STILL A LONG WAY TO GO: A COMPARATIVE STUDY OF FAMILY

POLICIES BETWEEN THE UNITED STATES AND THE UNITED KINGDOM

HANSARD SOCIETY INTERNATIONAL SCHOLARS DISSERTATION

SHARON CHUNG

INTRODUCTION For many families, the birth of a new child is a time of blessing, life-altering new beginnings, and celebration. The birth of a new child also opens a plethora of tensions between financial obligations, work responsibilities, and child rearing duties. The early years between infanthood and toddlerhood are absolutely crucial for a child’s cognitive and emotional development which makes constant adult attention almost compulsory. Moreover, for many families, a new child comes with its extra costs that too often stretch incomes and push those already on edge into poverty or dangerously close to it. It is estimated that one quarter of all poverty spells in the United States (US) begin with the birth of a new child.1 Not to mention, the stressors of a new child are not all just financial either – the mother’s health must recover from childbirth, sleeping patterns have to be adapted, and the entire family experiences disruptions in their daily routines.1 The arrival of a new child is exhilarating, but the pressures of parenthood are exhausting and undeniably universal. Just last Wednesday on November 25th in the United Kingdom (UK), a Childcare Bill aimed to provide 30 hours of “free childcare for young children of working parents” had its second reading in Parliament at the House of Lords.2 Juxtaposed side by side, the US comparably lacks a coherent child care policy.3 Overall, the Americans lag considerably behind other nation states in terms of legislating adequate policies to support its families. In a 2015 InterNations survey done by Expat Insider on family life index: out of 41 countries, the US was ranked 25th for overall family life; 12th in availability of child-care and education; 37th in cost of childcare and education; 25th in the quality of education; and 16th in family well-being.4 Although the UK does not fare much better in ranking (22nd in overall family life, 24th in availability of child-care; 31st in cost of childcare; 9th in quality of education; and 21st in family well-being)4, Westminster is aware of the lack of support and relentless efforts have been made since the New Labour government in 1997 to reform family life for Britons. However, there is still a lot of change left to be desired for both nations. With children being such an integral part of people’s lives, there is value in observing how governments implement policymaking to support its families and their children. This paper will be doing a comparative exploration of family policies through US and UK history; consider the contemporary issues plaguing both nations’ ability to provide sound institutional provisions for its parents; note the cultural differences between Anglo-American and Continental European social welfare states impacting policymaking; and conclude with how the US can draw upon UK legislating experiences for the future. Can US implement a universal paid family leave policy and provide sound child care services? It is also important to note that because of time constraints, this paper will only be elaborating on comparative American and British family policies in terms of parental leave and child care policies.

1 Waldfogel, Jane. "International Policies Toward Parental Leave and Child Care." The Future of Children 11, no. 1, Caring for Infants and

Toddlers (Spring - Summer, 2001) (2001): 98-111. Accessed December 10, 2015. http://www.jstor.org/stable/1602812. 2 "Childcare Bill [HL] 2015-16." Bill & Legislation. 2015. Accessed December 10, 2015. http://services.parliament.uk/bills/2015-

16/childcare.html. 3 Kelly, Erin L. "The Strange History of Employer-Sponsored Child Care: Interested Actors, Uncertainty, and the Transformation of Law in

Organizational Fields." AJS 109, no. 3 (November 2003) (2003): 606-49. Accessed December 10, 2015.

https://www.soc.umn.edu/~elkelly/Kelly2003CCAJS.pdf. 4 "The Internations Survey." Family Life Index 2015. Accessed December 10, 2015. https://inassets1-internationsgmbh.netdna-

ssl.com/static/bundles/internationsexpatinsider/images/2015/topic/family_life_index_full.jpg.

