The four organizations expressed our opinion on the Action plan  for the period 2017-2018 for the implementation of the National Strategy for Poverty Reduction and Promotion of Social Inclusion 2020 and Report on its Implementation for 2015-16.

Institute of Social Activities and Practices since 2001 Works for the professionalisation of psycho-social practice with children and families, aimed at the social inclusion of vulnerable groups of people in public life. The Institute deliberately and consistently develops innovative models of social services, disseminates new knowledge and skills, supports professional development through sharing and reflection, conducts scientific and applied research, is actively involved in social policy-making.

I. General comments

At present, our opinion is that the Action Plan for Implementing the National Poverty Reduction and Promotion of Social Inclusion 2020 Strategy for 2017-18 does not contain sufficiently ambitious measures to overcome child poverty in Bulgaria, which is still far above Average levels for the European Union. 43.7% of children in Bulgaria live at risk of poverty or social exclusion, and the Action Plan lacks targeted measures to overcome this problem. There is more and more scientific evidence that testifies that the family's poverty situation is directly related to the poor care, incentives and attitudes of parents to the child in infancy, which at this stage leads to the under-development of certain portions of the child's brain , and later to deficits in various aspects of his emotional, cognitive and social development. In this sense, poverty alleviation programs aimed at increasing parents' incomes and supporting families have a significant impact on the development of children and their full inclusion as active citizens.

II. Specific comments on the Action Plan for the period 2017-2018 for the implementation of the National Strategy for Poverty Reduction and Promotion of Social Inclusion

We would like to express our concern about the adoption of the Action Plan for 2017-18 years after more than a quarter of its implementation time has elapsed. The fact that the plan is still at the public consultation stage in July-August 2017 does not speak well for the strategic planning of such policies.

In this relation, we also express the view that the proposed and voted action plan for the period 2017-2018 at the meeting of the National Council on Social Inclusion on 13.07.2017 continues to contain measures and activities which аre set in other short and long-term documents and programs, ie. There is duplication and overlapping of approved activities such as "Ensuring the Activities of the Healthcare Advisory Centers for Maternal and Child Health" or "Updating the Legislation" set out in the National Program for Maternal and Child Health and the National Program for the Protection of the Child for 2017 Year. At the same time, it also contains activities that are carried out by law by line ministries and agencies, such as "Granting Family Allowances for Children" and "Making Financial Support for Childcare in a Family Environment". Additionally, only the quantitative indicators are included in the proposed plan, which unfortunately do not indicate the expected effect of the implementation of the specific measure and activity. We propose that indicators be targeted and expanded, taking into account the quality and the real impact of the achievement and the change in relation to the standard of living of children and people in general.

We are extremely concerned about closed access to vocational training for large groups of children and young people at risk. In practice, children who have dropped out before the 8th grade have only a theoretical opportunity to access vocational training. Without this access being guaranteed with special educational, social and health measures and programs, this group of children is doomed to misery, crimes, prostitution, wandering. According to the National Statistical Institute, the total number of children leaving the general and special schools for the school year 2015-2016 is 14 483. he data show a negative trend for the drop-out of the enrolled children in school in each of the categories for which the National Statistical Institute measures group net coefficients by degrees: in the initial stage of education the net enrollment rate of 95.8% in 2011-2012 lowered the level Up to 92.1% in the 2016-2017 academic year; In lower secondary education of 81.8% in 2011-2012, the net coefficient is down to 78.2% in the 2016-2017 academic year.

In support of what has been said above as a process of developing the Plan, we again note that only two of the more than 30 proposals to include new measures and activities that we have put forward to the draft Action Plan within the Working Group on the document were accepted and the rest did not find a place in the document that was put to the attention of National Council on Social Inclusion. The implementing measures included in this plan must be much more comprehensive and decisive in order to achieve a real outcome. Our proposals are again related to the inclusion of new measures and activities in the following priorities of the National Strategy:

Proposals for measures and activities under Priority 1: Ensure employment opportunities and raise labor income through active labor market inclusion

Proposals for measures and activities under Priority 2: Ensuring equal access to quality pre-school and school education

Proposals for measures and activities under Priority 3: Ensuring equal and effective access to quality healthcare

Proposals for measures and activities under Priority 4: Elimination of the institutional model of care and development of cross-sectoral services for social inclusion

Proposals for measures and activities under Priority 5: Ensuring the sustainability and adequacy of social payments Proposals for measures and activities under Priority 6: Improving the capacity and interaction in the sphere of education, healthcare, employment and social services in realizing common goals for social inclusion

Proposals for measures and activities under Priority 6: Improving the capacity and interaction in the sphere of education, healthcare, employment and social services in realizing common goals for social inclusion

Proposals for measures and activities under Priority 8: Improving the housing conditions of vulnerable groups and supporting the homeless

Institute for Social Activities and Practices Association "Children and Adolescents"

July 25, 2017