Don’t pave the way for more institutions in Bulgaria

As part of its Recovery and Resilience Plan, in June and July 2022 the Bulgarian authorities presented one of the Plan’s promised milestones for approval by the European Commission. Milestone 290[1], as it appears in the Plan, promises the entry into force of an “Ordinance on the Quality of Social Services”. The aim of this Ordinance is to outline the minimum quality standards for the provision of services. 

As such, Bulgaria has presented a set of standards for, among other things, “therapy and rehabilitation”, “day care”, “residential care”, “shelter” and “assistant support”. The European Commission subsequently approved the Ordinance, despite the fact that it opens the door for the creation of new institutions across the country, particularly for persons with disabilities.

The Ordinance states that Bulgarian residential care settings can house up to 120 people when the setting is intended to house older people. For settings specifically aimed at housing adults with disabilities, up to 30 residents are allowed. It is also permitted to have up to two residents sleeping in each bedroom, meaning that the minimum quality standards set out by the Bulgarian authorities do not guarantee privacy, dignity and a safe space for people to be alone should they want to.

A number of other standards are also prescribed that are likely to create settings that are institutional in nature. The settings should have, the Ordinance states, “at least one room designed for group work”, something that that in no way reflect a typical and independent home setting. It also states that “the main activities for each user are written in an individual work schedule” which again paints the scene of a controlled setting where service users cannot easily determine what they do, in a spontaneous way that reflects what we mean be independent living and following one’s own free choice.

The Ordinance also mentions the need to be located near to medical facilities. It should be reminded that, while inclusion in the community is dependent on having good access to local amenities, persons with disabilities and other service users should not be receiving their support services, including medical services, in the place of their dwelling. Having the services provided on-site will result in a hospitalisation of the living setting and further alienate residents from regular interactions with their communities. Furthermore, in no way should the provision of these services be tied to living in such residential settings, something that will make it difficult, if not impossible, for people to move away should they want to live somewhere else without losing access to necessary services in the process.

The United Nations Convention on the Rights of Persons with Disabilities (UN CRPD) outlines the right to support for independent living and inclusion in the community in its Article 19, as well as its General Comment 5. Contrary to the type of settings being proposed by Bulgaria, the UN CRPD’s General Comment 5 explains that States that “Independent living/living independently means that individuals with disabilities are provided with all necessary means to enable them to exercise choice and control over their lives and make all decisions concerning their lives”, something that is arguably unlikely to be achieved in settings of up to 30 people, where residents might not even have their own personal space, where residents’ routines are charted and where there are rooms within dwellings for “group work”.

We call on the European Commission to review its assessment of Bulgaria’s new Ordinance on Quality of Social Services, and to promote minimum standards that go much further in supporting independent living and freedom of choice of people with support needs.

You can find the full statement here.

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EEG Statement on the European Care Strategy

On September 7th, the European Commission released the European Care Strategy. The Strategy focuses on the importance of providing accessible, affordable, high-quality, and available care services to all. With this purpose, the Strategy aims to set an agenda to improve the current situation for both carers and service users.


The EEG welcomes the inclusion of elements such as gender-related issues among caregivers – both formal and informal – the call for affordable care and services, the push for support to family carers as well as the proposal for more EU action to promote national policy reforms. Moreover, the EEG acknowledges the focus of the Care Strategy on ensuring sustainable financing of social services and the Commission’s call to Member States on promoting both private and public investment within this area. The EEG welcomes the draft Council recommendation on the revision of the Barcelona Targets on early childhood education and care (ECEC). The recommendation states that “children with disabilities have the right to participate in mainstream ECEC on an equal basis with others”. It emphasizes accessibility including adequate infrastructure, including adaptation to special needs of parents and “the professionalization of staff and specialists to adequately support children with disabilities” as key aspects of inclusive ECEC. These features make the recommendation an example of good policy practice for the inclusion of disabled children into mainstream education and against any form of segregation.

Nevertheless, the EEG remarks several points which should be addressed for the general improvement of the current EU Care Strategy (full statement here)

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EEG Regrets to see a lower ambition to push for people’s social rights in the 2022 European Semester process.

