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AMALIPE congratulates the growing engagement of the European Commission with the challenge of Roma integration and particularly the anticipated EU Framework for National Roma Strategies. Having in mind the importance of the future National Roma Strategies for the effective and efficient Roma inclusion process as well as the importance of the expected in April Commission’s Communication for the quality of the National Roma Strategies AMALIPE proposes the following elements to the EU Framework for National Roma Strategies

1. The status of Roma inclusion policy: Roma inclusion should become one of the key priorities in the development process and cohesion policy at national level. Strong and consecutive measures for Roma inclusion are necessary. In this regard the EU Framework for National Roma Strategies should:  

·        require the Europe 2020 targets to be enriched by concrete Roma specific targets at national level: the achievement of the EU 2020 targets in itself does not guarantee progress in the integration of Roma. For example, even if the general early school leavers rate would decrease, there still might be no progress in keeping Roma children and youngsters at school. Roma specific targets at national level are necessary to encourage the national governments to work for achieving the national Europe 2020 targets among vulnerable communities such as the Roma community;     

·        require the National Roma Integration Strategies to be integral part of the National Reform Strategies and to be reflected in the National Strategic Reference Framework and the Operational programs in the next programming period: higher status of the National Roma Strategy and its clear links with the European funds absorption is one of the key preconditions for its real implementation. It is important to keep in mind that most of the EU countries with significant share of Roma population have adopted different kinds of Roma integration documents (strategies, programs, action plans) but their normative status has been very low, they have not been bound with the EU funds absorption documents and their implementation has been rather formal. The National Roma Strategy prepared within the EU framework should avoid this and should produce the necessary change in the life of Roma; Furthermore, the implementation of the NSRF and the various Operational programs should result in the social cohesion of all European citizens and if Roma are not explicitly included in the target and beneficiary groups, the problems of Roma all over Europe might be overlooked.

 ·        in addition, the European Commission should incorporate Roma inclusion among the conditionalities for the absorption of European funds: the Conclusions of the Fifth Cohesion Report introduced the idea of conditionalities and incentives for achieving national Europe 2020 targets - Member states that significantly under-perform shall lose eligibility for EU funds (conditionality), while Member states that significantly exceed the targets shall be awarded additional EU funds from a European performance reserve (incentive). We propose Roma inclusion to be explicitly added in the tentative list of conditionalities and incentives: this will strongly encourage the Member states to implement their National Roma Strategies

 2. Approach: The European Council Conclusions on Inclusion of the Roma from June 8, 2009 underlined the necessary approach for the Roma inclusion policy through 10 Basic Principles. The amendments in Article 7 of the ERDF Regulations from June 2010 also contributed through stressing the necessity of integrated interventions (that combine housing, education, employment, and so on) in marginalized communities. The National Roma Strategies should follow these trends and the Commission’s Communication should support it through:  

 ·        requiring Roma inclusion targeted measures: although the Council’s Conclusions on Roma inclusion underlined that “explicit but not exclusive targeting“ is inseparable part of the Roma inclusion approach, many national governments still hesitate in implementing Roma targeted actions even when the latter are designed for broader groups of vulnerable people or marginalized communities. The Commission should encourage Member states to appropriate Roma targeted measures that follow Basic principle 2 from the Council’s Conclusions;

 ·        stressing the importance of mainstreaming Roma issue in all relevant national policies and documents: Roma inclusion challenge could not be met only through Roma strategies and programs. The main points of the latter should be incorporated in the mainstream national policies and documents: in education, employment, health care, housing and others. This is also in accordance with Basic principle 4 “Aiming for the mainstream” from the Council’s Conclusions;  

 ·        encouraging integrated multi-dimensional measures: Roma measures and programs that combine interventions in employment, education, health care and housing would make better difference than the interventions in only one field. This approach is traced through Art. 7 of the ERDF Amendments and should be encouraged within the National Roma Strategies

 3. Financial back-up: Implementing complex programs for social inclusion of vulnerable groups (such as Roma) requires significant financial resources. European funds (through ESF, ERDF and EAFRD) are good opportunity in this direction. At the same time the engagement of the state budgets is also crucial. In order to be effective, the National Roma Strategies should provide the necessary back up for the Roma inclusion policy through:

 ·        defining minimal share for Roma inclusion targeted actions in the National Operational Programs: the experience from the present programming period has shown that if there are no minimal requirements for Roma targeted measures, the Managing authorities tend not to announce such measures or to under-finance them. As a result Roma are underrepresented as final beneficiaries and EU funds absorption hardly contributes to Roma inclusion in the degree it could. Defining minimal share for Roma targeted actions could happen in different ways: for example the key operational programs (Human Resources Development OP, Regional Development OP, etc.) could contain specific Priority Axes or Chapter for targeted actions in Roma community with specific financing. Another way is to prepare specific Operational programs that apply multi-dimensional interventions in marginalized communities;  