A LOOK IN HISTORY: AMERICAN CHILD CARE POLICY Mothers had to work with the circumstances that they were in when it came to childrearing for the most part of American history. Babies were strapped and carried on cradle boards on the backs of Native American mothers; Pioneers’ infants were placed in wooden boxes on the Midwestern plains; White southern plantation wives’ looked after African American children while their parents slaved away on cotton fields; African American mothers neglected their own children in order to sing for their owner’s white babies; and migrant workers have left children to play in the dirt of slums and tents while they worked in factories to achieve each respective American dream.5 From cradles, cribs, tenement flats, factory mill lots to nannies, governesses, and neighbors, working American mothers have had to think on their feet and invent various creative ways for their children to be looked after while they worked.5 It was the mother who primarily took care and managed the business of the children. And it was not until the latter half of nineteenth century, when the women’s movement picked up during the Progressive Era, did family and childcare reform finally take its root in American policy. In 1893, the Model Day Nursery in the Children’s Building was featured in the World’s Columbian Exhibition at Chicago, and it went on to inspire the founding of America’s first nationwide organization dedicated to the issue of childcare, National Federation of Day Nurseries (NFDN) in 1898. But day nurseries soon grew to be increasingly unpopular. Progressives of the time did not perceive having working women outside the home as positive solutions. Reformers such as the Hull House Colleagues, Jane Addams, and Julia Lathrop (who later becomes the first chief of the US Children’s Bureau, CB, in 1912), all campaigned relentlessly to keep women from taking low-paid jobs and their children from being left in inadequate care by advocating for mothers’ or widow’s pensions. In the view of reformers, “mothers, like soldiers, were performing a service to the nation and therefore deserved public support when they lack a male breadwinner.”5 The campaign gained signification traction and by the end of the 1930s, mothers’ pension laws have been successfully passed in nearly every state. Although this policy of choice kept the women at home and did not challenge traditional gender roles, it beget family policymaking in the US. As successful as the mothers’ pensions rhetoric was framed, it did little for poor and low-income mothers. Women of color were especially excluded from benefits; state administrations had restrictive criteria and operated on stringent, bias practices to ensure African American mothers’ ineligibility. With pension coverage being sporadic and mercurial, maternal employment “not only persisted but increased”5 throughout the 1920s. The demand for child care soared but with the victory of mothers’ pensions monopolizing the political agenda, many philanthropists struggled to win public funding for day nurseries. The Great Depression and President Franklin D. Roosevelt’s New Deal continued the mixed impacts on delivering American child care. Two hundred day nurseries closed between 1931 and 1940, and only after the urging from a key New Deal Agency, Works Progress Administration’s (WPA), did Roosevelt establish the

5 Michel, Sonya. "The History of Child Care in the U.S." Child Labor Reform. 2011. Accessed December 10, 2015.

http://www.socialwelfarehistory.com/programs/child-care-the-american-history/.

Emergency Nursery Schools (ENS) program. The program was to “offer employment opportunities to unemployed teachers and compensate the physical and mental handicaps caused by the economic downturn.”5 Over 75,000 pupils were enrolled between 1933 and 1934 covering forty-three states and the District of Columbia, Puerto Rico, and the Virgin Islands.5 In contrast with its predecessors, which were largely private day nurseries oriented at the middle class, the ENS program nurseries were government-sponsored, free, and opened to all families regardless of socioeconomic income. Furthermore, they were designed as schools and not just as child care facilities. The educational component prompted many organizations like the National Association for Nursery Education to revive the idea of progressive pedagogy and develop a curriculum for the ENS. However, due to the economic depression, the ENS started suffering from high teacher turnover rates from them opting to take better- paying jobs in the 1930s and many to shut down. The program was a step forward from just having mothers’ pensions as the main policy agenda for families; the economic circumstances were just not ideal. World War II too was only able to have equivocal effects on the direction of American child care policy. With the war ultimately reducing the unemployment rate and eventually leading the whole nation into a critical labor shortage, a social crisis of millions of women and mothers joining and seeking employment in the war-effort ensued. The US federal government was initially reluctant in accepting the social change and insisted that mothers who stayed at home would be doing the country a patriotic change. In time though, it was indisputable that the government had to implement policies and respond to the unprecedented need for child care since women employment did not slow. Congress passed the Lanham Act in 1941 which authorized community facilities to be created in “war-impacted areas”5 that allowed for the child care centers to be built for working mothers. While the New Deal sponsored ENS and the wartime child care proved to be monumental steps in “American social provision,”5 many of the child care centers lacked the organization, staff, and the means to meet high standards. Inadequacies and horror stories of children suffering from maternal deprivation perpetuated public concerns of child care centers. Congress, wary of having to provide permanent services, declared that they would be open for the duration of wartime only. Funding for the Lanham Act was cut off right after V-J day even against numerous local groups’ demonstrations such as the Child Welfare League of America. But to no avail, many of the childcare centers had to close despite maternal employment rates dipping only marginally for a few years before steadily being on the rise once more. It was during this early post-war period that the American mothers began to truly feel the immense vacuum of support for women who wanted to stay working. Groups lobbied for federal funding for child care centers tirelessly; nevertheless, they were unable to persuade Congress to pass the Maternal and Child Welfare Act in 1946. Child care provisions won in some states and cities such as New York City, Philadelphia, Washington D.C., and California – but for the most part, the future of American child care looked rather bleak heading into peacetime. In 1954, Congress finally found an approach to bridging the vacuum of childcare and maternal employment – “the child care tax deduction.”5 Low- to- moderate income families were able to deduct $600 from their income taxes to use for childcare. In 1958,

