Промяна на чл. 36 (2), изм. – ДВ, бр. 89 от 2016, в сила от 11.11.2016 г. от Правилник за прилагане на закона за социално подпомагане

TO: Mrs. Zornitsa Rusinova

Minister of Labour and Social Policy in resignation


Mrs. Maya Manolova

Ombudsman of the Republic of Bulgaria


Mr. Tsvetan Vasev

Executive Director

Agency for Social Support


Mrs. Ofelia Kaneva


Government Agency for Child Protection


Mr. Daniel Panov

Chairman of Management Board

National Association of Municipalities in the Republic of Bulgaria



Mrs. Marianne Thyssen

Employment, Social Affairs, Skills and Labour Mobility

European Commission


Regarding: The change of art in Guidebook (Regulation) for the Implementation of the Law on Social Support. 36 (2), alteration – official gazette, 89th issue from 2016, in force since 11.11.2016.


Dear Mrs. Rusinova,


Dear Mrs. Manolova,

Dear Mr. Vasev,

Dear Mrs. Kaneva,

Dear Mr. Panov,

Coalition “Childhood 2025” is a Bulgarian alliance of 16 non-governmental organizations and networks, as well as individual expert members that are actively working on the deinstitutionalization process. We are writing because we are highly concerned and would like to inform you of the difficulties that could arise as a result from the accepted changes in the Guidebook for Implementation of the Law on Social Support.

Some of the Coalition’s members are social service providers and some of them manage residential types of social services such as small group homes (SGHs) for children and adolescents with disabilities. All of these services are state delegated activities and managing them is based on tenders conducted by the relevant municipalities.

A change of art. 36 (2) of the Guidebook for Implementation of the Law on Social Support was enacted on 11th November, 2016. According to the new text of p. 4, the small group homes can be “aa) small group home for children without disabilities; bb) small group home for children with disabilities; cc) small group home for adolescents with disabilities; dd) small group home for adults with psychological disorders; ee) small group home for adults with dementia; ff) small group home for adults with physical disabilities; gg) small group home for adults with mental disabilities.”

The normative change cited above aims to differentiate the social service users and turn the small group homes that currently have the target group “children and adolescents with disabilities” into small group homes for “children with disabilities” and “adolescents with disabilities”. In this regard, we would like to draw attention to the following problems that will arise if this normative change is implemented in practice so as to impact on children and adolescents with disabilities:

A change of the configuration of SGHs and alteration of the target group of each type of facility means that the adolescents who are currently placed in SGHs for children and adolescents with disabilities would have to leave the existing service with the change of the profile of the service to SGH for children with disabilities and the other way around – the children with disabilities, placed in SGHs for children and adolescents with disabilities would have to move to a different service once the profile is changed to SGH for adolescents with disabilities. Moreover, there is the matter of determining the manner in which the new services shall be defined as well as the criteria on which the differentiation of the new services will be based.

We express our firm belief that moving the children, without having the required time to prepare them, without consulting with the non-governmental sector and without taking the individual needs of the children and adolescents in mind, would have a highly negative effect on their development because they have already developed bonds with each other and with the staff of the services. Furthermore, most of these children and adolescents were already moved from institutions to SGHs over the last few years within the project “Childhood for All” and have just completed the adaptation period. A shift, like the one suggested by the changes, will place their emotional and physical condition at risk while also jeopardizing the deinstitutionalization process as a whole. The changes might also lead to the separation of brothers and sisters who have been placed in a service together.

We are strongly opposing these changes due to the fact that they have been accepted without a wide public debate and without consulting with or noting the opinion of the governmental and non-governmental experts when there is no urgent public need that could justify the necessity for such a change.

We demand:

  • A recall of the indicative letter for the profiling of small group homes and the movement of the children and adolescents placed there (who have already adapted to the setting and personnel) on the sole basis of an age criterion;
  • The urgent creation of a working group, in which we are also participants, that will discuss the need for profiling and specialization of the services and will develop principles and criteria for an individual approach to the decision-making process for children and adolescents that have already been placed in existing services that will take account of their needs and will serve as a starting point for new placements;

Ladies and gentlemen, the implemented change to the Guidebook for Implementation of the Law on Social Support alters the entire meaning and spirit of the state policies for children and persons with disabilities, which focus on the need to uphold the rights, interests and needs of each individual. The current changes only focus on the social service as such.

As a Coalition, we have always worked in close partnership with governmental and local authorities responsible for the development of social services in Bulgaria and for the deinstitutionalization process.  We hope that the above-mentioned problems and issues will be addressed in the same manner as in the past and will be solved in the same way that we have worked in until this point and we express our willingness to participate in any meeting arranged to discuss the issues raised.

Please inform us of your views on the matter and let us know of any intended actions based on your authority and within the legal time limits.

Kind regards,

Coalition “Childhood 2025”


Bulgarian Association for Persons with Intellectual Disabilities (BAPID)

Bulgarian Association of Clinical Psychologists

Bulgarian Helsinki Committee

Bulgarian Centre for Not-for-Profit Law

Know-how Centre for Alternative Care for Children, New Bulgarian University

“Equilibrium” Association

Association for Pedagogic and Social Aid for Children (FICE – Bulgaria)

SOS Children’s Villages- Bulgaria

“Polder” Foundation

“For our Children” Foundation

“Karin Dom” Foundation

“Tulip” Foundation

“Lumos” Foundation

“International Social Service – Bulgaria” Foundation

“Cedar” Foundation

Hope and Homes for Children – Bulgaria

Valentina Simeonova, individual expert member

Rossitsa Bogalinska-Petrova, individual expert member

Haralan Alexandrov, individual expert member



Galina Bisset

“Equilibrium” Association

0884511385 coordinator@eq-bg.org

7000 Ruse, 14 “Lipnik” Blvd.

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