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Nation as Context: Comparing Child-Care Systems across Nations

by Sally Lubeck - 1995

Reviews recent trends in female employment and preschool provision in the United States and Europe, discussing how governments have responded to the issues. "Nation as context," a type of cross-national research, is developed by comparing and contrasting child care and early education systems in Germany, France, and the United States. (Source: ERIC)

This article provides an overview of recent trends in female employment and preschool provision in the United States and the European Union. It then explores some of the ways in which governments have responded to issues regarding women’s work and child rearing. One type of cross-national research—“nation as context”—is then developed by comparing and contrasting the child care and early education systems of three nations: the former German Democratic Republic, France, and the United States. A model is presented for comparing these systems along two dimensions, one marking the degree of administrative and fiscal centralization, the other the degree of uniformity.

The study of child bearing and rearing in homes, neighborhoods, and villages has been of interest to anthropologists for some time, but societal changes in the late twentieth century have stimulated interest in forms of child rearing that occur outside of the familiar context of near and extended kin and close-knit groups.1 In consequence, systems of child care and early education have become an important research focus both here and abroad.

Governments are making a commitment to early education for a variety of reasons.2 A number of studies have made the case that early education has value for children. Moreover, government sponsorship and subsidization of some types of programs have helped to address working parents’ need for child care. Virtually all advanced industrial societies are in the throes of change, as new patterns of family formation and other demographic shifts have stressed traditional forms of caregiving. Macroeconomic factors that have affected all postindustrial nations in greater or lesser degree include a decrease in well-paying manufacturing jobs, an increase in lower-paying jobs in the service sector, and a continued increase in women’s rate of labor force participation.3

Families historically have relied on extended kin for caregiving, but, increasingly, young children do not live in intergenerational households, and, with women of all ages employed in greater numbers, fewer family members are available to care for children. In many families both parents must work to maintain the same standard of living that one parent could provide only a generation ago. The increase in the number of single-parent—what the British call “lone-mother”—families in many nations has also increased the demand for extrafamilial care.

Most mothers in the West now work outside the home. Fully 68 percent of U.S. mothers with children under age eighteen are employed.4 In Europe, 58 percent of Economic Community (EC—now European Union [EU]) mothers (with children under ten) were employed in 1991: “ Highest levels (75% and over) are in Denmark and Portugal. Lowest levels (under 50%) are in Ireland (38%), Luxembourg (42%) and Spain (44%), Greece and Netherlands (46%). In between come Italy and UK (50-59%) and Germany, France and Belgium (60-69%).”5

As a corollary to these trends—and also to the increased awareness of the value of early childhood education—the numbers of children enrolled in preschool programs have escalated. Fully 68 percent of U.S. children 3–5 were in some form of non-parental child care or early education program in 1991.6 As Table 1 illustrates, high rates of participation are also evident in European Union nations.7 In nearly every nation cited, the numbers of children in preschool programs have burgeoned.

Despite surface similarities, however, nations vary greatly in the amount of public responsibility that is assumed for young children. In the United States, responsibility is largely privatized until children reach the age of school entry. When the government does take responsibility for children’s well-being, it is nearly always because parents are thought to have failed in their child-rearing duties. A central tenet of American law is the principle of parens patriae. This doctrine states that the state should intervene only when parents cannot or will not care for their children.8 Demographic changes in the United States have thus been interpreted as signals that increasing numbers of parents are failing their children and that increasing numbers of children are “at risk.”9 Yet not all nations make such assumptions as a matter of course. Many guarantee all families some baseline of support, and the French conceive of public support for preschool education, not as a reluctant handout to those whose parents cannot provide well for them, but rather as a “welcoming” of all children into French society.10

This article has a fourfold intent: (1) to explore some of the ways that governments have responded to issues regarding women’s work and child rearing, (2) to describe modes of inquiry that have been used to make comparisons cross-nationally and to apply these to recent work on child care, (3) to further develop the type defined as “nation as context,” by comparing and contrasting the child care systems of three nations, and (4) to suggest how and why the study of such systems can be useful. Specifically, I use illustrative case studies of three societies—the United States, the former German Democratic Republic, and France—to explore dimensions of concern in the development and maintenance of child-care systems in postindustrial societies. I argue that the cultural inventions of other societies are of interest not simply for their exotic appeal, but rather because they help to clarify policy options within as well as across nations, and to suggest potential constraints and mitigating factors that make it difficult within a given social and historical context to move public policy in a particular direction.



