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Privileging Biological or Residential Relationships: Family Policy on Obligations to
Children in 12 Countries
Daniel R. Meyer
University of Wisconsin–Madison
School of Social Work
Institute for Research on Poverty
drmeyer1@wisc.edu
Christine Skinner
University of York
Department of Social Policy and Social Work
christine.skinner@york.ac.uk
Jacqueline Davidson
University of York
Social Policy Research Unit
DRAFT August 2012
We thank Deborah Johnson for assistance with the manuscript and Emily Warren and
Vanessa Rios Salas for research assistance.
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ABSTRACT
Children’s domestic living arrangements have become increasingly complex over the last
several decades in developed countries, with increasing numbers of children born to parents who
do not live together, and, even among those born to parents who do live together, increasing
numbers are experiencing their parents separating and one or both re-partnering. Children may
live with a variety of adults including biological parents, married step-parents, cohabiting stepparents, and, perhaps, other adults who have no biological relationship to the child but do take on
aspects of the parental role. In countries with generous and well-developed welfare states, these
demographic changes may have few consequences for the economic well-being of children. But
in other countries, these demographic changes raise complex questions about who has financial
responsibility for the children. In this paper, we identify six common family transitions that
children may experience and conceptualize how different potential child support (child
maintenance) schemes might deal with these transitions. We then investigate how the child
support policies in place in the mid-2000s in several countries handle these family transitions,
and use the results of this analysis to categorize countries into the five potential child support
schemes. Finally, we compare the categorization of child support schemes with the level of
family complexity in each country to see if countries with the highest levels of complexity tend
to organize responsibility differently.
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Children’s domestic living arrangements have become increasingly complex over the last
several decades in developed countries, with increasing numbers of children born to parents who
do not live together, and, even among those born to parents who do live together, increasing
numbers are experiencing their parents separating and one or both re-partnering. Yet, the rates
of these types of complexity and instability are not uniformly high across countries, sometimes
varying substantially across countries that are similar in other ways.
To examine these trends and document the differences between countries, Andersson
(2002) attempts to provide comparable and systematic data across a range of sixteen developed
countries.1 Andersson (2002) found substantial variation in the proportion of children born
outside of residential unions (that is, whose parents were not cohabiting or married). It varied
from 3% of births or less in five of the countries he studied, including Finland, to more than 1718% in the United States (17%) and the German Democratic Republic (GDR; because he is
tracking children’s lives over time, he uses data prior to German reunification). Of these
children born outside of unions, it is relatively common for them to experience their mother
beginning a new residential partnership (either cohabitation or marriage), often fairly quickly. In
seven of nine countries for which there is data, more than half of these children experienced their
mother partnering (which may be re-partnering) by the time they were nine years of age
(Andersson 2002). But even though this is a common experience, there is substantial variation in
proportions, from 32% in Poland to 87% in the GDR.
Family instability and complexity is not just an issue for children born outside of unions.
For those born in an unmarried cohabiting relationship, by the time they were nine, one-quarter
These “countries” include separate data for Austria, Czech Republic, Finland, Flanders, France, GDR, Hungary,
Italy, Latvia, Lithuania, Norway, Poland, Slovenia, Spain, Sweden, USA, and West Germany.
1
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or more had experienced the dissolution of their parents’ relationship in twelve of fourteen
countries, and, among these countries, Hungary (48%), Latvia (58%), and the United States
(64%) have very high rates. In contrast, rates of dissolution in Italy are estimated to be quite low
(7%). While the rate of dissolution is lower for children born in marriage, more than one in ten
marital children has experienced dissolution by age nine in twelve of the sixteen countries with
data (Andersson 2002). The high rates of dissolution are followed in many countries by high
rates of re-partnering; within three years of parental separation (either marital or nonmarital)
more than one-third of children experienced their residential parent being in a union again in
Norway, United States, Germany, Hungary, Czech Republic, and Slovenia.
The conclusions from these data are clear: first, the degree of family instability varies
substantially across countries. This has also been documented in other studies, examining
different countries and different indicators of children’s experiences (e.g., Chapple 2009;
Iacovou & Skew 2010; Organization for Economic Cooperation and Development [OECD]
2011). Second, regardless of the circumstances of a child’s birth, a large proportion of children
will experience some time living apart from one of their biological parents, and many of these
will experience time living with one of their parent’s new partners.
