systems

simultaneously according to a given set of criteria. The third factor is the ‘paradigm shift’ we

have observed in the evolution of international policy making. Governments (especially those

in the developed world) have discovered the importance of conscious and deliberate policy

making. As a result, regimes have gradually moved to employ the model of ‘evidence-based’

policy making. Methodological developments in disciplines like economics, sociology and

psychology enabled the introduction of new technical methods into policy making. ‘Evidence-

based policy making’ presumes that ‘evidence’ can be found not only inside but outside the

borders of the nation state -makers are particularly interested in looking at practices in other

countries for comparison purposes, because doing so is easier and cheaper than creating

reference groups and pilot projects at home. Therefore, the identification of comparable

policies abroad has become a widely popular method in international social (and other) policy

making. In addition to its technical efficacy, this method also enabled researchers to draw

conclusions regarding the absolute and relative results of a program. Furthermore, such a

comparative approach allows us to place our results in ‘time and space’. The fourth aspect of

the globalisation of policy making is the role of intermediaries. International organizations

like the World Bank and the IMF (as well as the OECD and WTO) assist countries in

employing the new models and methods which proved successful in other countries. These

institutions often condition their financial support on the introduction of preferred policy

models. Due to these conditions, the supported countries have seen the evolution of a special

mixture of policies over time. It is often quite difficult to decide whether a policy is

‘transferred’ or ‘indigenous’.

The globalization of social policies can appear in many forms. One example is when

richer countries take some form of responsibility for countries with less developed economies.

This responsibility is not always a generous action, as it sometimes serves mutual goals in a

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bilateral or multilateral partnership with implications for the policies of the affected countries.

For instance, mass migration has social implications even for those states that are not directly

affected by the problem. Since mass migration inflicts a burden even on third-party countries

due to its spill-over effects, developed states are just as interested in dealing with the issue

(Castles and Miller 1993).

According to Deacon et al. (2009) supra-national tendencies in social policy appear at

least in three forms: supra-national regulation, supra-national redistribution and supra-national

services. Many of the new rules that originate from the common social regulation of the EU

break through the traditional boundaries of nation-states. Deacon argues that the model of

Open Method of Coordination (OMC) is applicable outside the borders of the EU, and similar

social legislation could be implemented in other international organizations (such as the

African Union and the United Nations). Social issues could also be discussed in extended

versions of global regulatory papers (Lang and Hines 1996) on related areas (like climate

change or economic growth) of social policy. Adding social issues to the original concept of

these papers would cause a firm shift towards more equitable policies. Considering not only

the economic but also the social problems, these concepts would evolve to fit the notion of

global thinking. Another form of supra-nationalism of social policies is ‘global redistribution’,

or at least the global thinking about redistribution. The base concept of this kind of

redistribution is that richer countries financially support poorer ones in order to improve their

economic and social status. This practice is widespread in the EU’s regional policy and it has

traditions going back decades. In its Human Development Report, the United Nations

recommends the creation of global institutions. Furthermore, the UN supports the introduction

of a progressive income tax system which is necessary due to the globalisation of societies.

These common institutions and methods would help the flow of income from rich states to

poorer ones and would reinforce the UN itself. The third form of supra-nationalism

constitutes those welfare benefits and services that reach over national governments.

International welfare networks (where services and payments are transferable from one

country to another according to international agreements) are not particularly widespread

outside the EU. Even among the EU member states, it is often problematic to carry social

rights and benefits from one country to another. Weale (1994) argues that unified social

policies in the EU could mitigate the xenophobic worries that arose in the ‘old’ member states

due to expectations of ‘welfare tourism’ from the new member states. Deutsch (1981, in.

Deacon 2009:10) takes a deeper look into the internationalization of social policies, and

suggests the establishment of an international welfare system. Such unification of social

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transfers would have been likely to succeed in the EU-15 of the early 1980’s, before financial

and demographic problems started to threaten the EU welfare states and before the poorer

Eastern-European states were integrated.

Georg Vobruba (2004) argues that globalization has made an impact on the European

Social Model. According to his definition, globalisation is a process that enhances the

competitiveness of markets and the worldwide flow of goods, services, financial resources

and labour. Globalisation, based on the capitalist world economy, exerts an influence that is

sometimes delayed but never avoided. Globalization promotes mutual dependence among

regions which are far from each other, and the dependency it creates serves as a constant

source of uncertainty. Nevertheless, Vobruba recognises that globalisation is the only path to

modernity, even if it creates new social risks not experienced before. These new risks are

generally the reason why opponents of globalization keep their faith in the nation-state and

attempt to maintain its obsolete structures. A typical example of these tendencies comes from

Bismarckian Germany, where safeguard duties were introduced against imported agricultural

products. Consequently, the German agricultural sector was destroyed by high food prices and

the retaliatory response of other countries. In addition, the high tariffs lead to lower duty

revenues. In light of these global trends, the role of social policy is to make global changes

acceptable to the victims of the process by mitigating the social burdens and risks. This

compensation is particularly important when it comes to disadvantages resulting from

increased labour market disparities. By creating jobs, globalisation increases the tax revenues

of states and thus provides the financial base for the social risk mitigation efforts. The

provision of a guaranteed annual income is possibly the best method for alleviating social

disadvantages, as it helps maintain the standard of living amid the new economic and social

circumstances.

Offe (2003) argues that an integrated European Social Model (ESM) could provide the

basis for the transferability of eligibilities, so that inter-European services could be

implemented in all member states. If the process were driven by economic interests, the

poorer Southern and Eastern European states would widely support the integrated ESM

(particularly with a firm redistributive effect) with the hope of eventually profiting from it.

However, Offe warns that the issue is much more complicated than mere concerns over

financial feuds in transferring money from the rich to the poor countries. Variation in social

expenditures across countries is due to differences in economic development. However, the

discrepancies also reflect different interests, values and attitudes towards welfare issues.

Differences in the structures and history of welfare regimes also complicate the introduction

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of a unified European welfare regime. Offe points out that while economic issues generally

have regulatory overtones, social issues always have redistributive features which ask of us if

we are ready to reach into our pocket.