The European Semester cycle aims to review performances of Member States each year on both economic and social matters. To guide Members States, the European Commission publishes the Country Specific Recommendations (CSRs) in addition to Country Reports (CRs) within the Spring Package of the European Semester mechanism.
The analysis of CRs and CSRs highlighted the need for actions in merit of the Russian invasion of Ukraine, the energy crisis, as well as the post-pandemic period. However, in its analysis, the EEG could also identify the presence of specific recommendations in compliance with the transition from institutions to community-based services.

Deinstitutionalisation
The EEG believes that all people have the right to live outside institutions. Institutions are any residential care where people are forced to live together and/or away from the community, residents do not have decisional power, and/or the organization of the care takes precedence over the residents’ individual needs. The process to end institutional care is defined as deinstitutionalisation.
In these regard, deinstitutionalisation has been mentioned within CRs or CSRs of ten countries: Austria, Belgium, Bulgaria, Croatia, France, Italy, Poland, Portugal, Romania and Spain.  The CRs and CSRs of five countries (Bulgaria, Portugal, Belgium, Croatia, Italy) mention specific initiatives in the National Recovery and Resilience Plans (NRRPs) or other political reforms to support deinstitutionalisation. Other Country Reports reported the urgency to implement further measures and the need to address NRRP funds in the deinstitutionalisation process (Austria, France, Poland, Spain). In the case of Romania, the Country Report highlighted the lack of human resources, administrative capacity and sufficiently integrated services as structural elements preventing deinstitutionalisation.

Community-based services for specific target groups
In addition to specific recommendations regarding the transition from institutional to inclusive support practices, the analysis of the CSRs has also focused on the implementation of community-based services in reference to the EEG target groups.
In particular, concerning children and their families, several of the Country Reports highlighted an increase in the rate of poverty or risk of social exclusion in comparison to data from previous years. While in some cases the allocation of funds to support the inclusion of children in the community has brought to some results (like in Latvia and Ireland), the percentage of children at risk of poverty and social exclusion remains high in most of Member States. The findings highlight an enhanced risk for children in low-income households, children with disabilities, Roma children and children with a migrant background, etc. Concerning these last two groups, it is important to point out the high rate of Roma children that leave education early (Romania and Slovakia) and the fact that children with migrant background are three times more at risk of poverty (Netherlands, Luxembourg). Moreover, the CSRs describe a substantial lack of provision of formal care for children below 3 years old – specifically in some Members States (Czechia, Lithuania, Malta, Poland and Romania) – which has been exacerbated by the pandemic.
Similarly, the analysis of Country Reports has emphasized number of initiatives within NRRPs to promote social inclusion of people with disabilities. Some CRs include measures to boost employability (Belgium, France) as well as the use of ESF+ funds to establish a network of social inclusion services (Cyprus, Italy). However, employment gaps between people with and without disabilities remain a major problem in almost all Member States’ CSRs[1].
Likewise, people with disabilities have a high rate of risk of poverty and social exclusion throughout all EU countries (EU average was 28.4% in 2021) with even higher rates in several countries (Estonia, Germany, Ireland and Lithuania). In the specific case of Romania, the CSRs highlight deinstitutionalisation of people with disabilities as a substantial step in achieving the 2030 EU headline target on poverty reduction. Furthermore, findings from the EEG’s analysis identify people with disabilities often not finishing school due to inequalities within the educational system (Belgium, Estonia).
Although most CSRs do not include mental health, the promotion of deinstitutionalisation and community services for people with mental health problems is mentioned as a goal for some countries(Portugal and the Netherlands)

Housing
Within the CRs, accessible social housing represents another common issue. Shortages and low quality of social housing concerns a number of Member States like Belgium, Czechia, Denmark, Hungary, Ireland, Latvia, Lithuania, and Luxembourg. In particular, with no national strategy to end homelessness, social housing represents a particular issue for Slovakia. In order to face the lack of social housing, the CSRs call for the adoption of a specific legal framework and the implementation of affordable, social housing facilities. Accessible social housing is also recommended in many CSRs in regard to people fleeing Ukraine and in response to the migration emergency in the EU.

Conclusions
Within its analysis, the EEG could identify general information for target topics such as deinstitutionalisation, community-based services and social housing. Despite the allocation of some funds for community-based services, their accessibility remains difficult in most of EU state members for those people living in poverty and social exclusion. Finally, social housing represents another issue present in several Member States. This problem is enhanced both by the absence of housing strategies as well as by Russia’s invasion of Ukrainian.