an organization devoted exclusively to the issue of child care, the Inter-City Committee for Day Care of Children (ICC), was formed. Its founders: a New York activist, Elinor; a leader of the Child Study Association, Sadie Ginsburg; a New York City official who had established a licensing system for childcare in the city, Cornelia Goldsmith; and a child cares specialist, Winifred, worked closely with the Children’s Bureau (CB) and the Women’s Bureau (WB) for federally funded centers again. Republican Senator Jacob Javits of New York attempted to implement several child care bills in 1958 and 1959 with the help of ICC’s grassroots efforts but was unsuccessful. President John F. Kennedy’s administration was the first presidential administration to recognize the problem. In one of his statements, Kenney asserted, “I believe we must take further steps to encourage day care programs that will protect our children and provide them with a basis for full life in later years.”5 Kennedy’s administration appeared to have sought out a broad-based approach for child care other than tax deductions. The President’s Commission on the Status of Women was even able to circulate a report identifying how child care not only enabled mothers to work outside the home but also heavily benefitted children’s developmental advancement and social and racial integration. Regrettably, even with such a momentum, Kennedy’s administration did not have sufficient political support for a universal child care policy to be passed. Two welfare reform bills were passed in 1962 and 1965, instead, for Congress to federally fund child care alongside policies encouraging poor and low-income women to find employment outside the home. The Aid to Families with Dependent Children (AFDC) as it was called, aimed at cutting the number of Americans on welfare and had a strict criteria to actively excluded women from being recipients. The closest the US government came into passing a legislation for universal child care was in 1971. A coalition of feminists, labor leaders, civil rights leaders, and early childhood advocates teamed up with Congress and drafted the Comprehensive Child Development Act. It would have been a sweeping policy, the first of its kind to thoroughly address the issue of child care and families extensively. Unfortunately, President Richard Nixon vetoed the act and set the tone for the next three decades: “direct federal support for child care was limited to policies targeted at low-income families.”5 Indirect governmental support for middle and upper-middle class families were typically in the form of “tax incentives for employer-sponsored child care”5 or reductions in personal income taxes. In the 1980s, the federal child care funding balance shifted with low-income families’ expenditures being reduced and middle-and high-income families’ income nearly doubling. With a stimulated economy, voluntary and for-profit child care grew as low-income families still writhed to make ends meet. The Child Care and Development Block Grant (CCDBG) was passed in 1990 to allocate $825 million to individual states to specifically target poor families. In 1996, the AFDC was replaced by the Personal Responsibility and Work Opportunity Reconciliation Act that gave time-sensitive public support with rigid employment directives. Congress then went on to combine the CCDBG with other public programs to formulate the Child Care and Development Fund in order to gauge the gaping need for expansive, nation-wide child-care. There were more public funds than ever dedicated to this policy area, yet, quality, supply, and