Policy learning

Phillips (2000) describes the process of policy transfer as “learning from elsewhere”, a

term that captures the basic concept of policy adaptation and summarises the core message of

the trend. Philips’ definition does not completely reflect the meaning and usefulness of the

phrase “policy transferability”, since “learning from elsewhere” implies a simple copy-paste

process without taking into account the real importance and novelty of the concept. Policy

learning always refers to “a change in thinking” (Kemp and Weehuizen 2005:5). This is not

only a singular change, but the array of continuous and conscious changes, which finally lead

to the introduction of new policies and the replacement of former ones. The process begins

with the recognition of new policies and the wish to rethink and reform (or replace) previous

ones in order to make them more effective or equitable. Johnson and Lundwall (2001) argue

that knowledge is the key factor in the process of policy adaptation, as it contributes to the

transferability and entrenchment of different policies. In their explanation, knowledge is a

well-structured information chain through which policy transformation can be constructed.

Knowledge appears as a form of processed information that is meaningful to informed agents.

The authors differentiate four types of knowledge which influence transferability. Know

“how” is the ability to do something, know “what” refers to the knowledge about facts, know

“why” points to the knowledge about corresponding principles and laws, and know “who” is

the knowledge about ‘who knows what’. Knowledge becomes collective through codification

(laws, norms etc.). Therefore, formal knowledge can be stored and transferred as information.

Kemp and Weehuizen (2005:9) highlight another important key factor of policy learning: the

process through which new information is acquired and internalized. They consider learning

as a shift in habits and thoughts that eventually changes former behaviours. But what

distinguishes individual learning from collective or institutionalized learning? Collective

learning, or in other words “organisational learning“, refers to a process where an entire

system is involved in the change. This kind of systemic learning consists of various

participants even beyond the boundaries of the organization (NGOs, other outside supporters,

knowledge centres, etc.). Policy learning is always an institutional learning, because policies

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imply the presence of organizations through which they are implemented. According to

Argyris (1976), the learning process can be classified in three ways based on the traits of the

practice. Instrumental learning refers to the learning of instruments (techniques) and their

effects on goals. Conceptual learning is a kind of problem-learning which refers to the fact

that learning is accompanied by the introduction of new concepts and principles. The third

way is social learning, which covers ‘higher aims’ like norms, responsibilities or causes and

effects.

The term “policy learning” is different from “policy borrowing” in its general

functions and goals. Raffe (2011:2) distinguishes policy learning from “borrowing” based on

differences in their functions and the situations they are used in. Policy borrowing always

searches for available ‘best practices’ to be integrated into the development of a certain

system. On the other hand, ‘policy learning’ refers only to the phase of knowing and

understanding, and does not necessarily imply the implementation of the chosen policy.

Naturally, “policy learning” can also incorporate the identification of appropriate programs,

and the creation of transferability conditions for the entire system or its individual

components. Thus, learning can serve as a process leading to adaptation, or can be useful in

and of itself. Raffe (2011:3-4) identifies five general questions or ‘golden rules’ as guidance

for decision makers in the process of policy learning. First, the collection and examination of

international experiences should be used to serve the enrichment of the methodology of policy

analyses. It should never be used as a ‘quick-fix’ solution for difficult problems, even when it

is tempting to do so. Second, governments should look for ‘good’ but not best practices, as the

latter are sometimes vague and difficult to determine. Good practices can be selected through

comparative analyses. However, such practices continuously change along with the

environment in which they are to be implemented, and therefore can only rarely serve as a

general model through time and space. Focusing on the exclusive study of good practices is a

general mistake of governments who search for alternatives to replace their present systems.

Third, a comprehensive approach can help identify system failures, isolate components which

complicate adaptation and give a broad perspective on the problem to be solved. Fourth,

international experiences are very useful not only to find and choose good practices but to

identify the weak points of domestic policies. The identification of similar problems in similar

countries can help policy makers identify and re-examine the true nature of problems in the

host country. This approach provides the opportunity to observe numerous solutions (or at

least some efforts) aimed at the core problem and to choose the most suitable one. Fifth, the

nature of the core problem and its location in time and space is important. Learning from the

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past and looking at the problem from a historical perspective can help us avoid and prevent

wrong decisions.

How to learn or study new policies

In their overview, Bennett and Howlett (1992) draw attention to three aspects of the

learning process: who is learning, what is learned and to what effect. The method of learning

new policies is described by Kemp and Weehuizen (2009:17-19) as a sequence of tasks that

participants need to complete. First, decision makers have to differentiate between three types

of policy learning: technical learning (about instruments), conceptual learning (about goals,

strategies) and social learning (about values, responsibilities and policy approaches). Second,

they should identify the material to be learned. It can be done by analyzing existing

documentation, project assessments and evaluation reports covering the entire program. The

most useful way of obtaining up-to-date information is the direct method, whereby decision

makers and experts on the subject are personally interviewed and programs are empirically

examined. Third, it is important to test whether the actors learned the lessons of technical,

conceptual and social learning. This can be done by observing participants, or with the help of

pilot projects which can function as a filter to find good practices or discard the faulty ones.

On the fourth stage, analysts should assess what role this learning has played in the policy

change. This can be done by examining the institutions which incorporate the effects of policy

changes. Technical elements of learning are relatively easy to analyze but aspects like

changes in values and interests are quite difficult to assess. How can we select from the many

variables and changes that reflect the effects of a policy newly introduced into an institution?

To get sufficient information on the subject, institutions should be analyzed as thoroughly as

possible. Long-term evaluations might also be necessary.