[1] According to research, the Disability Employment Gap is substantial and varies between 10 to 42 percentage points amont EU countries. In the EU as a whole 50,6% of disabled people are employed, compared to 74,8% of people without a disability. For individual disabilities the situation can be worse. Out of 30 million blind and partially sighted persons the unemployment rate is 75%. Among autistic people, only 10% are in employment. According to the ENIL Independent Living Survey from 2020, 96% of respondents found labour market access to be inadequate or requiring improvement. 

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EEG Members’ initiatives on Ukraine

The ongoing war in Ukraine has already caused the death of thousand of civilians and the massive fleeing of people from their homes. As the mediation process is still in progress and there has not been any indication of a de-escalation of the conflict, the number of people seeking safety from the war is expected to increase.

In these circumstances, EEG members have taken several initiatives not to leave behind and expose to further risks people in need of support.

Here you can find the list of EEG members’ initiatives to support children, people with disabilities, homeless people and people experiencing mental health problems in Ukraine:

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Deinstitutionalisation should remain a priority for EU funding

EEG’s analysis of Recovery Plans and recommendations for 2022 European Semester

The European Semester represents an important process to strengthen not only economic and fiscal reforms but also social inclusive policies among the European Union (EU) Member States. While the 2021 European Semester mechanisms had been halted to allow a better response to the Covid-19 pandemic, the 2022 European Semester goes back to its original cycle with the adoption of country reports and country-specific recommendations by the European Commission. It will, however, still pay particular attention to the National Recovery and Resilience Plans (NRRPs). In order to inform the European Semester outputs, the European Expert Group on the Transition from Institutional to Community-Based Care (EEG) has consulted its members and gathered information on the process of deinstitutionalisation (DI) and on the development of community-based care. The EEG has been focusing on 12 Member States being Belgium, Bulgaria, Croatia, Czech Republic, France, Greece, Hungary, Italy, Latvia, Portugal, Romania, Slovakia and Spain.

The EEG has submitted its findings to support the European Commission in promoting inclusive NRRPs and in the writing of country-specific recommendations which will be published in May 2022. Indeed, through this contribution the EEG aims to support the implementation of the standards in the United Nations Convention on the Rights of Persons with Disabilities (UNCRPD), the United Nations Convention on the Rights of the Child (UNCRC), the UN guidelines for the Alternative Care of Children, and the European Fundamental Rights Charter.

The EEG country fact-sheets delineate the existing situation of the DI process – including improvements and ongoing problems – and point out the main weaknesses as well as strengths of the NRRPs.

Concerning the situation of children within the Member States we have analysed, the EEG has pointed out that the number of children in institutional care has not undergone considerable changes in last 2 years (only Spain and Bulgaria have seen decreases). In most of the cases, children in residential care were in institutions: while in some states almost the totality of children in alternative care remain in already existing institutions, the EEG expressed concern about the inclusion of the construction of new institutions in some NRPPs (such as Belgium’s). Moreover, the EEG has identified poverty and lack of economic support as being among the main reasons for the institutionalisation of children; other reasons include lack of community-based services able to meet the needs of persons with disabilities, marginalisation, neglect, abuse, a lack of family support services in the community or migration. In the case of asylum-seeking children, they might end up staying in the institutional care system until they reach the age of maturity or, as in the case of Hungary, they might end up being confined in transit zone areas. In its analysis, the EEG has also highlighted a lack of data collection and disaggregated data which prevent the implementation of efficient policies and reforms towards deinstitutionalisation. The transition process from institutional to community-based care is further hindered by the absence of a defined strategy on a regional or community level: this is particularly true for those countries which have autonomous administration within the same country, like Spain, Belgium and Italy.