Family instability raises questions about who has financial responsibility for children.
When children live with their biological parents, it is clear that both parents have financial
responsibility for the children. When children live with only one biological parent, countries
have developed a variety of child support (child maintenance) policies that outline whether the
resident parent, the nonresident parent, some other adult, or some combination has financial
responsibility for them (Corden 1999; Meyer, Skinner & Davidson 2011; Skinner & Davidson
2009). However, as can be seen in the data on family complexity, children may go on to live
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with a variety of adults including biological parents, married step-parents, cohabiting stepparents, and, perhaps, other adults who have no biological relationship to the child but do take on
aspects of the parental role. These family transitions raise complex questions about who has
financial responsibility for the children.
In this paper, we identify six common family transitions that children may experience and
conceptualize how different potential child support schemes might deal with these transitions.
We then investigate how the child support policies in place in the mid-2000s in several countries
handle these family transitions, and use the results of this analysis to categorize countries into the
five potential child support schemes. Finally, we compare the categorization of child support
schemes with the level of family complexity in each country to see if countries with the highest
levels of complexity tend to organize responsibility differently.
I. Conceptual Overview of Biological and Residential Responsibility Schemes
An important distinction in classifying family policy across countries is whether financial
responsibility for children resides primarily in private relationships or in the state, and a
substantial amount has been written on this topic (e.g., Cunningham-Burley & Jamieson 2003;
Eekelaar 1991; Esping-Anderson 2009). One key distinction is between residual welfare states
(in which individual families have primary financial responsibility, with the state playing a role
only when parents are not able to provide) and those countries in which financial provision for
children is seen more as society’s responsibility as a whole. Another broad distinction is whether
policy allows for defamilialization, that is, the extent to which the state provides social rights to a
minimum income standard that means individuals do not need to rely on the family (Hantrais
2004). The literature on the role of parents versus the state and the family versus the state is
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fairly well developed, but it is not our focus here. Instead, we are interested in the private
sphere, in identifying which adults are responsible, given family changes.
We begin our categorization of child support schemes of assigning responsibility for
children by outlining common family transitions. Distinctions between schemes are easiest to
see when family transitions occur because different types of transitions change responsibilities in
some schemes and not others. In the top panel of Table 1 we introduce notation and identify a
base case and six transitions. The base case is simple: a focal child lives with one parent (the
resident parent, R) and the other parent is living elsewhere (the nonresident parent, N), and
neither of these parents is living with a partner or has had children with another partner. There
are then six main family transitions of interest that could occur from this base case. The
transitions are differentiated by which parent gains a new partner — the nonresident parent gains
a new partner (NNP) in T1 and the resident parent gains a new partner (RNP) in T4. The
transitions are further separated by whether the new partnership includes an “old” child (the child
of the new partner, the stepchild of the focal child’s parent) in T2 and T5 or a “new” child (a
biological child of the focal child’s parent and the new partner) in T3 and T6. There are other
potential transitions that we could include, including the addition of new children without a new
resident partner, or the dissolution of the relationship with a new partner, or combinations of
these transitions; we ignore these because the issues are closely related to other cases we cover.
In the base case, and after each of these transitions, children live with one parent (R) and
the other parent (N) lives elsewhere; in some of these cases children also live with another adult,
their parent’s new partner (RNP). Which of these adults should have financial responsibility for
the child? Countries assign responsibilities differently, as seen in their child support schemes.
One key division is between biological responsibility and residential responsibility. Under an
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extreme biological scheme determining parentage is critical. A child’s two biological parents
always retain financial responsibility, regardless of their family transitions.2 Thus, in the base
case, the resident parent, R, would have obvious responsibility and the nonresident parent, N,
would also be responsible, with the obligations paid as child support under whatever rules or
guidelines are in place. If either or both parents re-partner and live with new children (either
biological, or the children of the new partner), it would not matter: biological parents have full
responsibility. This is the first of our five schemes (A-E) defined in Table 1 as “A: Biology
Absolute.” The bottom panel of Table 1 shows that no transition affects N’s obligation to his/her
biological child.