Public policy defines goals and some means of reaching those goals. Given the changes discussed above, nations have devised alternative means of addressing a number of policy issues:

Should it be a matter of government policy to encourage or discourage female employment?

Should government foster gender equity in both work and child rearing?

Should the care and education of young children be the private responsibility of parents or a public societal responsibility?

At what age should the government assume responsibility for the education of children?

A thorough discussion of each of these issues is beyond the scope of this article. The purpose here is merely to illustrate how nations address such questions in very different ways.

Government Support of Female Employment

In Hitler’s Germany women did not have rights separate from those of their husbands, and maternal employment was discouraged. After World War II, Germany was, of course, divided into two nations, the (now former) German Democratic Republic (GDR), which became one of the communist bloc nations of Eastern Europe, and the Federal Republic of Germany (FRG), which remained part of Western Europe.

With a greatly depleted work force in the postwar era, the FRG ( W e s t Germany) imported immigrant labor, and, to this day, professes little public support for maternal employment or public provision for children younger than three.11 Lack of government support for out-of-home care, by default, became support for the “at home” option.12

By contrast, the German Democratic Republic (East Germany) encouraged female employment and gradually established public institutions for young children. In the late 1980s, prior to the unification of the Germanys, 90 percent of GDR women were in the work force or studying,13 and most children age 1–10 were in publicly supported child care institutions for at least some portion of the day.14

Although it is unwise, in some deterministic fashion, to attribute observable differences solely to differences in government policy, it is nonetheless striking that the peoples of two nations sharing a common heritage and language developed very different attitudes toward female employment and extrafamilial child care. One recent study of West German fathers revealed that 80 percent held that “if there’s a child, the father goes to work and the mother stays at home.”15 Conversely, a study comparing gender-role attitudes in East and West Germany found that East Germans were much more likely to believe that “a working mother can establish just as warm and secure a relationship with her children as a mother who does not work.” East Germans also dismissed the notion that “a preschool child is likely to suffer if his or her mother works.”16 In this study, all attitudinal differences regarding gender roles between East and West Germans proved to be highly significant.

Government Support of Gender Equity and Shared Responsibility

The U.S. government has been virtually silent regarding policies that would encourage shared parenting. This is not the case in Sweden, however, where gender equity in child rearing has become a public policy issue.17 In 1991, Sweden guaranteed fifteen months of paid leave to be taken by either parent after the birth of a child, and other Scandinavian countries have established paternity leave.18 Within the European Union, the Childcare Network has stated that “greater involvement by fathers in childcare needs to be encouraged”19 and the network has recommended that EU countries adopt a baseline standard guaranteeing three months nontransferable leave to each parent.20

Private versus Public Responsibility

There is also a substantial amount of variability across nations regarding the degree and kind of responsibility for families and children that will be assumed by government. Of all industrialized nations, the United States and South Africa accept the least public responsibility for young children.21 The United States has virtually no program that supports all the society’s young families.

There is no universal health insurance that guarantees that all pregnant women will receive adequate pre- and postnatal care or that all children will be immunized.22 Parental leave recently (August 1993) became federal law with the enactment of the Family and Medical Leave Act. However, the act applies only to firms with fifty or more employees and therefore does not cover most American workers. There are no child allowances, although recent changes in dependent-care tax credits may develop into something like them.23 And there is little infrastructure currently in place for an early care and education system in which standards are uniform throughout the nation, much less one that provides universal care.24

Despite the fact that government plays an increasingly prominent role in people’s lives, the ideology of private responsibility remains firmly etched in the American consciousness. Child bearing and rearing are perceived to be a parental/family responsibility, and it is primarily parents who finance child care and early education for their children.25 The inability to provide well for children, to afford child care or decent housing or needed health care, has thus signaled individual rather than structural failure. Although recent efforts to increase public responsibility for young children in the United States have shown some success, the ideology of individualism and private responsibility continues to hamper the development of a coherent family policy.26

By contrast, the German Democratic Republic was founded on the belief that the nation’s resources should be shared. Health care was free, and all children were fully immunized. In 1986, a “baby year” was introduced, guaranteeing job security and 70 percent of salary to the mother, father, or grandmother who stayed home with an infant.27 Approximately 80 percent of children 1–3 were in Krippen, while universal provision had been achieved for all children in need of care in Kindergarten and in after-school programs (H o r t e) for school-age children. Krippen and Kindergarten w e r e officially open 13 hours a day, from 6:00 A.M. to 7:00 P.M.28