Kemp and Weehuizen emphasize that attention should also be paid to those practices

that are eventually discarded. Before the implementation process, experts regularly project

and/or observe many promising scenarios from which only one will be selected for

implementation. Thus, policy reforms are regularly accompanied by many good practices, all

of which seem worth implementing. If they are all functional and feasible, which policy

should be implemented in the end? This question should be answered by the organisational

culture and the role of incentives. Kemp and Weehuizen (2009:21) argue that in systems

where new structures are not carefully deliberated, perverse incentives lead to perverse

responses. They mention the Dutch health care reform as an example, with a particular focus

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on a section that addresses psychiatric care. The authors highlight that the general regulation

of the sector was managed directly by government bureaucrats, whose expertise on

professional issues was firmly questionable. As a result of the measures, the time length of

psychiatric care was significantly shortened despite the fact that the patients had related

problems that would have necessitated a variety of other treatments. Shortening the term of

psychiatric care reduced direct expenses, but also increased total costs. Rising costs were due

to the increase in the number of nursing days, as patients had to be re-registered in the system

every time a new disease was diagnosed. The Dutch experience is a typical example of the

type of perverse incentives that arise when the actual needs of patients and the traits of the

target group are not taken into account during the decision process.

Chapman (2002:13) analyzed the possible hurdles of policy learning in the public

sector. He pointed to several internal factors which tend to hinder successful learning. He

mentioned (inter alia): the pressure on stakeholders to learn and introduce new policies, the

hardships caused by deficient or missing evaluations, time pressure that leads to

inefficiencies, etc. If policy making is such a complicated process, what motivates policy

makers to do it? Berry and Berry (1999) draw attention to the technocratic process of ‘policy

transfer’. This term refers to the situation where policy learning and dissemination is not a fair

transfer between equal partners, but is instead a convergence competition among countries

who hope to catch up with the developed states. This competition is similar to the economic

policy efforts developing countries undertake in order to reduce economic disparities.

Diamond (1998) has an even gloomier assessment of policy transfers between developed and

emerging countries. In his opinion, developed states are not interested in lending good

practices to poor countries. Rather, rich states attempt to take advantage of poorer ones by

exploiting their existing ‘weak’ policies, which were designed in the first place to protect the

economic interests of the developed world.

According to another theory on policy transfers, transferability is mainly driven by the

democratic process that defines the politics of modern states. This is because the democratic

electoral system implies that modern democracies are able to periodically remove bad

practices and introduce new (better) ones. This is a rather optimistic point of view, based on

the assumption that a democracy can function as a purifying system based on internal

‘offsetting’ mechanisms, able to resolve policy-based problems alone. Banks et al. (2004:6)

states that bad policies are often introduced when a regime needs fast reforms due to outside

pressure. The natural desire to find good practices is not always enough. The implementation

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of hastily designed policies leads to rushed and ill-considered actions which occasionally

undermine the functionality of reforms.

Policy borrowing and lending

The international literature on the subject of policy borrowing and lending is limited,

as only a few experts go beyond the theoretical boundaries of the general “how to learn good

practices” approach. According to Dolowitz and Marsh (2000, in. Feenstra 2010),

transferability of policies refers to “a process in which knowledge about policies,

administrative arrangements, institutions and ideas in one political system (past or present) is

used in the development of policies, administrative arrangements, institutions and ideas in

another political system”. Dolowitz and Marsh interpret policy borrowing and lending as a

two-way process where both the borrower and the lender partners are actively involved in the

exchange, and are both interested in making the transfer successful.

In her theory of “policy borrowing and lending”, Steiner-Khamsi (2004) also points to

the transfer of policies as a two-way process. This is in contrast with the traditional “one-

way” approach where an actor receives good practices from another. Her theory assumes two

active participants in the process: one who learns and imports from elsewhere (borrower) and

the other who sees what can be taught and exported to elsewhere (lender). In order to borrow

and lend certain policies and to justify the necessity and usefulness of doing so, local decision

makers must foresee three factors. First and most important, they have to see why it is

necessary to change, modify or even replace existing policies and why they need to introduce

new ones. The urge to modify existing policies can originate from the malfunction or political

unpopularity of the existing policy. Since the perception on the unsuitability of the old policy

is rather subjective, it is useful to evaluate and test existing policies before the change is

introduced. The reforms are sometimes lead by emotional rather than rational considerations.

At the selection stage, decision makers often prefer those policy traits that better fit their own

tastes, failing to take into account the relevant features of the chosen practice. The lack of ex-

ante evaluations, pilot projects and assessments of the possible outcomes can mislead the

stakeholders, and result in poorly designed projects that do not address the real needs of the

target groups. Sometimes it takes less effort to modify or enhance former (and already

operating) policies than to take risks by introducing new ones. For example, Tomasz Inglot

(2008) points out that Eastern European countries in transition were very eager to implement

and learn foreign policies without assessing the potential consequences.

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Second, decision makers must have a good understanding and oversight of the entire

process from the early phase of introduction through implementation to evaluation. Forced

introduction based on partial information can be more dangerous than useful. Therefore, local

policy makers must acquire the knowledge that is necessary to provide an appropriate

environment for the adaptation. Lack of ex-post impact assessments and the neglect of social

and economic factors may render the program dysfunctional in practice. In other words, more

efforts at the planning board translate into fewer problems in practice. Appropriate overview

of the entire process can ensure the feasibility of implementation. Of course, this does not

mean that supervision should be concentrated in one hand. Rather, the technical framework

and the implementation procedure should be shared among various participants while

ensuring that decision makers have complete oversight of the process.

According to Steiner-Khamsi, the third stage of the borrowing and lending process is

the ex-ante identification of the participants and beneficiaries affected by the envisioned

measures. Policy-related decisions must reflect the interests of well-defined target groups.

Without the precise identification of beneficiaries, there is no point in planning a program.

The situation and needs of potential users should guide the selection of policies. Only those

practices should be borrowed that can be suitable solutions for these needs, problems and

claims. The composition of future beneficiaries defines the general characteristics of the

borrowed policy, and justifies the necessity of implementation. For instance, if the aim of a

new policy is to motivate childbearing among young couples, the chosen policies must

address the needs of young women. The general features of the target group determine not

only the main characteristics of the policy to be borrowed, but also the composition and

qualifications of experts, scholars and bureaucrats who will later work on the project.

