COMPARATIVE LAW REVIEW OF LONG-TERM CARE SYSTEMS IN SOME EUROPEAN COUNTRIES

The organisation and funding of a long-term care system have been one of the most commonly debated issues in the social policies of developed European countries since the 1920s. The key issue in the debate on the long-term care system is to what extent the population should finance their own needs for custodial care and assistance, and to what extent it should be done by the state. Another important issue is whether the funds for long-term care should only be beneficial for those who cannot pay from their own assets (residual model), or whether long-term care services should be a universal right. The existence of such huge national differences has contributed to the intensity of this debate, both regarding how the system is organised (according to the type of benefits) and how the resources are generated. Bearing in mind the foregoing, in this paper, the author analyses the long-term care systems for people dependant on custodial care and assistance in several most developed European countries. The paper examines their organisation and funding, and highlights their major advantages and disadvantages, which may eventually serve as an indication for improving the domestic system.