Public policy supported the idea of collective responsibility for the nation’s children. All adults were to have the opportunity to work, and all forms of discrimination against women were to be systematically eliminated. Women were to be given equal access to education, training, employment, and political involvement. The 1946 “Law on the Democratization of the German School” promised educational equity, while the constitution of 1949 guaranteed women legal equality, the right to work, and the right to equal pay.29 In 1950 the law protecting mother and child became the foundation on which a comprehensive child care system was constructed.30 Despite its instantiation in law, the commitment to ending gender discrimination proved to be more ideological than actual.31 Nonetheless, the child care system was established both to enable women to work (indeed, under socialism, all able-bodied citizens were expected to be gainfully employed) and to foster the development and socialization of the society’s children.32

Age of Entry into the “Public” System

All advanced industrial nations now have a publicly funded system of education. Children typically enter primary school some time between the ages of five and seven (see Table 1). Children in the Netherlands, Luxembourg, and Great Britain enter at age five; in Greece, at five and a half; in Germany, France, Italy, Belgium, Ireland, Portugal, and Spain at age six; and in Denmark, at age seven. With the gradual expansion of kindergartens in the United States, the vast majority of American children enter public schooling at age five.33

Increasing percentages of children 3–6 experience some form of pre-schooling. However, such programs are financed differently in different countries. Programs in France, for example, are free. Consequently, 98 percent of French children 3–5 were in centers in 1989, compared with 31 percent of U.S. children.34


Child care policies and programs tend to emulate features of the social and economic systems in which they arise. Consequently, cross-national studies can provide insight into various ways in which governments influence the contexts in which young children are reared.

In recent years, a number of collected volumes and handbooks have been published that describe early care and education systems. Since little recent work has been done to systematically compare chi ld care approaches, however, a broader framework for cross-national studies can be instructive.35

One author has proposed a typology consisting of four kinds of cross-national research: “Those in which nation is the object of study, those in which nation is the context of study, those in which nation is unit of analysis, and those that are transnational in character.”36 The first type describes nations or the institutions within nations for their own sake. The second is primarily concerned with generalizing about how institutions operate or how social systems influence individual thinking and behavior. As units of analysis, countries are no longer of interest in and of themselves but rather the characteristics of nations, such as gross national products, become variables for comparison. Finally, transnational research considers nations constitutive of larger international systems.

Most recent work on child care has been illustrative of the nation-as object-of-study variety. For example, Olmstead and Weikart profile how fourteen countries address child care and early education, while Melhuish and Moss describes how five nations do so.37 Detailed information is provided, but, with the exception of a brief introductory or summary chapter, there is little effort to understand commonalities and differences among the nations represented. By contrast, the unit-of-analysis approach is exemplified by Tietze and Ufermann and Tietze and Paterak, who summarize variations in preschool provision cross-nationally (see Table 1).38 To date, there have been fewer efforts to study child care using a nation-as-context or nations-as-systems approach.

Nation-as-context studies have been further subdivided into two types: (1) those that examine how social institutions such as child care settings might influence personality at the group level, and (2) those that enable the researcher to make more general statements about how institutions appear to operate in the lives of families and children.39 The book Preschool in Three Cultures is illustrative of the first type.40 In comparing preschools in three societies—China, Japan, and the United States—the authors first give an insider’s view of preschools, based on the descriptions and explanations of parents, teachers, and administrators in each country. Later, in analyzing questionnaire data, they seek instead to understand from the “outside” how pre-schooling affects individuals and families. They note, for example, that the Americans and Chinese surveyed considered it very important for children to learn to express themselves verbally, while the Japanese stressed listening over speaking: “The top Japanese answer to the question, ‘What are the most important things for children to learn in preschool?’ was ‘sympathy, empathy, concern for others.” The subsequent analysis is of the second type and thus compares some of the ways in which institutions function in the lives of families and children.


The governments of postindustrial societies have crafted a number of responses to child care. In the last twenty to thirty years, nations such as Australia, Belgium, and Italy have moved from a welfare model (in which public funds are expended only for the neediest children) to one of near universal provision, yet little work to date has been done to compare these and other types of policies and programs in some systematic way’s41 In what follows, the child care and early education systems of three nations—the United States, the former German Democratic Republic, and France—will be examined. The United States is an example of the welfare model, while the GDR is an example of the universal provision model. France offers free pre-schooling for children 3-6.42

The subsequent analysis depicts program characteristics as existing to a greater or lesser degree along two dimensions. Unlike national-level comparisons in which variables are seen to be discrete characteristics of particular nations or regions, this form of representation captures some degree of consistency within the social organization of different societies, but also allows for change over time. The first dimension deals with overall program organization. Nations can be plotted according to the degree to which they exhibit administrative and fiscal centralization. The second concerns similarity of provision and maps the degree of uniformity that exists within a given system.