Steiner-Khamsi states that “borrowing is not copying” (2004:5), pointing to the fact

that adaptation is a sophisticated and time-consuming process. External factors like social,

political and economic issues must be considered beyond the implementation procedure itself.

Simple copying would not take into account the local characteristics (such as structure and

traditions of welfare services, traits of poverty and social needs, etc.) and would provide an

operational environment that is inappropriate for the special needs and claims of the target

group.

The learning process is only the first stage of many in the process of policy

implementation. This first stage helps policy makers understand the issues and obtain

necessary information about the given policy. If learning were used to simply “copy” policies

without reflecting local characteristics, it could lead to the total collapse of the policy transfer

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process. Borrowing is thus always a more sophisticated procedure than copying. Arguments

that arise against social, health care or educational reforms usually highlight that the main

problem with policy borrowing is that the lender and borrower countries can be very different.

Many economists and sociologists state that the main problem with the so-called ‘Washington

consensus’, which attempted to reform the poor Latin American and Eastern European

economies, was that it ignored local characteristics and inexorably believed in the creation of

a ‘world class model’ (cf. Stiglitz 2005). John Williamson described the consensus as a

‘panacea’ for economic and social problems in 1990. In his 10 points, Williamson wanted to

create a world class method for countries that faced similar economic hardships after the

political transitions. Eventually it became clear that forced privatisation of state property and

significant reductions in social expenditures lead to unpredicted negative side effects in the

social sphere as well. Poverty and social disparities worsened while states’ social

responsibility diminished. As a result of social dissatisfaction, popular and extremist political

parties rose to power in some of the new democracies (such as the new Marxist movements in

Latin America).

Schriewer (2000) draws attention to the functionalist approach of “borrowing and

lending”, which Morais de Sa e Silva (2010) also analyzes in a wider context. The

functionalist approach suggests that in certain cases local or national governments use policy

adaptation as a way to explain or justify already implemented measures. Clearly, this practice

is not a real example of “policy borrowing”. In these cases, policies are borrowed with the

goal of portraying controversial and dysfunctional government decisions as examples of a

functioning good practice from abroad. Such “reforms” generally come from within the

country, and lack the prudent examination of the policy they reference. This strategy of

foreign policy internalization is used to convince opponents of unpopular political actions.

Spreen (2004:101-113) mentions the South African education reform as a clear example of

how “borrowing and lending” can be used to justify an already decided policy measure. Post-

apartheid South Africa saw the broad reform of its educational system, and decision-makers

did not hesitate to use a repertoire of international examples. The main feature of the reform

measures was the so-called outcomes-based education (OBE), also widespread in some

Anglo-Saxon countries like Australia or New Zealand. South Africa introduced the OBE

model in the late 1990s as part of its efforts to modernize the educational system, eventually

copying the Anglo-Saxon model without modification. Spreen (pp. 111) points out that the

implementers of the program handled OBE as a ‘world class’ model that can function in time

and space regardless of the surrounding economic and social environment. OBE eventually

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found its place in the local environment, and gained its own South African traits as though it

had always been a regional project.

Experts on the subject agree that ‘policy transfer’ is not a spontaneous process.

Instead, it is a well-designed and consciously built-up sequence of stages. Feenstra (2010)

draws attention to the importance of background research and ex-ante evaluation before the

programs are implemented, since the analysis of external factors has a crucial role in the

success of future projects. The various circumstances to be examined can include economic,

financial, social and environmental aspects, as well as technical, cultural and demographic

factors. While in theory, it is rather easy to develop or modify certain policies, in practice

social or cultural factors are often hard to influence or change. According to Feenstra,

decision makers should start by identifying existing policies which are successful at achieving

their goals. The second step of the process should be the examination of external factors and

their comparison to the situation at hand. Before a program is copied, it is important to decide

whether the entire project or only an arbitrary part should be chosen and implemented. In light

of the globalization gap, countries with developing economies are under pressure to meet

international requirements and address the educational, social, cultural etc. challenges they

face. It is often tempting for countries to copy the successful practices of others, without

paying attention to their individual socio-economic conditions or examining the external

factors. As a result, the implemented programs cannot be integrated into the system as a

whole and lack the support of social actors. As Steiner-Khamsi emphasized, “copying is not

borrowing”: the key to the successful implementation of reforms is whether local

circumstances and interests are taken into account.

Tilly (2004) points to the general effect of globalization on poverty, examining a core

set of problems most countries must face regardless of their economic status. Instead of

looking at the stage of economic development, he prefers to analyze the distribution of

income and a measure of the state’s social responsibility. According to Tilly, similar

conditions demand similar responses. Therefore, the newly instituted social and educational

policies can be adaptable as long as they are designed to address the same problems. These

standardized problems and the applied solutions build up a “world class model” which derives

from the original model of “reference societies”. The new model is adjustable and

transferable, either in part or in its entirety. Based on Ochs and Phillips (2002), Phillips

(2004)1 prescribes a six-stage process of policy transfer as follows. First, there must be

1 in Steiner-Khamsi ed. 2004

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certain circumstances in the “home” country which necessitate the reforms. Well-functioning

systems do not need change only to satisfy the desire to ‘reform something’. Another

possibility is that the system needs to be reformed but there are no political or social interests

behind the measures. Reforming without social and political consensus is arbitrary and it can

achieve only short-lived and volatile changes in practice. If no one is interested in the

planned reforms, there is no point in implementing new policies even if there are real

problems in the operation of the current system. Second, the policies must be accessible and

desired in the “target” country. Lender countries must be willing to offer their policies to

borrowers and provide access to the necessary knowledge and skills. At the same time,

borrower countries must be fully willing to receive the policy. The third step of the borrowing

process is the political decision about the acceptance and application of programs, which is

followed by the phase of internalization. Steiner-Khamsi (2000) calls this stage

“indigenization”, referring to the process whereby policies become part of the borrowing

regime. Optimally, political debates are held before the final implementation of policies in

accordance with democratic norms. In this case, the decision about borrowing is the result of a

consensus between political parties. In order to establish extensive social support for the

program, it is best if a wider platform is involved in the decision process, including both

NGOs and market actors.