 ·        requiring raising the capacity of the Managing Authorities and the Inter-mediate bodies: their capacity to steer interventions in Roma community should be raised. Engaging experts from Roma origin is one of the good practices that should be encouraged;

·        ensuring that Roma inclusion targeted actions in the Operational Programs will have proper indicators: specific quantitative and qualitative indicators for measuring the impact of the operational programs on the development and the social inclusion of the Roma community are necessary. Proper monitoring and evaluation in this direction should be encouraged as well as system of conditionalities and incentives for fulfilling the “Roma” indicators;

·        encouraging the National governments for substantial core financing of the Roma inclusion programs from the state budget: the European funds should not abolish in any way the engagement of the national budgets

4. Institutional infrastructure: proper institutional infrastructure at national level is also of key importance for implementing Roma inclusion policy. Different Member states have very different experience in this direction and it is time for the European Commission to propose flexible framework for Roma inclusion institutional infrastructure at national level. The National Roma Strategies should contribute in this direction through:

·        encouraging the Member states to establish inter-ministerial executive body dealing with Roma inclusion: such a body should overcome the weaknesses of the existing inter-ministerial councils with only consultative responsibilities and to be medium- or high-level structure with executive responsibilities to plan, implement and evaluate Roma inclusion programs and actions. Participation of Roma in this body should be strongly encouraged. Participation of national EU funds managing authorities in the work of this body should be ensured;

·        in addition, the European Commission should establish cross-DG Unit to coordinate the implementation of the EU Framework for National Roma Strategies. The European Roma Platform should go beyond the exchange of experience and to appropriate stronger policy development, consultation and monitoring functions.  

5. Roma participation: the active engagement and participation of Roma community in planning, implementing and evaluating the Roma inclusion measures is not only human rights issues. It is also a question of efficiency and effectiveness: the Roma inclusion policy could not succeed without active participation of Roma. In addition, this policy should support the process of modernization and self-organizing of the Roma community. The National Roma Strategies could contribute for the Roma participation via:   

·        requiring the national authorities to invest resources in raising the capacity of Roma community, CBOs and NGOs to participate in all phases of the National Roma Strategy: from planning through implementation to monitoring and evaluation;

·        proposing mechanisms for policy coordination with Roma NGOs: different Member states have different experience (successful and unsuccessful) for consultative mechanisms with participation of state institutions and Roma NGOs. It is time for the European Commission to require appropriate policy coordination with Roma organizations and to propose different models for it;

·        requiring incorporation of Roma NGOs as concrete beneficiaries in the new Operational programs as well as the opportunity for Roma inclusion strategic grants: broader participation of Roma NGOs in EU funds absorption will help achieving stronger impact on the development Roma community. That is why Roma NGOs (national umbrella Roma organization/s, Roma organizations with proved capacity and expertise, etc.) should be included as concrete beneficiaries in the operational programs for the next planning period in order to be able to implement strategic projects and to take their responsibilities for fostering Roma inclusion.

 6. Scope: The rich experience of institutions and organizations accumulated during the previous years outlined the main fields of intervention that fall within the scope of Roma inclusion. The EU Framework for National Roma Strategies should re-affirm and make them more concrete:

·        social inclusion in its main fields (education, employment, health, living conditions) should be stressed: the EU Framework should propose concrete successful practices as well as requirements within these fields. For example, introducing intercultural education and education in ethnically mixed class-rooms are examples for such practices and requirements in education, etc.;

·        the empowerment of Romani women (including also addressing the most aching problems Romani women face in the fields of education, health, employment and living conditions) as crosscutting issues and specific field of intervention should be explicitly targeted: since Romani women face multiple discrimination and their situation is much more vulnerable, the problems of Romani women should be obligatory included in the National Roma Strategies. Furthermore, the latter should have a clear gender-sensitive perspective. It should be included in both ways: as crosscutting issue and as specific field of intervention in order to ensure stronger impact on the situation of Romani women. This is in line with Basic Principle 5 “Awareness of the gender dimensions” of the Council Conclusions from June 8, 2009;

·        incorporating the topic of Roma culture and identity should be also reguired (as crosscutting issues and specific field of intervention): Roma inclusion is closely linked with preserving and renewing Roma culture and identity; it means in no way assimilation and acculturation. That is why the National Roma Strategies should pay special attention on Roma culture in both ways: as crosscutting issue and as specific field of intervention. This is in line with Basic Principle 3 “Inter-cultural approach” of the Council Conclusions from June 8, 2009)