In a decentralized system, people are, in theory, able to adapt a program to the immediate situation and to change quickly to meet local needs. Centralized control, by contrast, fosters standardization and coordination. Were the Federal Interagency Day Care Requirements that were rescinded in 1981 still in effect in the United States, all fifty states would have the same standards and follow the same regulatory procedures. While the United States is characterized by administrative decentralization, the GDR child care system was highly centralized.

The second dimension arrays systems according to the degree of uniformity they exhibit. The U.S. system is unusually diverse, supporting a broad range of care arrangements for children under five. The GDR, by comparison, established a far more uniform system, one in which nearly all children of a particular age were provided the same type of care. In what follows, I will briefly compare the child care systems of the United States, the GDR, and France along these dimensions. The discussion is intended to suggest potentially fruitful lines of inquiry—not to exhaust them.


The United States

The U.S. child care system has been described by a number of researchers.43 Thus, for purposes of illustration, only its general contours will be sketched here.

Child care in the United States is supported under diverse auspices and funding streams and thus has been called a “patchwork quilt.” This primarily community-based organizing allows for many types of sponsors, preserves a degree of program autonomy, and avoids the pitfalls inevitably incurred when a bureaucracy is created.44 A pivotal characteristic is the Resource and Referral (R&R) Center. Although not available in all communities, R&Rs, where they exist, provide (1) information and referral, (2) technical assistance and training, and (3) advocacy and community education.45

Centers can be categorized as for-profit, not-for-profit, and government sponsored. For-profit centers are locally owned and operated “Mom and Pop” operations or national franchises, such as KinderCare or La Petite. Notfor-profit centers are run by community institutions such as churches and hospitals, while government-sponsored programs can involve local, state, and/or federal governments. Head Start is a national, federally funded program for (mainly) four-year-old children from low-income families.

Day care programs are generally governed by state departments of social service or human resources, while school-based programs come under the purview of state departments of education. Some states do not regulate part-day or church-based programs, however, and regulations—mandating space requirements, staff-child ratios, and group size—vary greatly from state to state. For example, Maryland and Massachusetts support a staff child ratio of 1:3 for infants; Idaho, by contrast, allows a ratio of 1:12.46 The National Child Care Staffing Study, a study of child care in five urban areas, found that 65 percent of child care teachers and 57 percent of assistant teachers had had some college training.47 However, few had received specialized training at the college level. In general, only limited requirements exist for personnel: “States allow . . . children to be cared for by someone who has not completed high school, and who has very little or no prior in-service training in child development or early childhood education.”48 The Child Care Staffing Study, moreover, found the average wage of child care workers to be $5.35 an hour—producing a yearly salary below the poverty line.49 Given the low wages, many family day care home providers exist outside the system and do not acknowledge their wages as taxable income.

It has been argued that the value that local control affords is offset, to some degree, by the lack of coordination of services and by wide disparities in standards. Moreover, since authority is so widely dispersed, child care in the United States lacks an overall guiding vision, and national-level data that might support alternative policies and programs have not been readily available.50 Frequent complaints of the U.S. approach include such factors as variations in standards, the lack of uniform quality-control measures, insufficient training and technical assistance, low wages, and high rates of teacher turnover.

The German Democratic Republic

The child care system that evolved in the former GDR has also been summarized by a number of researchers.51 Where American child care is primarily organized at the community level and regulated by individual states, the GDR system was organized at the federal level. Policies were the result of a centrally planned effort to equalize children’s access to health, education, and care.

In rather stark contrast to developments in the United States, the administrative and regulatory system that evolved in the former German Democratic Republic was governed at the federal level, with all planning and decision making being made at the top and then passed down through a bureaucratic structure to programs at the bottom. Because the system was centrally planned, it achieved a degree of homogeneity that would be unthinkable in the United States.