socioeconomic divides still remain as huge challenges for Child Care policy under the Reagan era and onwards. BRITAIN’S CHILDCARE POLICY: A MULTIFACETED HISTORY The continental European social welfare states are more generous to the poor and the disadvantaged in comparison to the US.6 By current governance and provisions, the UK is no exception. Still, it is important to note that the UK has not always been receptive of enacting family support and policies. Historically, the state has been fairly reluctant to assist its working mothers in contrast with their European peers. It will take a radical shift in politics in the late 20th century for the UK government to acknowledge a need for child care policies. For the most part of the 16th to mid-20th century, children’s welfare and their maintenance have been with their fathers. A series of Elizabethan Poor Laws did pass in 1597 aimed at increasing powers for the Boards of Poor Law Guardians to provide for the destitute, and ultimately children.7 Mainly, these laws were centered upon illegitimate children since divorces were non-existent at the time. The state would support the mother and the bastard child until the father was apprehended and reimbursed the parish. This relief to the poor was maintained through the years until post World War II. In its entirety, the codified laws oversaw support for the elderly, the ill-stricken, the infant poor, and strikingly, the low-income able-bodied persons.8 In the late 18th century the Poor Laws were also supplemented with the Speenhamland system– an economic practice of poor relief that enabled the raising of workingmen’s income to an agreed level instead of fixing minimum wages for poor labourers.8 The money came out of parish rates and this system lasted alongside the Poor Laws. Though many historians and commentators have condemned this system stating that it perpetuated the poor’s idleness, this is the backdrop of the social welfare system in the UK in context. The evolution of child support in the UK is greatly impacted by the development of divorces. Under the Married Women Maintenance Act (In the Case of Desertion) of 1895, mothers were able to apply to the magistrates’ courts for reasonable care if she could prove that the father neglected to provide for her and her children.8 The Children Act of 1908, asserted that children needed to be kept out of workplaces and that parents were liable for the children’s maintenances.8 During the Progressive Era, while their American counterparts fought for their mothers’ pensions, the UK passed its National Insurance Act in 1911. The then chancellor, David Lloyd George, made maternal health benefits universal and the issue of mother’s rights and well-being were put into the limelight in British political agenda for the first time.9 The Married Woman (Maintenance) Act of 1920 followed to expand a woman’s right to apply for half a pound 6 Alesina, Alberto, Edward Glaeser, and Bruce Sacerdote. "Why Doesn't The US Have A European-Style Welfare State?" Harvard Institute of

Economic Research. November 1, 2001. Accessed December 10, 2015. http://post.economics.harvard.edu/hier/2001papers/2001list.html. 7 Cosstick, Sally. "An Overview of The British Child Welfare System." Accessed December 10, 2015.

www.sws.soton.ac.uk/cwab/Guide/England.doc. 8 Pearson, Barry. "History of Child Support in the UK." International History of Child Support. August 7, 2005. Accessed December 10, 2015.

http://www.childsupportanalysis.co.uk/information_and_explanation/world/history_uk.htm#references. 9 Jarvis, Alice- Azania. "The Timeline: Maternity Leave." Health & Families. October 23, 2011. Accessed December 10, 2015.

http://www.independent.co.uk/life-style/health-and-families/features/the-timeline-maternity-leave-2113236.html.