In contrast, in an extreme residential scheme, financial responsibility for a child would
end if a parent/adult stopped living with a child (or financial responsibility would never start if
the parents never lived together following the birth of the child). Because no parent has financial
responsibilities for nonresidential children, no child support system is required. Only resident
parents would be responsible for the child until/unless the resident parent re-partners, in which
case the new partner would also have responsibility for all children and stepchildren with whom
he/she lives.3 No developed country that we are aware of has this type of extreme residential
scheme, so we do not consider it here.
We do, however, consider a scheme, “B: Residence Primary,” in which residence is more
important than biology in some instances. In this scheme, a country requires a nonresident
parent to be financially responsible in the simple base case, consistent with a principle in which
two separated biological parents should be financially responsible for any child (as long as they
2
For simplicity, we ignore adoption, essentially assuming that adoptive parents can be treated as biological parents
in later family transitions.
3
If a child lived with both parents after they split (joint custody/joint residence or equal shared care), each parent
would have full responsibility for the child whenever the child was residing with him/her, and no responsibility
when the child was not.
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do not have other obligations). But in scheme B, any other residential transition could change
who is responsible for a child, with residence being more important than biology. First consider
any type of transition that involves the resident parent living with a new partner, whether they
have new children or not (T4-T6). In this case, the focal child becomes their joint financial
responsibility because of their joint residence and the nonresident parent’s child support
responsibility is lessened or ends. Alternatively, consider the division of responsibilities when it
is the nonresident parent who re-partners (T1-T3). If the nonresident parent lives with a new
partner, he/she has obligations to the new partner, as well as to any children living in their home
(whether step or biological children), so the child support obligation to the original focal child is
lessened (or perhaps eliminated). In these ways, residence trumps biological responsibilities.
Thus the bottom panel shows that the financial obligation of N is lowered under any transition.
Note that in this scheme (and in others described below), we group together the
elimination of financial responsibilities with the lowering of financial responsibilities. We do this
for both pragmatic and conceptual reasons. Pragmatically, the data we will use to categorize
countries are not always clear on whether child support is lowered or eliminated. Moreover, in
many cases elimination of responsibility is merely the extreme case of lowering the obligation.
For example, often N’s ability to pay support matters; N’s responsibility after a transition might
be eliminated if there was deemed to be no ability to pay, a small amount if there was a small
ability to pay, etcetera.
The third scheme we consider, “C: Biology Primary,” is similar to scheme A (Biology
Absolute) in that biological relationships primarily define responsibilities. However, in this
scheme more recognition is given to financial responsibility for residential biological children
than biological children who lived elsewhere. In this scheme, if the nonresident parent re-
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partners but no children are involved (T1), or if the nonresident parent re-partners and has only
stepchildren (T2), this does not affect the responsibility for the focal child, since biological
relationships are primary. However, if the nonresident parent has a new biological child with
whom he/she lives (T3), this would lessen the responsibility to a previous biological child (the
focal child), since biology and residence together trump a child who has only biology. Because
biology is primary in this scheme, N’s responsibilities to biological children are unaffected by
R’s transitions (T4-T6).
In an adaptation of this scheme, “D: Biology Modified,” responsibility for biological
children is still quite important, but responsibility for adult partners as well as for children is
incorporated. The key difference between schemes C and D occurs when the nonresident parent
takes a new partner, but no children are involved (T1). If a country wants to ensure that a
nonresident parent fulfills obligations to a new partner, it could lower (or eliminate) the
responsibility for the focal child whenever there is a new residential partner. In this scheme,
though, there is no new responsibility for resident stepchildren (T2); they remain the
responsibility of their biological parents. Nor does N have a change in responsibility for R’s
transitions, since, for example, there is no responsibility for stepchildren (N’s biological child is
RNP’s stepchild, and biological ties remain).
Finally, there could be a Biology Pragmatic scheme (E). This scheme is like the
modified biological scheme (D), but it also considers responsibilities to stepchildren. Typically
N’s responsibility to a residential stepchild (T2) would be enough to lessen responsibility to a
biological nonresident child. However, this scheme has what could be considered a fundamental
inconsistency. If a nonresident parent’s stepchildren can lower the obligation to his/her
biological child, then that can be seen as one having some responsibility to stepchildren. But if
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this is the case, then a resident parent’s new partner (RNP) should have some responsibility for
the focal child (the RNP’s stepchild), and this new adult with responsibility could lower the
obligation of N. In the countries with this type of scheme, however, this change does not occur.