The Krippen, the child care institutions for children 1–3, were governed by the Ministry of Health (Ministerium für Gesundheitswesen). The Kindergarten for children 3–6 and the Horte for school-age children were administered by the Ministry of Education (Ministerium für Volksbildung). Nonetheless, the system was not entirely uniform. Eighty-nine percent of Krippen were state-sponsored; the remaining 11 percent were sponsored by factories.52 Kindergarten had three types of sponsorship: state-run programs, company-run centers and cooperatives, and church-run centers. Since both state-run and company-run centers were state-supported, however, this distinction is of no great consequence. Eighty-six percent of the kindergartens were state-run, 11 percent were run by companies, and 3 percent were sponsored by churches.53

Staff-child ratios and group size were set by the state. In 1990, there was a ratio of 1:5 in the Krippen and 1:10 in the Kindergarten. The same amount of money was allocated for each child in each type of institution, and all programs, except those sponsored by churches, were required to use the same curriculum. Finally, fully three-fourths of all nursery teachers had received three years of training in a “medical technical school” (medizinis-che Fachschule) and two-thirds of the kindergarten teachers were fully trained in an “educational technical college” (pädagogische Fachschule).54 Thus, a high degree of uniformity characterized the system.

Due to strong centralized control, programs both looked very similar, and they were described by directors in remarkably similar terms.55 The general feeling was that the child care institutions were a valuable societal resource. Nonetheless, directors also tended to identify similar problems. Repeated complaints included unnecessary paperwork, unduly strict measures of accountability, lack of local decision-making power, limited resources, fluctuations in group size and staff-child ratios, long hours, low pay, and, what was often perceived as the consequence, high rates of teacher turnover.56 Despite a relatively high level of education, child care workers on average made less than laborers.57


French child care has been described as a system from which the United States can learn a good deal, and it has become a frequent topic in both popular and scholarly writing in English.58 Despite the fact that France has been going through a period of decentralization, the French child care system, and, indeed, French society in general, is far more centralized than is the case in the United States. Whether because of or in spite of this fact, the French have been able to create clear funding streams within their child care system, so that different levels of government are responsible for different facets of it. This administrative structure appears to allow both for local control and federal-level coordination.

National agencies are responsible for policy. Programs for children under three are administered by the Ministry of Social Affairs; the nursery schools (écoles maternelles) for children 3–6 are governed by the Ministry of National Education (Ministere de l’Education Nationale). The Ministry of Education has established the preschool curriculum that is used throughout the country. The National Family Allowance Office or CNAF, a wing of the social security system, sets policy for the provision of day care services for children younger than three. Regional offices or CAFs execute national policy but also adapt it to local needs and circumstances. Increasingly, CAFs work in concert with local authorities to finance the expansion and maintenance of day care services.59 It is local authorities (municipalités) that are responsible for all programs (crèches) for infants and toddlers, lunch and vacation programs for preschoolers, and before-and after-school programs. Thus, national-level policies ensure that standards are set for all types of care, but the administrative structure maintains clear lines of responsibility. Municipal authorities manage child care locally, and federal authorities operate only in conjunction with them.

The French system is organized to encourage compliance through incentives rather than mandates. For example, government incentives are provided to municipalities in the form of capital and operating subsidies when they expand and fulfill “quality enhancement” contracts for infant care. Family day care home providers become eligible for social security insurance, including retirement and disability benefits, unemployment insurance, and maternity leave once they become licensed. In addition, a minimum wage is set by law (although the provider can negotiate with parents for higher wages), and paid sick leave and vacation leave are included. Providers are visited by pediatric nurses and receive information by mail.60

Approximately one-fourth of all home providers are linked through family day care networks (crèches familiales). At the core of each network is a hub staff that performs administrative tasks, provides training for providers and activities for children (one half-day per week), and lends equipment. Municipal officials collect fees for these providers and handle payroll, so that providers themselves are relieved of these responsibilities. Seemingly in response to these incentives, a majority of family day care home providers in France are licensed.61

Another way in which the French government has fostered system stability through incentives is through their teacher training program. Free education and stipends are provided to students planning to be preschool teachers; in return, students agree to teach for five years in the field after graduation. The result is that all preschool directors and teachers have the equivalent of a master’s degree in early childhood education. Directors in infant-toddler programs are pediatric nurses, while infant-toddler teachers have what is equivalent to an associate’s degree plus two years of training in early childhood education and child development.62 Although teachers are responsible for an average of 22 children, they are more highly trained than those in the United States and, in each center, other adults serve in supportive roles.63

Preschool teachers make the same salaries as primary school teachers, and teacher turnover is quite low. Teachers work with aides who relieve them midday so that they have two hours off for lunch and preparation. Far more than either the U.S. or the GDR system, the French have addressed what is perhaps the central problem in day care today: low wages, poor working conditions, and resultant high rates of teacher turnover.