In the examined countries, the EEG has also analysed the situation and promotion of independent living for persons with disabilities. In its findings, the EEG remarked both a worsening and an improvement of the general trends depending on the Member State: some Member States (like France, Croatia and Portugal) have seen the number of people in institutions increasing during the last year due to the lack of community-based and person-centered services. This has also been enhanced by the incorrect use of EU funding going towards the deinstitutionalisation process and by the lack of available social housing. Some positive changes have also been noted on a political and legal level: for example, Greece worked to promote a National Deinstitutionalisation Strategy and Hungary has made changes to the constitution to support community-based services. Nevertheless, such changes have been weak in their implementation due to the lack of data and an incorrect approach towards the concept of deinstitutionalisation. In its review of Member States, the EEG has also been focusing on the Mental Health services and on persons with mental health issues in institutions. Overall, the EEG has outlined an increase in the number of people with mental health needs within institutions despite the launch – in few countries – of political reforms aiming to promote community-based mental health centres. Furthermore, when considering the situation of persons with disabilities, the EEG has defined the lack of clear and quantifiable targets, lack of economic support, and the lack of data availability as further elements that contribute to institutionalisation.

Finally, in the analysis of the Countries’ Recovery and Resilience Plans, the EEG has identified common recommendations for the considered Member States:

  • The transition from institutions to community-based care needs to follow UNCRPD and UNCRC principles; moreover, NRRPs need to exclude funding to new or pre-existing institutions and need to fix clear targets in the transition process.
  • To prevent child separation from their families, it is important that NRRPs include measures and programmes to prevent risk of poverty; inclusive education reforms are also very important to stop the institutionalisation of children with disabilities. Moreover, NRRPs should focus on increasing foster care provision and develop a wide range of support options in the community.
  • NRRPs should promote further research into the monitoring and collection of data. This should be applied specifically in the data concerning children (including children deprived of parental care), children with disabilities, people with mental health needs and persons with disabilities.
  • There should be a greater focus on social housing and on facilitating the process of access to available social housing.
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EEG condolences on the death of President Sassoli

The EEG would like to express its deepest condolences for the loss of David Sassoli, President of the European Parliament. Mr Sassoli’s engagement in upholding children’s rights and the rights of persons with disabilities made him a valuable ally as a person and as a policy maker.

As an association, we will remember with his leadership against inequality and the defense of these most at risk of exclusion.

The EEG’s thoughts go out to Mr Sassoli’s family, his loved ones and all Europeans.

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The Recovery and Resilience Fund as a means to creating community and family-based care

The online event “The Recovery and Resilience Facility as a means to creating community and family-based care”, which took place on the 18th of November 2021, aimed to provide an overview of the opportunities and the risks that the Recovery and Resilience Facility might fuel within the European Union.

In 2021, the EEG has been monitoring the Recovery and Resilience Facility (RRF), its investments for social resilience and recovery since out of the six pillars of the RRF most of them aim at inclusive growth; social cohesion; health & social resilience; and policies for future generations. The Expert Group publicly called for the EU and its Member States to commit to investing this money into deinstitutionalisation (DI) as well as in community-based services, and strictly forbidding any investments in institutions. The EEG also has been reiterating the higher impact of the pandemic on people residing in institutions.

Moderated by Haydn Hammersley, Social Policy Officer at the European Disability Forum and EEG co-chair, the event gathered almost 70 representatives from ministries of different countries, the European Commission and national and European civil society organisations.

The meeting opened with a video message by Commissioner Helena Dalli in which she highlighted that the RRF must respect the principles of gender equality and equal opportunities for all. She also encouraged Member States to put in place an inclusive process to monitor the implementation of the National Recovery Plans by including NGOs active in the area of equality and inclusion. She concluded with the following call: “Let us all contribute to a Union of Equality”.

At the beginning of the event, UN Special Rapporteur on the rights of persons with disabilities Gerard Quinn, has also stressed the fundamental role of the European Union as world leader in the implementation of deinstitutionalization policies (read full speech).

The event showed that the RRF truly represents a once-in-a-life occasion to boost the process of deinstitutionalisation and that these funds need to be carefully monitored in their use. Attendees also got insights in various NRRPs such as those of Romania, Portugal and Greece.

The EEG provided several examples of concrete projects which introduce indicators for monitoring of DI progress, promote housing initiatives and support young people entering into adulthood out of residential homes, including people with disabilities and homeless people.