From the description of the child support schemes in these countries, which we will describe
below, this is because the lowering of the obligation to focal child in response to a transition
involving stepchildren is seen as merely reflecting the fact that more children in N’s home mean
he has less ability to pay child support to the focal child, rather than reflecting a general principle
that adults have financial responsibility for stepchildren. For this reason, we term this scheme
“Biology Pragmatic” — biological relationships are the foundation of child support obligations,
but these obligations are tempered by a nonresident parent’s available resources, and
stepchildren matter in the calculation of available resources.
These are not the only conceptual schemes that are possible. We have already mentioned
what could be called a “Residence Absolute” scheme, in which responsibilities follow residence
only, and biology leads to no obligations. But other combinations are possible as well; for
example, if an RNP had substantial resources and was willing to provide for the focal child, a
country could essentially assign responsibility to RNP and lower N’s obligation. We have
focused on the five schemes we outline because they are conceptually distinct and are
represented by countries in our data. We now turn to our analysis of what countries actually do
in practice.
II. Data and Approach
This paper uses data gathered on the child support schemes in 2006 in 12 countries —
Austria, Australia, Canada, Denmark, Finland, Germany, the Netherlands, New Zealand,
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Norway, Sweden, the United Kingdom, and the United States.4 The data were gathered to assist
the U.K. government in evaluating changes to its child support policy (Skinner, Bradshaw &
Davidson 2007). An expert national informant was identified in each country and asked to
describe relevant policy, an approach often used in comparative research on tax and benefit
systems (see, for example, Bradshaw et al. 1996; Bradshaw & Finch 2002; Corden 1999; or
Eardley, Bradshaw, Ditch, Gough, & Whiteford 1996). In federalist countries, informants
selected a single jurisdiction’s policies to describe; thus the Canadian data are from Ontario and
the U.S. data are from Wisconsin. The expert informants, primarily academics who conduct
policy research, were each sent a questionnaire focused on a variety of aspects of child support
policy; it was structured to allow some scope for discursive responses. Questions were asked
about how child support amounts were assigned, followed by several specific questions covering
the nonresident and resident parents’ family situations. For example, country experts were
asked:

Is the obligation affected by whether the nonresident parent has a new partner
with whom he/she lives? How does it affect the obligation? Does a new partner’s own child (the
nonresident parent’s stepchild) matter to the obligation? How?

Is the obligation affected by whether the parent with care has a new partner?
How is the obligation affected? Does a new partner’s own child (the parent with care’s
stepchild) matter to the obligation? How?
Informants also responded to several vignettes in order to elicit child support policy
responses to common scenarios, including the re-partnering of the parents.
4
Data were also gathered from Belgium and France. However, both these countries have a discretion-oriented
judicial system, so questions were often answered “it depends on the judge;” as a result, we do not incorporate these
countries into our analysis.
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Our approach is relatively straightforward. We take responses within each country to the
series of questions about whether different family situations are considered in the setting of child
support obligations. We then confirm our understanding of the scheme by examining responses
to the vignette in which experts described what would happen to obligations in a series of
example cases that included family transitions.
The focus of this work is not on the precise calculation of the amount of the obligation,
but on whether the amount is varied depending on family circumstances. Thus, we categorize
countries based on whether obligations are lower in complex family circumstances, rather than
the actual amount of the difference. Our approach is obviously limited by the accuracy of the
experts’ information. Moreover, some countries have changed policies since these data were
collected; however, no more recent systematic policy review exists and this analysis serves to
elucidate the potential range of different responses of child support schemes to complex family
forms.
III. Results
Table 2 shows the results for each transition, and Table 3 shows the categorization into
schemes. In every country, in the base case, an N has financial obligations to his/her children.
We focus therefore on whether the obligation changes when transitions occur. As shown in the
first row of Table 2, in Australia, R’s transitions (T4-T6) are irrelevant to the obligations of N.