sterling a week for children ages 10 to 16.8 By evaluation, it almost likened to the success of American mothers’ pensions around the same time. And just before the Great Depression, the 1923 Matrimonial Causes Act equalizes the divorce criteria between men and women; divorces got much easier. This opened up divorces to the middle and working classes and mothers were awarded custody of children. All of this affected the multi-faceted journey for Britain’s modern child care policies as mothers from the Progressive Era started to gain more and more opportunities for employment and more say over the rights of her children. The beginnings of a political conversation were brewing. When WWII broke out, “women’s conscription into industrial jobs prompted a debate on their double burden.”9 More than thirteen hundred day nurseries were established to shoulder the surge in maternal employment during wartime. However, akin to their ally from across the Atlantic, many of these were only temporary and had to close after the war ended. Formal maternity leaves and family support remained firmly off the British post-war political agenda as UK shifted back into the traditional male breadwinner model family. Considerable ambivalence for mothers’ employments, and especially for mothers of young children, rose. Deemed as the “dark ages” for family policies, especially for women and children, Britain mirrored America’s inability to bring legislative focus for parents from the 1960’s through the 1980’s. UK saw Sweden’s introduction of a cross-gender parental leave being signed into law in 1974 and did not reciprocate. Iraq at the same time also allowed women to receive full pay while being granted maternity leaves and an extensive system for state-subsidized nurseries. In the time of the Cold War, at the hands of the anti-socialist Thatcher government, welfare was under fire. Taxpayers and government alike expected fathers to pay more and have the state do less, which resulted in the facilitation of only supporting theoretically lone and poor mothers. Women and children largely depended upon men in the family as this system only furthered the norm of child care being a private family issue. Maternity leave, childcare, and family support “varied from company to company”9. In 1985, subsidies for day nurseries were allowed as taxable benefit and gave £700 to £1000 for women’s taxes. By 1987, government removed the universal maternity grant. Then, the European Commission report of 1988 illustrated how much Britain lagged behind other contemporary European nations when it came to employment law since it was the only one to not offer statutory maternity leave. And even so, the government still proceeded to halt a draft directive that would have enabled Britain to adopt for minimum parental leave standards.9 The UK and the US essentially shared similar difficulties and dilemmas of enacting a coherent set of family policies during and immediately following the post-war years. The real divergence of UK’s cultural attitudes and changes actually happened drastically in the last few years of the 20th century. In 1990, the Seventh Report Social Security Advisory Committee published a report noting the number of “parents who defaulted while paying for child maintenance.”8 Following the report, the White Paper of “Children Come First” was published, documenting a political statement which preceded the Child Support Act (CSA) in 1991 addressing the matter of child support for the first time in UK history: “The present system of maintenance is necessarily

fragmented, uncertain in its results, slow and ineffective. It is based largely on discretion. The system is operated through the courts and the Department of Social Security. The cumulative effect is uncertainty and inconsistent decisions about how much maintenance should be paid.”8 The CSA established that (1) both parents are responsible for a qualified child (2) and that the child only qualifies for receiving maintenance when one parents is absent or if both parents were absent.10 The operation of the CSA began in 1993 and it wasn’t until two years after the New Labour government under the then Prime Minister, Tony Blair, did the Employment Relations Act in 1999 grant all employees a minimum of three months’ unpaid parental leave, with mothers having 18 weeks’ of paid leave. Men’s right for paternity leave was then included in Gordon Brown’s budget, and subsequently, male employees received paid paternity leave since 2003. It was the first time in UK history that gave fathers paternity leave. Seven years later, paternity leave was expanded and fathers were entitled to six months of statutory paternity leave to take the place of mothers at home. Advances have been made since 2010 with the European Parliament making a decision that all companies should provide 20 weeks of full pay maternity leaves and 2 weeks of paternity leaves. The UK has come a long way from its initial historical reluctance to legislate in the realms of British families, but there are still many aspects of UK family policies that still need to be tweaked. CONTEMPORARY ISSUES HINDERING AMERICAN PROGRESS Paid Parental Leave

10 "Child Support Act 1991." Child Support Act 1991. Accessed December 10, 2015. http://www.legislation.gov.uk/ukpga/1991/48/enacted.