The final stage is the evaluation of the efficacy of the implemented projects, which can

provide important feedback about the success of the program. A common mistake at this

project evaluation stage is to focus solely on the economic effects of the program, ignoring

equity issues. Looking at Latin American conditional cash transfer programs, Molyneux

(2009) highlights that while CCTs pay close attention to efficacy issues, equity considerations

are often undervalued and marginalized. Examining the World Bank’s reports on Latin-

American CCTs between 1998 and 2004, she points out that ethnic and gender issues

appeared only in 9 cases of the 73 official impact assessments.

Policy borrowing and the welfare state

The adaptation of certain programs, transfers and complete social safety networks is

common among international social policies. One can see many examples in the past, such as

the quick spread of the “Bismarckian” social security system in Central-Western Europe in

the late 19th century. Vobruba (2004:5) argues that state-run social security systems in

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Europe are able to save the most vulnerable groups from the negative implications of

economic crises. Social security systems spread the costs of crisis management among various

social actors, ensuring that victims do not become isolated from society. Fitoussi and Laurent

(2009:24) present a different point of view from that of Vobruba. In their opinion the

Bismarckian social security model, which is predominant in the welfare policy of the EU,

does not allow social systems to adequately respond to economic changes. Social services and

provisions often sustain and prolong unemployment and mask the real social effects of

economic changes. As a result, the strength of the welfare state becomes its weakness because

the continued provision of welfare services is used as an excuse to avoid necessary reforms

and political measures.

The open method of coordination (OMC), declared in the Lisbon Summit in 2000, has

become the foundation and main driver of the so-called European Social Model. The

Commission realized that the introduction of a common social policy regime would not be

possible because of the vast cross-country differences in traditions, levels of expenditures,

legal status and so on. Through OMC, the Commission creates directives to guide the

directions of the social policy measures of member states. Setting short and long-term goals

for the member states, these directives have become an excellent channel for policy transfer

and good practices.

The post-war balance of rights and responsibilities in the welfare state has

significantly changed since the economic crisis of the 1970s. As resources became more

limited and social expenditures sank, duties began to play greater part in social allowance

programs. Tools and methods applied by the European states can be of various types and can

be influenced by recent social problems, political values and economic interests. The political

debate on the welfare state was shaped by the discussion among liberal and social democratic

political powers in the late 19th century. The concept of ‘the state of social assistance’ and

theories on social services first emerged during this period. Welfare states received their

current form after the Second World War, which was a time of devolution and separation.

Universal social benefits and income replacement were brand new and never experienced

concepts in the new welfare states. The third wave of transformation occurred in the 1970’s,

when the generous Scandinavian welfare services came into existence. By the end of the 20th

century, all modern states (regardless of the development of their welfare regime) had to face

similar social problems, which tested the ability of the various welfare regimes to cope with

hardships. One of the most important new trends was the transformation of family roles and

particularly the labor market participation of women. Millions of women joined the labor

15

market which offered them suitable jobs requiring less physical strength, but more precision,

empathy and other traditional female skills. This development significantly altered the

traditional family models, the division of labor between spouses and the traits of social care

and child rearing. Thus, the increased labor market participation of women seriously affected

the social responsibility of the state. Because of the two-earner family model and the

consequent alteration of wage formation, households were no longer able to care for pre-

school children and their elderly. The task of the state in this context is how and to what

extent it is able to take over the burden of social care from working families.

The second important change that affected the welfare states occurred in the structure

of the labor market. Industrial mass production, which determined the economic trends of the

20th century, lost its significance. General reductions in industrial production and the

outsourcing of factories and plants caused job losses for millions of low-skilled blue-collar

workers who were not able to adapt to the new circumstances. In light of these changes, the

main responsibility of the welfare state is to redistribute the costs and benefits of economic

transformation across the winners and losers of the process. This redistributive effect can

appear in the form of increased reallocation, progressive taxation, special social services, etc.

The third new challenge that endangers cross-national welfare regimes can be found in the

welfare system itself. Social services and provisions, which were updated to accommodate the

post-war social risks and worked well for a long time, are no longer able to address the new

kinds of social needs. Welfare states were designed after WW2 to meet social challenges like

old age poverty, medical needs of injured veterans and the poverty of war orphans and

widows. Since social services were designed for the above-mentioned risks and needs, they

are not able to properly respond to new challenges like child poverty, immigration and

computer illiteracy. The arguably necessary reform of welfare states would hurt the interests

of current beneficiaries (primarily the pensioners). These groups possess enough political

power to prevent any program modification that might go against their interest.

In this essay, we mention two recent examples of welfare states attempting to cope

with social and economic problems by using internationally adopted models. The first

example is the thriving of neo-liberalism and neo-conservatism in the 1980’s. After the

economic crisis of the mid 1970’s, welfare states attempted to reduce their costs by cutting

social expenditures and limiting redistribution efforts. Financial cuts affected the whole

system and lowered the states’ social responsibility. Since the ‘state’ pillar of welfare was

significantly weakened, the ‘family’ and ‘market’ pillars should have taken over the role of

the welfare state. In the area of social security, private pension and health systems became

16

widespread while state-run funds provided only minimum level services to the neediest

groups. In the area of social services, market-based providers became more important as the

state began to finance for-profit providers and NGO’s instead of maintaining government-run

institutions. Neo-liberal initiatives fundamentally relied on the forced privatization of

formerly state-run institutions and funds. Under the leadership of the United Kingdom and the

United States, the motto of the reforms became ‘self sufficiency’. Margaret Thatcher and

Ronald Reagan were both quite determined to manage a ‘smaller state’. Similar reforms were

later introduced in Francois Mitterrand’s France and Helmut Kohl’s West-Germany.

The second widespread cross-country attempt to reform the welfare state began in the

1990’s. The leader of reforms was the United Kingdom where the Tony Blair’s newly elected

labor government re-designed the British welfare system. The so called ‘third way’ social

policy attempted to maintain the high level of welfare provisions by involving the private

sector, making possible the peaceful coexistence of state-run and for-profit social services.