An NNP (T1) would not change the obligation, nor would it matter if that NP brings a stepchild
into the N’s home (T2). All of these policies are consistent with the notion that one has an
obligation to a biological child that is not modified by residence. However, if the N and the NP
have a child together (T3), this is a new obligation of the N, which then lessens the obligations to
previous children. Thus, because only the N’s new biological children matter to the obligation,
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Table 3 shows this as a clear case of the Biology Primary scheme (C). Denmark, Norway, and
the United Kingdom are all similar to Australia in the results of family transitions, so they are
also categorized as Biology Primary schemes.5 The Norway case has an unusual feature (at the
time of the study). The obligation is calculated after considering the income of the N and an
amount set aside for own expenses. Because NPs are typically seen as potential earners, the
amount set aside for an individual living with a partner is less than the amount set aside for an
individual living alone. This means that in certain cases, the obligation to a nonresident child
could actually increase if an N began living with an NP.
Austria, Finland, and Germany are similar to Australia in that a new resident biological
child (T3) lowers the obligation to the focal child, and obligations are not changed based on the
R’s transitions (T4-T6). These countries differ from the first set of countries in that the addition
of a new spouse of the N (T1) can lower the obligation, because the N is essentially financially
responsible for a new spouse. Thus, Table 3 shows this as a Biology Modified scheme (D).
The United States, as exemplified by Wisconsin, is the only country studied that does not
change the obligation to the focal child in response to family transitions, as shown in Table 2.
Thus, Table 3 shows the United States characterized as a Biology Absolute scheme (A). In
Wisconsin, as in every state in the United States, the R’s living situation is irrelevant to the N’s
obligation. Similar to several other U.S. states, no adjustment is made when Ns re-partner. In a
few states, adjustments are made when Ns have new biological children (Brito 2005; Caspar
2006; Venohr & Griffith 2005), but in Wisconsin there is no adjustment; biological obligations
are not modified by residence.
5
We have categorized countries according to the responses of experts as to common cases, but our categorization
may not hold for all cases. For example, the Danish expert did note that it is possible for an NP to lower the
obligation to focal child, but because this would only occur after delinquency and after a full court review, and then
is not guaranteed, we do not consider it the typical case here.
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The Netherlands and Sweden can be characterized as Residence Primary schemes (B). In
both these countries, an R’s transitions (T4-T6) can mean changes to the obligation to the focal
child. This type of adjustment occurs because obligations are determined based on the economic
resources of both parents, and economic resources include the potential to draw on those
resources. Thus, if an R adds an NP who has low or no earnings, the R’s needs have increased
with the additional person in the home. If the obligation were recalculated, the N would now be
a little better off compared to the R than before; this can result in an increased child support
obligation. Correspondingly, if the RNP has moderate income, R is now better off compared to
N than before, so N’s obligation could decrease. In terms of the Ns’ transitions, adding any new
person into the home (T1-T3) increases needs and can result in the N having a lower obligation.
Thus, these are countries in which residence is quite important, and can (at least in principle)
lower biological obligations.
Finally, Canada and New Zealand are categorized as Biology Pragmatic schemes (E). In
these countries, an N’s transitions (T1-T3) can lower the obligation, using the same general logic
as the Netherlands and Sweden. However, in these countries, the R’s resources and needs
transitions do not generally enter the calculation of the amount owed, so the R’s transitions (T4T6) do not change obligations. Countries do vary by the transitions under which residence can
modify biologically based obligations, and by whether family transitions of adults matter, or only
when transitions include children. Special conditions can matter as well: for example, in Ontario
(Canada), the N’s transitions can all result in a lower obligation to the focal child, but only if the
transitions create undue economic hardship. Thus, Ontario can be seen as operating two
different schemes: for lower-income Ns, residence is important; in contrast, for parents who both
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have moderate incomes, residence is unimportant, and the system resembles the extreme
biological scheme of Wisconsin/United States.
IV. Discussion
Our analysis has shown that there is diversity in approaches across countries, although
most of the countries are more focused on biology than residence. One country (United States)
follows a scheme that emphasizes biological responsibility alone, and seven countries follow a
scheme that we characterize as primarily privileging biology, but allowing it to be modified by
residence in some circumstances. Two countries we consider Biology Pragmatic schemes
(Canada and New Zealand), and two countries we consider as following a Resident Primary
scheme (see Table 3).