As shown in Table 11, US’ leave policies lag far behind many other nations. Specifically, the US differs in three aspects: length of leave, wage replacement, and universality. The US is uniquely alone compared with its other OECD peers since it provides a shorter period of allowable leave that is generally unpaid and not all new parents are entitled to them. The US Family and Medical Leave Act allow employees to take up to 12 weeks of leave but does not mandate for pay.11 With the exception of three states, California, New Jersey, and Rhode Island, the US as a whole stands alone as a developed country when it comes to family leave. In the end, leaves differ from employer to employer and come in all shapes and sizes. Although many American businesses are not opposed to paid leave on its own with 65% of the civilian workers having paid sick leave and 74% having paid vacation, only around 12% of the private sector offer paid family leave.12 Why does the US differ so much in terms of parental leave? According to political scientist, Seymour Martin Lipset12, one explanation is that American democracy is simply different. There has always been this “American exceptionalism” in the US from the historic beginnings of the country’s foundation.12 Among several respects, the US differ from many European democracies because it has never been a monarchy or a feudal state.12 And as such, the US prides itself on individualism, equality, opportunity, and less structural class awareness. This lack of class division is what essentially contributes to less participation in trade unions and labor parties which in turn detracts from the median voter from supporting redistribution of public funds for individual private matters such as family support.6 With less labor power, it is facile to see how it can be an uphill battle for employees to successfully rally for employment changes to be instituted. Furthermore, at the end of WWII, the US was on very different circumstances compared with its European peers. While plenty of European states had to rebuild from the massive casualties and incredibly damaged infrastructure, the US did not emerge from WWII needing paid leave policies to replenish its population. In fact, for the Americans, when the men returned, women previously working jobs in factories and defensive plants went back home. With women returning home, there was less of an incentive from the start to create policies helping women to stay working. This also laid the steps for how US veered towards the opposite direction when European democracies leaned towards socialism as time went on. A professor of management at the Wharton Business School at the University of Pennsylvania, Peter Cappelli12, also added that the Americans tend to identify with the social class they aspire to be in instead of the social class they are in. In this way, small businesses gain a lot of sympathizers in American democracy as many identify as potential small business owners. It would be imprudent to discount the power businesses have in the US since the amount of dollars donated on campaigns in the US also dwarfs the finances of campaigns in European countries. Corporate contributions

11 Holohan, Megan. "See Where It Pays to Be a Parent (hint: It's Not in the US)." Health & Wellness. December 11, 2915. Accessed December

11, 2015. http://www.today.com/health/problem-parental-leave-u-s-t38701. 12 Kurtzleben, Danielle. "Lots Of Other Countries Mandate Paid Leave. Why Not The U.S.?" NPR. July 15, 2015. Accessed December 11, 2015.

http://www.npr.org/sections/itsallpolitics/2015/07/15/422957640/lots-of-other-countries-mandate-paid-leave-why-not-the-us.

have a substantial role in American politics, and as much as they are open to paid leaves, businesses do not want government mandating a “one-size fits all” approach for the workforce.12 Companies want the workplace flexibility and strategy to maneuver around these expensive policies to be decided by themselves. All of these reasons – historical developments, foundational attitudes, civilian socioeconomic class identification, and the power of businesses in America – all contribute to the belatedness of the US in providing paid parental leave. Child Care Presently, tax breaks are the most prevalent child care policy for American families. On the other hand, tax breaks also remain as one of the most expensive federal expenditures for the US government. There are two types of tax breaks: The Dependent Care Tax Credit (DCTC) and the Dependent Care Expense Account (DCEA).3 The DCTC is open to all eligible parents that file for tax returns and the DCEA is offered by employers whom have specifically established separate accounts to include benefits plans for their employees.3 An allowable $5,000 of an employee’s income can be set aside under the DCEA to pay for child care expenses. These would not be considered as taxable income and therefore, parents pay less for income tax and employers do not have to account those funds for Social Security. As said before, tax breaks are the primary government expenditures for child care and it is one of the most expensive piece of US federal funding. More money was spent on tax breaks than actually funding publicly subsidized child care. Approximately $4.5 billion was lost on the funds under the DCEA alone and an additional $2.8 billion was spent by individuals taking the DCTC for their own tax forms by 1997. “Tax breaks are a characteristically American form of social policy.”3 Tax breaks represent the “hidden welfare state” in the US where they are used to stimulate citizens’ utilization of market services in the place of actually implementing public services. Tax breaks supporters argue that they are: (1) less intrusive (2) less bureaucratic (3) the better alternative for government to regulate or direct spending (4) and more likely to go along with the market rather than against it.3 Thus, tax breaks remain uncontroversial since it would not be painted as welfare or “big government.” As policy measures, they also can continue indefinitely and not subjected to budget battles periodically.3 With such a firm stance on tax breaks already, employers go unconvinced that creating sponsored child centers would be necessary. Moreover, the 1981 tax law that led to the creation of DCEA was intended by the US government to encourage businesses in establishing child care centers, but because of the ambiguity of the law, few employers did. Scholars have argued time and time again that US laws on regulating organizations rarely deliver clear and exact guidance for compliance. This leaves many businesses interpreting new laws in an infinite amount of ways and for practices to vary widely. So when benefits consultants linked the DCEA program creatively with other new programs such as “cafeteria plans” or flexible benefits programs, companies were able to frame it into a whole package for its clients in the name of responding to working parents’ needs. This is how the DCEA soared in