The new labor government thus broke the tradition of their predecessors by moving away

from regulating market actors as a way to tackle inequality. Instead of doing so, they planned

programs like life-long learning and human-capital investments which aimed to alleviate

poverty by enabling the poor to re-join the labor force. This kind of welfare reform became

popular both in the Western (particularly in Gerhard Schröder’s Germany) and in the Eastern

part of the continent (Hungary, Czech Republic). The main concept of the reform was that the

alleviation of poverty contributes to more effective markets. Effective markets then create

jobs for high-risk groups like women with infants, young workers and low-skilled employees,

among others.

The modern welfare state is built on three pillars: the family, the state and markets.

Local values, interests, traditions and attitudes then determine which pillar is chosen as the

main driver that shapes the institutions and policies of the welfare state (Esping-Andersen

1997). Scandinavian countries have focused on the ‘state’ pillar. These states address social

problems through high-quality state-run services, using a comprehensive system of

institutions that covers the needs of the elderly, children, the unemployed and other risk

groups. Tax rates in these countries are quite high, because the large-scale free services are

rather expensive to maintain. However, only these Scandinavian welfare states were able to

simultaneously increase birth rates and decrease old-age poverty. The universal social

provisions enabled employees to leave the labor market without suffering a significant loss in

their quality of life. High social allowances are particularly favorable to women who decide to

have a baby and leave the workplace for a couple of months. Opponents of the social-

17

democratic welfare state argue that expenditures on such high-level services overburden the

state budget, particularly at a time of recession. Comparison of private and public

expenditures on various welfare services (such as education and health facilities) reveals that

private out-of-pocket costs for services are comparable to public expenses.

The Anglo-Saxon countries relied on markets to address social needs. The

management of those needs that cannot be solved by markets (such as homeless care and

social assistance) was allocated to NGOs, churches and government offices. In this welfare

model, income tax rates are relatively low but private expenditures on welfare services are

high. Countries which maintain liberal welfare states mostly employ a private social security

system that emphasizes the importance of self sufficiency. The poor who are not covered by

private funds receive minimum level state-financed payments and services. In the area of

social assistance, there has been a significant shift from ‘welfare’ to ‘workfare-like’ assistance

starting in the mid-1990’s. The implication is that beneficiaries must meet certain work-

related requirements that range from job-seeking to direct in-work activities.

Continental European states have focused on the ‘family’ pillar of welfare. Work-

related social problems (such as pensions, unemployment and maternity leave) are generally

addressed through traditional income-based social security systems. In continental welfare

states, the focus is on the male breadwinner whose income supports the entire household.

Income-creation measures, geared towards the needs of the father, define the main traits of the

welfare regime. Traditional Bismarckian social security systems are built on the concept of

directly supporting the head of the family in case of job loss, health problems, inability to

work and so on. This rigidity of the system is the main reason that traditional social security

networks are not able to assess new social risks like employment-based problems of single

mothers during pregnancy, maternity and child rearing. At the same time, these systems work

quite well in the areas of old-age income security and unemployment benefits for working-age

men. Despite the fact that continental welfare states spend a lot of money on family policies,

birth rates are lagging behind both universal and liberal welfare states. Since these traditional

welfare states employ in-cash provisions instead of providing social and childcare services,

women with infants are not motivated to go back to work or have another baby. In the area of

labor force participation, the reconciliation of childbearing and work is quite difficult in the

absence of childcare facilities. The Netherlands and France, two conservative welfare states,

have been able to improve on their former practice by introducing modern childcare services.

France established childcare services in the form of family daycare, which has been fairly

effective in promoting the re-employment of mothers.

18

Esping-Andersen draws attention to the fact that there is no clear separation between

the above-mentioned welfare model types, as all states borrow new practices from other

countries. We can observe some common trends in how welfare states attempted to address

the social effects of the economic crisis. Scandinavian states tackled the vulnerability of low-

skilled workers and risk groups like mothers, old-age employees and young entrants by

establishing competitive wages and positions in the state sector. These efforts made state

employment a favorable alternative to private sector positions, crowding out employers who

offered low quality and badly paid jobs. Naturally, this high level expenditure on state-run

employment requires high taxes and social solidarity. Full employment is the source of these

tax revenues, which means that almost all social groups have to participate in the labor market

regardless of their health status, gender and age. Mothers with infants can work part-time by

using childcare services, disabled employees can work at workplaces maintained for people

with reduced capacity to work, and the elderly can also work in specialized environments.

Liberal welfare states follow different practices. Instead of widening the services provided by

the state, these regimes reduced social expenditures and made their allowance system more

workfare-like. Low-paid jobs function as a kind of poverty alleviating mechanism by offering

a minimum standard of living for low-skilled workers and young entrants. It is quite easy to

shift in and out of these positions; therefore the labor market is rather flexible and can adapt

itself to new challenges.

The fact that a given practice (e.g. private pension funds) functions well in one country

is no guarantee that the same method can be successfully introduced in another state. The

process of policy borrowing and lending is arguably less complicated among welfare states

that belong to the same category. Similar social and economic trends, institutions and attitudes

allow them to transfer knowledge or techniques in part or as a whole among each other. But

what happens when a policy is transferred between two countries with completely different

welfare characteristics? In their comparative analysis of Eastern European, Latin American

and East-Asian countries, Haggard and Kaufman (2009) analyzed the implementation of new

welfare policies in these new democracies. Decision makers in these countries wanted to

implement pragmatic changes compared to previous regimes, and they were generally very

enthusiastic to learn new policies. International organizations (like the World Bank or IMF)

supported the reform of former systems which had already begun to fall apart as a result of the

political transition. The IMF and World Bank proposed the transfer of developed country

practices such as multi-pillar pension systems, private health funds and strictly targeted

19

assistance. Acceptance of these recommendations was not always voluntary, as financial aid

was often conditioned on the adaptation of these reforms (cf. SAPRI reports in Hungary).