The rates of family instability and transition differ across countries. Child support policy
could be linked to the level of family instability in a country. That is, if a country experiences a
high level of family transition, one might imagine that their policy would be particularly likely to
take this into account. On the other hand, if a country has high rates of family transition, policymakers might be particularly reluctant to take into account these changes because the magnitude
of changes would make the workload high for those charged with assessing obligations and
monitoring and enforcing their payment.
We are able to provide some suggestive data on this issue in Table 4a and Table 4b.
Table 4a shows demographic indicators from the six countries in which Andersson (2002)
provided data on the rate of family changes in four key areas. Table 4b shows point-in-time
measures of children’s living situations in ten countries. Together, these enable us to explore
whether it is the countries with the most change/most instability that factor in residence to their
scheme regarding obligations for children. The table shows substantial diversity on each
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indicator. In Table 4a, the United States stands out with the highest rate in three of the four
indicators of family transitions, sometimes substantially higher than the second-highest country.
Norway shows the highest rate of partnering for children born to lone mothers. Table 4b, shows
that the United States has by far the highest rate of children living in a sole-parent family, and
Denmark is second highest; the United States also has the highest rate of living in a step-family,
and Finland is second highest.
Interestingly, the United States, Norway, and Denmark, the countries with the highest
rates of residential transitions and of single parenthood, are those with the least modifications for
residence — the United States as the example of the Biology Absolute scheme and Norway and
Denmark as Biology Primary schemes. There are several competing explanations for this
suggested relationship. As suggested, this could be pragmatic: if the child support system in a
country with high rates of transitions were to adjust child support obligations in response to
residential transitions, changes to obligations would need to occur fairly often. Or perhaps this is
motivated by a desire to protect children financially from transitions of their parents, or perhaps,
especially in the U.S. case, the lack of responsiveness of policy may be an intentional effort to
dampen family instability. All explanations are consistent with the observed relationship; further
research would be useful.
This research has described parents in terms of residential relationships, rather than
focusing on gender. We have done this because custody laws in developed countries are
generally gender-neutral. If, however, mothers are much more likely to be resident parents than
fathers, a country that had strong gendered roles for parents might be more likely to think of the
categories as based on fathers and mothers, rather than nonresident and resident parents.
Describing a country’s rules in terms of nonresident fathers and resident mothers can provide
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additional insight. For example, in both Norway and Austria a nonresident father’s obligation to
a focal child can change if he has a new wife, but the effect can be in opposite directions. In
Norway, the new wife is essentially assumed to be an economic contributor to the household, so
the nonresident father is better off and he may be able to afford more child support. In Austria,
in contrast, a nonresident father is essentially taking on a new dependent when he marries, and
thus he is allowed a higher amount for his needs, and his obligations to his child could go down.
This contrast potentially highlights differences in gender roles and perhaps gender equality
mechanisms in countries. More explicit consideration of the role of gender within and across
countries could yield important further insights.
We have highlighted here differences across these countries — differences in their child
support policy schemes, and differences in their level of family instability and transitions.
However, the level of transitions seems to be increasing in countries where there is comparable
over-time data (Chapple 2009); while there is some debate over the extensiveness of the second
demographic transition, the level of family complexity does not appear to be lessening (OECD
International Futures Programme 2011). Family policies developed in periods of relative
stability may need to be re-examined to see if they are still appropriate in contemporary
circumstances.
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References
Andersson, G. 2002. “Children’s experience of family disruption and family formation: Evidence
from 16 FFS countries.” Demographic Research 7: 343–364.
Bradshaw, J. & N. Finch. 2002. A comparison of child benefit packages in 22 countries.
Department for Work and Pensions Research Report No. 174, Corporate Document
Services, Leeds.
Bradshaw, J., S. Kennedy, M. Kilkey, S. Hutton, A. Corden, T. Eardley, H. Holmes, & J. Neale.
1996. The employment of lone parents: A comparison of policy in 20 countries. The
Family and Parenthood: Policy and Practice, Family Policy Studies Centre, London.