numbers, and yet, employers were against building masses of child care centers to truly assist mothers and fathers. Overall, American’s fondness of tax credits, distaste for welfare, and legal ambiguity in employment law are all causative explanations for the lack of child care policy in the US. ACROSS THE ATLANTIC: WHAT IS AILING THE UK FAMILY POLICY? Currently, mothers in the UK can enjoy 39 weeks of maternity leave with a variety of perks such as free prescriptions, dental care, child benefit payments, and governmental subsidies to “offset the cost of parenting.”11 However, the provision is by no means perfect. Mothers in the UK would only have their pay amount to only 30.9 % of their total income. When it comes to paternity leave, fathers in the UK were entitled to two weeks with 90% of their payment, which was still comparably low to other European countries until the government revised it to 12 months starting from April 2015. Fortunately, universal child benefits are available and a new integrated child tax credit was introduced April of 2003.13 The most pressing issues plaguing UK family policies resides in its governmental management of childcare. Although in many respects the UK has a coherent childcare policy in comparison to the US, many families have complained of its high costs and quality extensively.14 In May 2013, Elizabeth Truss MP, made a statement on the status of UK’s childcare: “The UK has some of the most expensive childcare in Europe as well as the tightest ratios.”15 From a Childcare Costs Survey done by the Daycare Trust, parents in the UK buys 50 hours of childcare at £4.26 per hour which amounts to an annual bill of approximately £11,000.15 A child under the age of two in the UK is now 77% more expensive than it was for childcare in 2003.15 In the 2011 OECD report, “Doing better for Families,” the UK has the second highest costs for childcare out of all the OECD countries when it comes to average family incomes (27% to the OECD average of 12%) and the third highest when it comes to average wage (41% to the OCED average of 18%).15 Truss also created awareness for UK’s stringent standards for carer to child ratios in day nurseries. UK has one of the tightest ratios in their child care centers and proposals were made in 2013 to make more child care services available.16 “England’s higher raiots lead to higher costs for parents and lower pay for staff,” she says.16 However, many are skeptical that improving standards would realistically cut costs. How would decreasing ratios improve the quality in day nurseries and child care centers? It is a balancing act of reducing costs and still providing the best quality childcare.

13 Finch, Naomi. "Welfare Policy and Employment in the Context of Family Change." Family Policy in the UK. Accessed December 11, 2015.

https://www.york.ac.uk/inst/spru/research/nordic/ukpolicy.pdf. 14 "Childcare: How the UK Compares to Rest of Europe." Childcare: How the UK Compares to Rest of Europe. May 6, 2014. Accessed

December 11, 2015. http://www.daynurseries.co.uk/news/article.cfm/id/1563511/childcare-how-uk-compares-europe. 15 "Childcare in the UK: The Tightest and Most Expensive? - Full Fact." Full Fact.org. May 13, 2013. Accessed December 11, 2015.

https://fullfact.org/factchecks/childcare_costs_ratios-28918. 16 "Nursery Ratios Raised 'to Improve Standards' - BBC News." Education & Family. January 29, 2013. Accessed December 11, 2015.

http://www.bbc.com/news/education-21232270.