Read the full report to find out how these funds can support deinstitutionalisation in Europe

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EEG’s main findings on the submitted Recovery & Resilience National Plans

Since the beginning of the year, the EEG has been following closely the work around the Recovery and Resilience Facility. We analysed several draft Recovery and Resilience National Plans[1], and shared country-specific recommendations with the European Commission based on each of the draft plans. Furthermore, in May the EEG published the statement “Recovery and Resilience Facility must support community inclusion, not segregation”, calling on the EU and its Member States to comply with the United Nations Convention on the Rights of Persons with Disabilities (UNCRPD), the United Nations Convention on the Rights of the Child (UNCRC) and the EU’s commitment towards deinstitutionalisation, and thus not allow for any investments in institutions to be included in the National Recovery and Resilience Plans (RRPs).

With the aim to verify whether the EEG’s recommendations were taken into account in the negotiations between the European Commission and Member States, and to assess whether the RRPs submitted to the European Commission still foresee investments into residential institutions[2], the EEG has analysed the final adopted plans. We hope our assessment will help the European Commission in its steering role during the implementation phase by identifying best practices and which parts require special attention.

EEG’s main findings

The EEG has identified several important measures in the final RRPs, such as improving access to the labour market of persons with disabilities (including vocational training and rehabilitation), as well as various measures to improve accessibility of the built environment and transportation, capacity building of preschool facilities for children, measures in the education system to tackle the digital divide and inclusive education that affect pupils with disabilities, and others. We have also identified measures in the area of prevention of institutionalisation, community-based services and deinstitutionalisation, but unfortunately also some investments which might contribute to institutionalisation.

Find here all countries analysed and EEG’s main findings on each of the submitted Recovery and Resilience Plans


[1] The Recovery and Resilience Facility Plans analysed by the EEG are as follows: BG, CZ, FR, GR, HR, LV, PT, RO and SK.

[2] For people with disabilities, older people, children (including children with disabilities), people with mental health problems and homeless people.

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Online seminar about EU funds for independent living and deinstitutionalisation

On the 28th of June, the European Commission jointly with the European Expert Group on the Transition from Institutional to Community-based Care and Hope and Homes for Children organised an online seminar for desk officers from DG EMPL, REGIO, RECOVER, NEAR and REFORM. The aim of the webinar was to inform the European Commission about the tools and good practices supporting independent living and family-and community-based care in light of the new funding regulations and policies.

The event counted on the participation of several speakers from the European Commission, academia, and civil society organisations presenting main EU policies and EEG publications, as well as practical examples on independent living.

Mr Loris di Pietrantonio, Head of Unit at DG EMPL responsible for programming and implementation of the European Social Fund +, opened the event followed by Professor Julie Beadle-Brown, who presented the report on the Transition from Institutional Care to Community-Based Services in 27 EU Member States, which she co-authored together with Professor Jan Šiška.

ProfessorBeadle-Brown presented the main finding of the study. During her intervention, she also stressed the need to develop person-centred and individualised support, the lack of affordable community-based services and housing, and the sustainability of EU-funded projects that promote deinstitutionalisation.

Ms Inmaculada Placencia Porrero, Senior Expert on social affairs at DG EMPL, presented a broad overview of the Strategy for the Rights of Persons with Disabilities 2021-2030, focusing on aspects connected to deinstitutionalisation and independent living. Among the actions foreseen in the Strategy, it was emphasized the guidance, which will be issued by the Commission by 2023, with recommendations to Member States aiming at improvements on independent living and inclusion in the community, in order to enable persons with disabilities to live in accessible, supported housing in the community, or to continue living at home (including personal assistance schemes). In addition, the speaker also presented the European Accessibility Act, in its connection with independent living.

Ms Michela Costa, Director of Global & EU Advocacy at Hope and Homes for Children,presented the updated version of EU funds Checklist to Promote Independent Living and Deinstitutionalisation. The purpose of the checklist is to ensure EU funds in the 2021-2027 programming period contribute to independent living and inclusion in the community. More specifically, the checklist supports EC Desk Officers to check the consistency of the measures with the legal and policy frameworks in the fields of:

  • Transition from institutional to family-based and community-based services for children, persons with disabilities, persons with mental health problems and elderly persons
  • Development of quality family-based and community-based services
  • Prevention of separation of children, including with disabilities, from their families
  • Prevention of segregation and institutionalisation of children, persons with disabilities, persons with mental health problems, older people and homeless people, regardless of the residence status.