Although this type of program organization allows for both local control and some degree of standardization and mitigates the most deleterious effects of a highly centralized or highly decentralized system, it has not escaped criticism. Local authorities can decide whether or not to invest in child care, and to date urban areas have much more publicly financed care available than do rural areas. Moreover, the system appears to be more coordinated in theory than in practice. Leprince has noted “the frequent absence of consultation between the parties involved in policy on day care provision: CAFs, Conseils Généraux and local authorities are not always well co-coordinated, nor is consultation always smooth between the Ministeries of Education and Social Affairs.”64


The United States

Child care in the United States is also characterized by its diversity. Preschool-age children are cared for by relatives, in-home babysitters, and family day care home providers, or they attend preschools, centers, or schools.65 Typically parents have opted to place children under the age of three in homes, while a larger proportion of three- and four-year-olds are in group-based arrangements. Since the early 1980s, however, the demand for infant and toddler center care has been escalating.66 Federally funded Head Start and state-funded pre-kindergarten programs also exist for children from low-income families; others receive subsidies to attend a child care program in the community. These programs, however, fail to fund all the children who qualify.

The United States continues to maintain what is frequently referred to as a “two-tier” system of child care.67 It is primarily parents who finance child care, and most parents, in theory, select the type of care they prefer. There is a wide range of choice—at least for those who can afford it. But differential resources create huge disparities in the availability and quality of programs. Public programs are means-tested, so that children are identified as low-income and therefore segregated by class—and frequently by race. This private/public split—a tradition of “private wealth and public squalor”—has historically characterized programs for American children.68

In the United States, the principal government subsidy for child care is the Child Care Tax Credit—a method, in political parlance, of maintaining “choice.” However, this method of subsidization does little to foster common standards or coordinated programming. The very diversity of arrangements, funding mechanisms, and regulatory practices contributes to the inequity that structures programs to the core. Problems of availability, affordability, and quality thus appear to be endemic to the U.S. approach.

The German Democratic Republic

In the late 1980s, nearly all GDR parents sent their children to public child care institutions. Public policy favored the development of the same type of care for all same-age children. Approximately 80 percent of children 1–3 were in the Krippen, 94 percent of children 3–6 were in Kindergarten, and 82 percent of children 6–10 were in after-school programs called Horte. The Kindergarten and after-school enrollments represent full provision.

Where U.S. programs, since their inception, have been class-based, GDR programs were intended to have a leveling effect. Funding for the child care institutions in the former German Democratic Republic came primarily from public coffers, with parents contributing only a nominal amount for food. Health care also was free, and all children were fully immunized. Health records (Ausweise), listing the immunization record and illnesses, were maintained in the child care institutions. A pediatrician visited regularly, gave checkups, and advised the staff on nutrition. Medicine, when needed, would be delivered to the center free of charge. In theory, the GDR solved many of the problems that most plague the U.S. approach. Standards were uniform, most teachers were well trained, and nearly all children had the same curriculum, with teachers throughout the country expected to achieve the same goals for their children at each developmental level. As described above, however, the system also proved to be unduly inflexible, and, just as in the United States, the low wages of the teachers contributed to system instability.


Over the last 100 years, France has moved from a two-tier system to one that guarantees quality care to all its preschool-age children. Virtually all French children 3–6 (and one-third of two-year-olds—those 2 1/2 and older) attend the acclaimed écoles maternelles or private schools that receive public subsidies.69 Fewer (approximately 30 percent) currently receive public funds as infants and toddlers.

As crafted in U.S. legislation, parental leave is of benefit to few parents, since it is both unpaid and targeted only at employees of large firms. By contrast, the GDR provided one year of leave at 70 percent of salary to the mother, father, or grandmother who stayed home with an infant. French leave provision lies somewhere between these extremes. Maternity leave (congé de maternité) includes six weeks of paid leave pre-parturition and ten weeks post for the first two children. For mothers with more than two children, leave time is extended to eight weeks before and eighteen after. Mothers receive 90 percent of their salaries, while fathers are granted four days paternity leave. Supplemental funds are frequently used to bring wages up to full replacement and/or to extend leave.70 Parental leave (conge parental) enables a mother or father to request full- or half-time leave with job guarantee for two years after the maternity leave period.71 Parents with three or more children are eligible for a minimal monthly payment during this time.72 Parents who adopt receive ten weeks paid leave.72

As described above, U.S. preschool-age children are cared for in many different types of arrangements. GDR children, on the other hand, were overwhelmingly cared for in public institutions. Once again, the French answer lies somewhere in between. While virtually all children 3–6 attend the free écoles maternelles (about 90 percent) and publicly subsidized private schools (8 percent), parents of infants and toddlers ostensibly have a range of choices.