Banks et al. (2004) argue that new cross-national social policies at the beginning of the

21st century can be categorized into three general welfare directions. These are: (1) tackling

child poverty, (2) supporting the low-income population, and (3) promoting employment or

increasing human capital. Many countries decided to employ a common set of practices to

tackle social problems, starting to simplify welfare expenditures and tighten eligibility

conditions at the same time. The first examples of new reforms with a multi-country reach

began in the mid-1990s when similar employment policies were spreading across the Anglo-

Saxon states.

As mentioned above, both the OECD and the World Bank played a major intermediary

role in the process of spreading the ‘new wave’ international social policies. There are two

main examples of their activity on social policy internationalization. The first example is the

OECD’s (and other institutions like IMF’s and the European Commission’s) push for member

states to introduce ‘make work pay’ policies, i.e. to reform former welfare policies and

replace them with work-related payments. The second example of the globalization of social

policies was the World Bank’s attempt to convince developing countries to reform their

pension systems and introduce multi-pillar models.

The pension system reforms were conducted in a way to reflect the changing nature of

pension regimes and the ability to sustain them. The targeted countries were experiencing

similar social risks (originating from elderly unemployment, deficiencies in the pension funds

and adverse demographic trends), but chose very different solutions. The sequence of

measures was rather multicolored. While Latin American countries chose the privatization of

welfare services as a remedial measure, countries in Eastern Europe resisted market pressure

by keeping most services and transfers under state supervision.

The major international organizations designed and started to promote work-related

reforms in the 1980s as a way to move from unemployment to full employment. The primary

driver of reforms was the OECD’s ‘Jobs Study’ which established a set of measures for states

to follow. These measures (such as the reform of collective bargaining, lower marginal and

average tax rates and less emphasis on employment protection) later contributed to more

flexible labor markets. Incidentally, these labor reforms were driven by former U.S.

initiatives, originally designed for the American labor market. Countries that implemented the

OECD recommendations reached better employment outcomes by the late 1990s. According

to some experts (cf. Banks 2004:9), these improvements did not come from the OECD

20

recommendations. Rather, they were due to other external factors, including economic and

social changes. The welfare reforms were based on the so-called ‘work-based society’ (Offe

1983) concept. This notion differentiates between ‘in-work benefits’ and ‘out of-work

benefits’, the latter of which previously constituted the concept of ‘welfare’. Newly

introduced ‘Making Work Pay (MWP)’ models became widespread in countries (such as

Canada, New-Zealand, United Kingdom etc.) that had already had previous experience with

employment-based transfers. In countries where these payments had not been in place before,

MWP policies were novelties that often turned out to be difficult to implement.

Several previous studies have focused on the adaptation of policies in modern social

welfare states. Midgley (2008) measures the effects of the 1996 United States welfare reforms

on modern British social policy. The U.S. welfare reform had a powerful and prolonged effect

not only on the British (and Australian) reform measures, but also on the social policy design

of such global institutions like the World Bank and the International Monetary Fund. Through

their financing mechanisms, the international institutions later contributed to the

implementation of these social welfare policies in countries with emerging economies. It is

instructive to take a closer look at the Anglo-Saxon reform measures. The Personal

Responsibility and Work Opportunity Act (PRWORA) came into existence during the Clinton

administration in 1996. This reform had a strong impact on the largest temporary allowance

program of the U.S. by restricting eligibility criteria and shortening the assistance period.

PRWORA tied the former non-conditional transfers to educational and health related

conditions, with a particular focus on children. The member states reserved the right to ratify

the law under various names. Furthermore, states were in charge of the distribution of federal

funds (using a capped budget). Several other Anglo-Saxon countries copied the American

model. Accordingly, the United Kingdom’s Working Families Tax Credit and Australia’s

Work for the Dole program assigned very similar goals and employed similar policy tools

(Midgley 2008). The Anglo-Saxon welfare reform that began in the 1990s is still work in

progress. For the past five years, the global economic crisis has ignited efforts to reform the

welfare system. The new welfare reform package (Welfare Reform Bill) introduced by the

British government in 2011 is a clear example. In its first wave of reforms, WRB modifies the

conditional benefits introduced in the 1990s, with the goal of eventually turning them into

minimal-level-allowances that target the most vulnerable groups exclusively.

No doubt, from the mid 1990’s onwards the post-modern world has seen the

integration (and sometimes even motivation) of stimulus programs in new social policies.

Social transfers were integrated into a comprehensive system that was designed to achieve full

21

employment. New labor reforms across Europe, like the Harz reforms in Germany and the

RMI/RSA in France, have definitely infiltrated welfare transfers by imposing conditions on

the previously non-conditional transfers (Simonyi 2010).

CCTs and policy transferability

Based on the types of requirements, we can identify two forms of conditional cash

transfers. The first form consists of the so-called workfare-like allowances, in which benefits

are conditioned on work or work-related activities (job searching, training, etc.). The second

form of CCTs promotes investment in children’s human capital by imposing health and

education-related requirements on beneficiaries. Underlying these transfers is the recognition

that health and education-related disadvantages are rooted deep in childhood, and have

negative effects that last a lifetime. These negative trends close the path of social

advancement quite early on. Transfers mitigate these early disadvantages by directly

promoting access to educational and health facilities. The accessibility and availability of such

facilities are therefore essential for the success of these transfer programs.

For many programs (Progresa, Solidario, Bolsa Família), health-related cooperation

begins as early as the pre-natal period through regular screening of mothers. It continues on

with the vaccination of babies and regular medical check-ups for infants. Typical educational

conditions consist of regular school attendance and annual student enrolment. However,

certain programs can also impose additional requirements such as conditions regarding

learning outcomes, in-school behaviour, mandatory parent-teacher meetings and cooperation

with the case manager. Based on international practice (Friedman et al. 2009:14, Silva 2009),

behavioural requirements tied to social transfers can take two forms: (1) “added benefits” and

(2) “added conditions”. In the first case, transfers are brand-new provisions built on the

already existing allowance system. These transfers work by providing positive incentives to

promote regular school attendance and reduce drop-out rates. The main mission of such

transfers is to reward the desired behaviour. The extensive Latin American CCT projects

belong to this group of transfer programs, as does the Hungarian kindergarten allowance

program. The second form of CCTs is based on negative incentives. These projects tie former

non-conditional transfers (either discretional allowances as in the United States and Australia,

or universal ones as in Hungary and Romania) to education-related conditions.