Brito, T. 2005. “Legal issues, complicated families, and child support policy.” Report to the
Wisconsin Department of Workforce Development. Madison, WI: Institute for Research
on Poverty.
Caspar, E. 2006. “A review of child support guideline policies for multiple family obligations:
Five case studies.” Report to the Wisconsin Department of Workforce Development.
Madison, WI: Institute for Research on Poverty.
Chapple, S. 2009. “Child well-being and sole-parent family structure in the OECD: An analysis.”
OECD Social, Employment and Migration Working Paper No. 82.
Corden, A. 1999. Making child maintenance regimes work. Family Policy Studies Centre,
London.
Meyer, Skinner & Davidson | 18
*Conference draft: Please do not cite*
Cunningham-Burley, S. and L. Jamieson (eds.). 2003. Families and the state: Changing
relationships. Basingstoke: Palgrave.
Eardley, T., J. Bradshaw, J. Ditch, I. Gough, & P. Whiteford. 1996. Social assistance in OECD
countries: Country reports. Department of Social Security Research Report No. 47,
HMSO, London.
Eekelaar, J. 1991. “Parental responsibility: State of nature or nature of the state.” Journal of
Social Welfare and Family Law 13(1):37–50.
Esping- Anderson, G. 2009. Incomplete revolution: Adapting welfare states to women? New
roles. Oxford: Polity Press.
Hantrais, L. 2004. Family policy matters: Responding to family change in Europe. Bristol: The
Policy Press.
Iacovou, M. & A. Skew. 2010. Household structure in the EU. ISER Working Paper No. 201010, Colchester: Institute for Social & Economic Research.
Meyer, D. R., C. Skinner & J. Davidson. 2011. “Complex families and equality in child support
obligations: A Comparative policy analysis.” Children and Youth Services Review 33:
1804–1812.
OECD. 2011. Doing better for families. Paris: OECD Publishing.
OECD International Futures Programme. 2011. The future of families to 2030: A synthesis
report. Paris: OECD Publishing.
Meyer, Skinner & Davidson | 19
*Conference draft: Please do not cite*
Skinner, C., J. Bradshaw, & J. Davidson. 2007. Child support policy: An international
perspective. Department for Work and Pensions Research Report No. 405, Corporate
Document Services, Leeds.
Skinner, C. & J. Davidson. 2009. “Recent trends in child maintenance schemes in 14 countries.”
International Journal of Law, Policy and the Family 23(1): 25–52.
Venohr, J., C. Venohr & T. E. Griffith. 2005. “Child support guidelines: Issues and reviews.”
Family Court Review 43(3): 415–428.
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*Conference draft: Please do not cite*
Table 1: Family Transitions and the Assignment of Financial Obligations for Children in Five Schemes
Living Arrangements: Base Case and Six Transitions (T1-T6)
Base: Child lives with resident parent (R); not with nonresident parent (N); neither parent has a new partner
T1. Nonresident parent (N) adds new partner (NNP), no children involved
T2. Nonresident parent (N) had new partner (NNP), adds resident stepchild (new partner’s child)
T3. Nonresident parent (N) had new partner (NNP), adds new biological child together
T4. Resident parent (R) adds new partner (RNP), no children involved
T5. Resident parent (R) had new partner (RNP), adds resident stepchild (new partner’s child)
T6. Resident parent (R) had new partner (RNP), adds new biological child together
Five Schemes for Assigning Financial Obligations
Scheme
Description
A. Biology Absolute
N and R always have obligation to focal child
B. Residence Primary
Financial obligations primarily linked to residence
C. Biology Primary
Financial obligations primarily biological, but biology and residence
together is a higher claim than biology alone
D. Biology Modified
Financial obligations primarily biological, biology and residence together
is a higher claim than biology alone; residential partnerships also exert a
higher claim than biology alone
E. Biology Pragmatic
Any residential relationship of N exerts a higher claim than a
nonresidential biological claim
After a Transition, Does the Nonresident Parent’s Obligation Decline?*
Scheme
T1
T2
T3
T4
T5
T6
A. Biology Absolute
No
No
No
No
No
No
B. Residence Primary
Yes
Yes
Yes
Yes
Yes
Yes
C. Biology Primary
No
No
Yes
No
No
No
D. Biology Modified
Yes
No
Yes
No
No
No
E. Biology Pragmatic
Yes
Yes
Yes
No
No
No
*In some cases the obligation declines to zero (i.e., is eliminated).