Public funds support the education of all French preschool-age children, whether or not their parents work. Public monies for infants and toddler care, on the other hand, are marked for the children of working parents. Children can be cared for in homes connected to family day care networks (crèches familiales), a sort of organized family day care home scheme, by independent but licensed family day care providers (assistantes maternelles) or in full-day nurseries (creches collectives), mini-crèches, or crèches parentales. A majority of the full-day nurseries serve fifty or more children, while the smaller nurseries have sixteen children or fewer. Parent-run nurseries typically hire one or more permanent employees, but parents, who work one-half to one day per week, also staff the centers. Part-time nurseries (halte garderies) , which were established so that nonemployed mothers could have some time off, currently tend to serve mothers who work on a part-time basis.73

Although there appears to be a broad range of “choice” for children under three, there are far fewer public funds available for children in this age group. The 1989 report by the French-American Foundation found 21 percent of infants and toddlers to be in centers, 9 percent in family day care homes, and 70 percent in parent, relative, or at-home care.74 Locale appears to determine access to public funds more than does need, although some places are reserved for children with special needs. Families in some areas have more choices available to them than do others.

As currently structured, the French system also has other drawbacks. The ècoles maternelles run from 8:30 to 4:30 each day, and only some local authorities offer after-school care. Schools throughout France do not have meals at lunchtime or classes on Wednesdays, and they make only limited provision on school holidays. As in the United States, working parents must fend for themselves during these times.75 Despite its flaws, however, the French approach is premised on the belief that “society owes good care and education to all children,”76 and family supports generally are among the most generous and extensive of any nation on earth.77


Virtually all nations are confronting issues related to maternal employment and child care. This article has used case studies of the child care systems of three postindustrial societies to suggest how the institutions that arise within nations might be systematically compared across nations. Two dimensions—one marking the degree of administrative and fiscal centralization, the other the degree of uniformity—were developed to illustrate the type “nation as context.” Such research is concerned with making general statements about how institutions function and about how social structure can be expected to affect individuals in somewhat predictable ways.

In Figure 1, the dimensions marking degrees of centralization and of uniformity are shown as intersecting. Through this visual display, nations that support these two organizational forms to a greater or lesser degree can be “located” in two-dimensional space. In the examples discussed above, the United States can be seen to foster a flexible (decentralized) form of program organization and diverse types of care. By contrast, the GDR is shown to have supported a standardized and highly coordinated (centralized) system and relatively uniform programs for same-age children. France is organized so that some aspects of the system are centralized, while others are under local control. Similarly, programs for preschool-age children (2 1/2–6) are relatively uniform, while there is greater diversity (and less public support) for infant-toddler programs. Thus, in the figure, France occupies a middle-of-the-road position in regard to these two continua.


The model casts in relief broad differences between and among nations and thus highlights how the history and political traditions of each nation, as well as the current climate for reform, serve to position systems in particular ways. Child care systems do not exist independent of the political and economic systems in which they are embedded, and yet each can be seen to have “moved” and to be “moving” over time.

At least three factors appear crucial to the development of supports for female employment generally and child care specifically: the strength of progressive political parties, the relative homogeneity of the population, and the perceived importance of children to a nation’s welfare. Nations that have moved from a welfare model to one of universal or near-universal provision appear to be characterized by a political structure in which one party assumes dominance for some period of time and thus can establish and enact a relatively coherent policy agenda. France and other nations of Western Europe have witnessed the importance of the Left and the power of unions to expand the welfare state from family policies that are limited and means-tested to those that provide universal or near universal coverage. This was the case also in Australia, where the Labor Party, once in power and able to act with relative autonomy, began to establish a universal child care system based on a sliding fee scale.78 Ten years later, when the conservatives regained power, the system was too firmly entrenched to be dismantled.

The countries of Western Europe with the most extensive social welfare systems are countries that traditionally have had relatively homogeneous populations. Public policies, in this context, become a way of taking care of one’s own and ensuring support across the life span. Finally, in much of Europe, child care, maternity leave, and child allowances were, at least in part, initiatives that complemented relatively longstanding pronatalist and nationalist policies aimed at encouraging women to bear children. The devastation and loss of population resulting from wars fought on European soil made child bearing and rearing crucial to the future of these nations.