22

Conditional cash transfers can be found in many countries around the world. However,

most of these programs operate in developing countries where they represent the only form of

social assistance. CCTs are not particularly common in countries with developed and

comprehensive welfare systems. When CCTs emerge as a brand-new practice of social

assistance, they start to support behaviours which were not rewarded earlier. Thus, CCTs are

perceived by the beneficiaries as positive incentives. In countries with developed welfare

systems (including the Eastern European welfare regimes), CCTs did not appear in the form

of new transfers. Instead, previously non-conditional transfers were tied to various

requirements. As of late, “added conditions”-based programs can be found only in the Anglo-

Saxon countries and Eastern Europe (Friedman 2009).

The “CCT wave”, a term coined by Fiszbein and Schady (2009:31) referring to the

spread of CCTs in low and medium-income countries around the world, began in the mid-

1990s. These programs built on local initiatives (such as Brasil’s Bolsa Escola and Mexico’s

Progresa) that were designed to reach the most vulnerable poor population in rural areas. Over

the course of a few years, CCTs were introduced in 29 countries with more states hoping to

join. The Mexican project started with 300,000 households in 1997 and today it reaches more

than 5 million poor families. Brasil’s Bolsa Escola began with a small program led by the

municipality of Campoinas. Over time, it has become a country-wide mammoth project with

11 million households and 46 million beneficiaries. Many experts argue that there is a definite

connection between the workfare-like social assistance programs of Western Europe and the

United States and the CCTs of emerging countries (cf. Fiszbein and Schady 2009:33). There

is, however, an important difference. While restrictive policy measures (such as the U.S.’s

TANF or the U.K.’s New Deal) impose sanctions on existing transfers and punish

beneficiaries when the requirements are not met, the World Bank-financed CCTs in Latin

America and other developing countries support behaviors which were previously not

rewarded.

It is difficult to say whether countries that have already introduced their own CCT

should follow a standard path or create their own. Both strategies can turn out well. For

example, Ecuador’s Bono de Desarollo Humano project required the compulsory schooling

and health care screening of children, but it did not punish the recipients if these conditions

were not met. Instead, a media campaign (using social media) was designed to facilitate

school enrolment and participation, and to motivate mothers to take their children to the

clinics.

23

The worldwide proliferation of (World Bank financed) CCTs in 2008

With respect to conditional cash transfers, the first obvious example of policy

borrowing and lending was the adaptation of Mexico’s Oportunidades in the United States.

The first developed-country CCT program was introduced in the form of New York City’s

Opportunity NYC pilot project. Fiszbein and Schady (2009:144) point out that out of 209

newspaper articles on ONYC, 109 (more than 50%) make a reference to Oportunidades.

Before the program was developed, reformers argued for its necessity by citing the results of

the Mexican project on the school attendance and health outcomes of the most vulnerable

groups. In the early stages, project managers from both countries often met in workshops and

conferences and organized study tours to exchange experiences. Nonetheless, the main critics

of ONYC drew attention to the differences in the structure and general characteristics of

poverty between the two welfare systems. Following the first introductory stage, ONYC

adjusted well to the modern welfare state by reflecting local needs in both language and

actions. As such, ONYC gradually diverged from the original design of Oportunidades

(Morais De Sa e Silva 2010).

Colombia’s Subsidios is another interesting example of CCT borrowing and lending.

International donor institutions (the IMF and World Bank) developed this program to alleviate

urban poverty and to curb its negative consequences. The project was based on Brasil’s Bolsa

Família and Mexico’s Oportunidades, transferring not only the project design but concrete

24

techniques, targeting and evaluation methods as well. The national government did not

receive direct funding from the international financial organizations. Instead, the local

municipality of Bogota was open to cooperation. As a result, two programs operated

simultaneously in Columbia: one run by the government (Familias en Accion in the

countryside) and one financed by the World Bank (Subsidios).

Macedonia introduced a new CCT program based on the practices employed in Latin

American projects like Oportunidades and Bolsa Família. The Macedonian policy transfer

copied certain elements (such as targeting methods and conditionality) from both programs

and became a sustainable CCT project in Eastern Europe. The adaptability of programs in

Eastern Europe is firmly questioned by Stubbs (2009), who describes the process of policy

borrowing as the “translation” of CCTs across time and space.

Behavior-based family allowance programs are common not only in Macedonia but in

other parts of Eastern Europe as well. Bulgaria, Romania, Slovakia and Hungary have also

tied certain cash transfers to educational conditions, using sanctions to tackle truancy and

early school-leave. In the media, several Hungarian and Slovakian experts reference the Latin

American CCTs as a guide for reducing early school drop-out rates in their own countries.

However, it is hard to determine whether the Latin American projects were really taken into

account before the implementation of the Eastern European programs or if they were only

used to justify political decisions that had been made long before.

Outside Eastern Europe, CCTs could not find a foothold in the social policies of EU

member states. The only Western European state which maintains an education-related

transfer is Belgium, where (in the Flemish areas) family allowance is tied to school

attendance. Aside from Belgium, countries in Western and Northern Europe do not employ

transfers tied to behavioral requirements like compulsory schooling or regular health care

check-ups. However, they do operate programs based on similar mechanisms like CCTs,

where beneficiaries must meet certain conditions related mostly to work or job-seeking

activities. In contrast to the Eastern European practice, “welfare to work” policies in Western

Europe and particularly in Scandinavia provide more entitlements and impose fewer

requirements (Kildal 2001). It is rather difficult to decide whether CCTs fit the welfare

concept of Continental Europe.

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