Finally, EEG members presented practical examples of community-based services. Ms Irene Bertana, Senior Policy Officer at the European Association of Service providers for Persons with Disabilities (EASPD), presented an EU-funded project on providing technical assistance on preparing of the deinstitutionalisation strategy in Greece. Ms Ines Bulic, Deputy Director at the European Network on Independent Living (ENIL), presented a practical example about personal assistance as one of the types of community-based support.

Participants posed questions to speakers, mainly regarding the implementation of community-based services given the obstacles related to the lack of accessibility of buildings in many EU countries and regarding the sustainability of investing in  deinstitutionalisation. They have also raised questions about residential care for children with disabilities, in particular how to ensure best care in family-based care, and how to develop family-based services and increase number of foster families. The European Child Guarantee was mentioned as a tool to address those needs. The online seminar provided a space for both desk officers and members of the EEG to discuss the persistent questions and share the good practices as well as challenges and opportunities intertwined with the deinstitutionalisation process.

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Stop EU funding of new institutions for people with disabilities in Poland, EEG says

In 2020 the European Expert Group on the Transition from Institutional to Community-based Care (EEG) contacted the European Commission to voice serious concerns about a large-scale institution for 100 residents with mental health issues in the city of Łódź, Poland. It was a clear example of EU funds being invested in an institutional care setting, something which the EU Regulations covering investments from this source outline as being de facto ineligible for funding. In August 2020, EEG Member ENIL, together with the Validity Foundation, filed a formal complaint.

Nearly a year on, the planned investment, known as “Wyjątkowy dom”, is still going ahead and there has been no substantive response to justify its continuation.

The EEG urges the Łódź Voivodeship Managing Authority to halt plans for the construction of this institution and, in the case where this does not happen, calls on the European Commission to suspend its funding and encourage investment in community-based services.

The EEG defines an institution as any residential care where:

• residents are isolated from the broader community and/or compelled to live together;

• residents do not have sufficient control over their lives and over decisions which affect them; and

• the requirements of the organisation itself tend to take precedence over the residents’ individual needs.

The three-story former school building being converted into a care home is not compatible with the right to live independently and be included in the community, as affirmed by the United Nations Convention on the Rights of Persons with Disabilities (CRPD), ratified both by Poland and the EU. Specifically, it represents an infringement of CRPD Article 19, as well as its General Comment 5 and the Charter of Fundamental Rights of the European Union.

While the project claims to aim at the “deinstitutionalisation of social services and care” – building a large-scale, congregated setting for persons coming from the whole region cannot be interpreted as deinstitutionalisation by any stretch of imagination. On the contrary, it contravenes the definition of a community-based service, and goes against the principles expressed in the EEG Common European Guidelines and Toolkit on the transition from institutional to community-based care.

Article 4(6) of the Common Provision Regulations (CPR) for the current funding period states that the European Social Fund (ESF) and the European Regional Development Fund (ERDF) have to be used in a manner which is compliant with the EU social inclusion policies and that ERDF should not be used to renovate or build new institutions.

This investment clearly fails to fulfil all the requirement above. It neither facilitates the rights of persons with support needs to choose where and with whom they live or to be included in the community, nor has the capacity to build support around each person’s individual requirements and preferences. The size of this setting alone raises alarm bells, clearly being an institution even in the most traditional sense of the term.

Beyond the infringement on the right to live independently and being included in the community, we also saw during the COVID-19 pandemic the tragic consequences of congregated living conditions. We therefore ask the Managing Authorities in Poland and the European Commission to look into this matter and take the necessary steps to ensure that the funding is redirected towards independent living, community-based and person-centred support, in compliance with the CRPD, the Charter of Fundamental Rights of the European Union and the CPR. Instead of the construction and extension of institutional settings, it is necessary to develop a range of services at community level, as well as to support personal assistance schemes.

About the EEG

The European Expert Group on the Transition from Institutional to Community-based Care (EEG) is a broad coalition gathering stakeholders representing people with care or support needs and their families, including children, people with disabilities, homeless people, and people experiencing mental health problems; as well as service providers, public authorities and UNICEF.

Contact: coordinator@deinstitutionalisation.com

The Statement is available in pdf here.

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