Conclusively, the UK is steps ahead of the US in terms of its current family policies. English families have paid leave, have tax benefits, and child care. The fine-tuning of those policies are what ails the UK government when it comes to legislating for British parents and their children. With the new Parliament just up and running and the Conservative government’s commitment for families to have 30 hours of free childcare, all eyes would be on the UK as the bill goes through the Parliamentary stages. Quality, cost, and the and refinement of the UK family policies are where the state is at right now. It has come a long way since the 1980’s of absolute reluctance to engage in family politics. ANALYSIS – MOVING FORWARD Can US implement a universal paid family leave policy and provide sound child care services? The answer to these questions are not clear-cut because the challenges are two-fold: the US has structural challenge and a fundamentally attitudal one to overcome. Though both the US and the UK shared similar historical attitudes when it came to the structure of the family, the two nations did not share the same historical experiences and government structure. What ultimately enable the UK to surge through and drastically reform its family policies during the last few years of late 20th century and the early 21st century was the political shift of the New Labour government. The central divide between the US congressional government and the UK Parliamentary governance, is that the UK Prime Minister holds more structural power to influence legislation than the US President. The executive branch and the legislative branch is combine in the UK and the high chamber in Parliament does not hold as much power as it does to its American Senate equivalent. So, when Tony Blair became the Prime Minister for the New Labour government in 1997, reforms from all ends of the spectrum were made possible. From asymmetrical devolution to changes of the House of Lords to modernization of political institutions17, the UK government was able to rapidly transform under new leadership in a way that could not be imitated by the US. It would take the coordination of both Congressional houses and the White House in order for a comprehensive family policy addressing either paid leave or child care to formulate. And as one have seen from President Nixon’s veto on the Comprehensive Child Development Act in 1971, this synchronization would not be an easy orchestration. Additionally, as a federation, the US has always struggled with “centralized redistributive policies” because of the tug-o-war between independent state rights and national jurisdiction under the federalism structure.6 So structurally, this did not create a solid backbone for socialist expansion and ideals that would have aided families. Secondly, the American aversion to “big government” is a monumental cultural hindrance for the conception of family policies. Alluding to before, America’s possible lack of socioeconomic awareness would be counterintuitive for the development of policies to help working families. Compared to the UK, the US spends only half as much in its government expenditures on American households, social security, and subsidies

17 Trueman, C N. "Constitutional Reform 1990 to 2001 - History Learning Site." History Learning Site. March 27, 2015. Accessed December 11,

2015. http://www.historylearningsite.co.uk/british-politics/constitutional-reform-1990-to-2001/.

– the UK spent 20 percent while the US only spent 11 percent. Social spending in the US is around 16 percent while the European average is around 25 percent. Perhaps one would need to explore the causes for the death of American socialism to fully explain the dearth of sufficient legislations in supporting families in the US. Further external research would be necessary to complete this hypothesis. Not until the government is willing to fully address this problem in defiance to corporations and businesses, universal paid leave and public child care funding for all classes would not be made possible. Another fundamental attitudal factor that could contribute to the American antipathy for social policies that can subsequently affect childcare and family would be that the general racial animosity in the US paints redistributing public funds to the poor and the working families, unappealing. What can US draw from the UK legislating experiences for the future development of American family policies? The US still has a long road ahead in reforming the employment laws and childcare provisions for its families. The ideal would be to provide at least 10 months of birth-related leave, support for the costs of care for children under the age of three, and to continuously re-evaluate the costs and quality of such public programs periodically. The UK is also amidst its reforms and the path of assisting working families is not a facile one. The significance in learning from UK would be for the US to embark on changes when the time comes because the reception of such legislative shifts are immensely conducive to not only the parents but the children. CONCLUSION With the US Presidential candidate and Democratic front-runner, Hilary Clinton, raising awareness for the need to finally reform American’s family policies in terms of paid leave and childcare, it is unequivocal that there is value in looking into other countries to explore how other nations assist their families. Historically, both the US and the UK were fairly disinclined to implement policies that would facilitate maternal employment following the post-war era to the 1980’s. However, since then the UK has gone ahead to stabilize a practicable infrastructure for mothers and families under the New Labour government in 1997. The US seems to still be dawdling in the shadow of 1980s UK without any changes set for the future.