Meyer, Skinner & Davidson | 21
*Conference draft: Please do not cite*
Table 2: Policy in 12 Countries: After a Transition, Does the Nonresident Parent’s Obligation Decline?
Country
T1: N adds
new partner,
no children
T2: N had
new partner,
adds resident
stepchild
T3: N had new
partner, adds
resident
biological
child
T4: R adds
new partner
T5: R had
new partner,
adds
stepchild
T6: R had
new partner,
adds new
resident
biological
child
Australia
No
No(a)
Yes
No
No
No
Austria
Yes, if 1
No
Yes
No
No
No
Canada
Yes if 2
Yes if 2
Yes if 2
No
No
No
Denmark
No(b)
No
Yes
No
No
No
Finland
Yes if 1
No
Yes
No
No
No
Germany
Netherlands
New Zealand
Norway
Sweden
United
Kingdom
United States
Yes if 1
Yes if 3 and 4
Yes
No(c)
Yes if 3 and 4
No
No
Yes if 3 and 4
Yes
No
Yes if 3 and 4
No
Yes
Yes if 3
Yes
Yes if 3
Yes
Yes
No
Yes if 3 and 4
No
No
Yes if 5
No
No
Yes if 3 and 4
No
No
Yes
No
No
Yes if 3 and 4
No
No
Yes
No
No
No
No
No
No
No
Coding of Conditions: 1 if married; 2 if undue hardship; 3 if N has low income; 4 if new partner has low income; 5 if new partner has
high income and R relies on it.
(a) If a court ordered N to assume financial responsibility for the stepchild, this would lower the obligation to focal child.
(b) If N was delinquent and asked for a full review; in the review, the amount of protected income would increase because N has a
new partner; if this is more than the income the partner brings, the obligation to focal child could be lowered.
(c) New partner decreases the amount set aside for his expenses so could in principle increase his obligation.
Meyer, Skinner & Davidson | 22
*Conference draft: Please do not cite*
Table 3: Categorization of Countries’ Child Support Schemes
A: Biology
B: Residence
C: Biology
Absolute
Primary
Primary
United States
Netherlands
Australia
Sweden
Denmark
Norway
United Kingdom
D: Biology
Modified
Austria
Finland
Germany
E: Biology
Pragmatic
Canada
New Zealand
Meyer, Skinner & Davidson | 23
*Conference draft: Please do not cite*
Table 4a: Child Support Scheme and Degree of Family Transitions
Scheme
% births
Of births to lone
Of those born in a Of those who experience
to lone
mothers, % ever
union, % ever out
parental separation, % ever in
mother
in union by age 3 of union by age 15 union within 6 years
D: Biology Modified
10
44
26
47
Austria
D: Biology Modified
3
39
20
45
Finland
D: Biology Modified
6
32
29
50
Germany*
C:
Biology
Primary
7
54
21
57
Norway
B: Residence Primary
5
29
30
51
Sweden
A: Biology Absolute
17
37
40
67
United States
Notes: Rates taken from Andersson (2002), Tables 2, 3, 4, and 7, period of data varies. * For Germany, we use the rates for “West Germany.”
Table 4b: Child Support Scheme and Cross-Sectional Measures of Children’s Living Situations
Scheme
Austria
Canada
Denmark
Finland
Germany
Netherlands
Norway
Sweden
United Kingdom*
United States
D: Biology Modified
E: Biology Pragmatic
C: Biology Primary
D: Biology Modified
D: Biology Modified
B: Residence Primary
C: Biology Primary
B: Residence Primary
C: Biology Primary
A: Biology Absolute
% children living in % children living in
sole-parent family
step-family
14
8
18
11
19
12
16
13
15
9
12
7
16
10
14
12
16
12
24
14
Notes: Rates are taken from Chapple 2009, and cover 2005–2006. * For United Kingdom, we use the rates for England.
Meyer, Skinner & Davidson | 24