By extension, efforts to forge a national consensus around child care in the United States have been thwarted, at least in part, because none of these conditions hold. The two-party system in the United States virtually ensures that federal-state tensions will continue to exacerbate efforts to formulate policies that apply nationally. The political maneuvering that took place around the Act for Better Child Care (ABC) bill is a case in point. While some Democrats fought to establish national standards, some Republicans refused to support the bill if national standards were included. The final bill reflects the compromises that were necessary. Federal funds were allocated to states within broad areas that allowed for statelevel decision making. The legislation authorized $2.5 billion (over three years) in block grants to states to subsidize care and to improve and expand the supply of care, both for preschool- and school-age children. It authorized $1.5 billion (over five years) for child care for low-income working families. It provided $50 million to states to improve standards, train providers, and monitor compliance. Finally, it expanded the Earned Income Tax Credit and established a refundable tax credit for low-income families. Although the ABC bill was the first major child care legislation to be enacted in more than twenty years, the allocation fell far short of the need, and little was done to address the central dilemmas of system coordination and equality of provision. Since the “new federalism” of the Bush and Reagan administrations, moreover, many federal-level programs have reverted to state control. Recent state-level initiatives aimed at developing coordinated professional development systems and new governance structures appear intuitively to grasp this fact.79 These efforts begin where coordination is possible within the American system.

The United States has also been far more ethnically and racially diverse than the social welfare states of Europe, with “minorities” disproportionately represented among the poor. Fully half of all African-American children, and nearly 40 percent of Latino children, are in families that live below the poverty line.80 This has led to an “us-them” mentality about welfare in general, a stance that undergirds the public/private split in the United States. As Arlene Skolnick has commented: “In Europe, family policy means everyone. . . . In America, it’s for ‘them.’”81 Finally, neither of the world wars was fought on American soil, so there has not been the same spur that existed in Europe to maintain and renew the population. The ideology of individualism and private responsibility encourages people to be responsible for their own children—and to have less concern for those of others.82 Child care in the United States, like much of the economy in which it is embedded, is dominated by the market. Parents are expected to purchase the kind of care they find to be most desirable, and the market is expected to generate the supply of care that is needed in response to the demand.83 The result has been a profusion of care arrangements, arrangements that differ in both cost and quality.

Public policies effectively create different contexts for family life in each of the societies discussed above. The former German Democratic Republic was by no means a perfect society, and yet, within the forty years of its existence, it succeeded in developing the most extensive system of publicly supported child care that has ever been attempted. A parent or grandparent could stay home with an infant for a year and receive 70 percent of salary with job guarantee. Pre- and postnatal care was free, and child care, as well as health care, was considered a basic social right. In this context, fully 90 percent of mothers were either employed or in school.84 In somewhat similar fashion, France guarantees sixteen weeks of paid leave at 70 percent of salary, pays most maternity costs through the national insurance scheme, subsidizes day care for approximately 30 percent of infants and toddlers, and provides universal free preschool for children 3–6. Parents also receive child allowances, which help put a floor of support under all families with children. In 1991, 59 percent of French mothers with children under the age of ten were employed.85

In the late twentieth century, these contrast cases illustrate how U.S. government policies—and the lack thereof—remain relatively inimical to family life. Parental leave is unpaid and guaranteed to only about 10 percent of U.S. workers. Health care is not universal, and fully 37 million Americans have no health insurance. Child care is subsidized through a nominal tax rebate, a form of subsidization that supports neither system coordination nor universal provision. And public monies are expended for child care and early education only when parents cannot provide for their children. The halting efforts that have been made to accommodate working parents do relatively little to sustain optimal child bearing and rearing within the United States. By continuing to support at-home child rearing by default, the U.S. ethic remains markedly out of sync with contemporary realities.86 In this context, families without substantial resources are at a significant disadvantage.87

In comparing the child care systems of three nations, this article has underscored several points. First, nations differ in their support of female employment and extrafamilial child rearing. Second, policies that encourage female employment and out-of-home care are social constructions that can and do change over time. Third, although the social and political conditions that gave rise to extensive entitlements in both the GDR and France did not exist in the United States, changing patterns of labor-force participation and family formation may create conditions for change in the future. Finally, although efforts to formulate family-support policies within the United States must be cognizant of the present ways in which child care and early education are organized, as well as of the historical circumstances that gave rise to them, cross-national comparison can suggest directions for change and alternative organizational configurations. For these reasons, systematic study of the policies and programs of other nations can be useful.

An earlier version of this paper was presented at the annual meeting of the American Educational Research Association, April 1994, New Orleans. Funding from the Spencer Foundation’s Small Grants Programmed is gratefully acknowledged.

Cite This Article as: Teachers College Record Volume 96 Number 3, 1995, p. 467-491
https://www.tcrecord.org ID Number: 23, Date Accessed: 12/2/2021 1:47:44 PM

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