Introduction: Bridging the transatlantic divide in social policy research

Abstract

This introduction to the Special Issue explores the historical and contemporary relationship between European and North American social policy research and development, tracing the evolution of policy influence and scholarly exchanges across the Atlantic. It highlights early mutual policy learning between Europe and North America, with particular attention to the impact of key reforms like the New Deal. Furthermore, it points to the gradual emergence of a transatlantic divide, particularly in the U.S. due to notions of “American exceptionalism”. The aim of this Special Issue is to revive transatlantic comparative research, exploring themes such as poverty reduction, the impact of ethnic diversity on social policy, and the implications of non-standard work.

Introduction

Social policy development has long connected Europe and North America ¹ , a situation that can be traced back to the emergence of the first modern social programs in the late 19th century and early 20th century (Rodgers, 2000). Yet in recent decades, a transatlantic divide in social policy research has emerged due to a series of factors that we discuss in this Introduction to our special issue on comparative social policy in European and North America.

The first main section of this article explores the evolution of social policy influence between Europe and North America. The second section focuses on the organization of social policy research on both sides of the Atlantic. The third section outlines key findings of existing social policy research that compares Europe and North America, a discussion that leads to a brief overview of the thematic issue and the research articles comprising it.

Policy influence: From Atlantic crossings to the transatlantic divide

Europeans have long turned to North America for political and policy lessons, and vice versa. On the European side, Alexis de Tocqueville’s Democracy in America is an early example of how Europeans started to understand themselves in the mirror of the “New World” (Tocqueville, 2000). On the North American side, it seemed opportune to look at Europe for political and policy lessons, as both Canada and the United States are former European (British and French) colonies. In the field of social policy, “Atlantic crossings” (Rodgers, 2000) allowed North American reformers to draw lessons from new social insurance programs created in late 19th and early 20th century European countries such as Germany and the United Kingdom. This lesson-drawing movement was well in evidence in the creation in 1906 of the American Association of Labor Legislation, which aimed at spreading the logic of social insurance -- born in Europe -- across the United States (Moss, 1995).

Although efforts to import social insurance to the United States failed during the Progressive Era (1901-1929) (Skocpol, 1992), the Great Depression and, especially, the advent of the New Deal under President Franklin Delano Roosevelt allowed social insurance to become a key aspect of federal social policy in the United States (Skocpol, 1995). As for Canada, it finally implemented its first federal social insurance program in 1941, once negotiations with the provinces made this reform possible in the first place, as the first social insurance legislation had been invalidated by the courts in 1937 (Banting, 2005).

With the New Deal, the U.S. began to appear on the radar screen of reformers all over the world, including in Europe (Patel, 2016). This was for example the case in the United Kingdom, where the New Deal directly influenced the ideas of British reformers, including William Beveridge (1942, 1944), the author of two globally influential reports published during World War II (Pear, 1962). In turn, these reports influenced social policy debates in both the United States and Canada, two close allies of the United Kingdom in which Beveridge’s proposals resonated (Béland, Marchildon, Mioni and Petersen, 2022; Brinkley, 1995). Franklin Delano Roosevelt and Winston Churchill included the principles of “improved social security” and “the freedom from fear and want” in the Atlantic Charter of 1941, designed to guide the post-WWII order (Kaufmann, 2003).

Immediately after the war, interactions in social policy advice and lesson drawing between Europe and North America continued but a transatlantic divide started to emerge. This is particularly the case in the United States, where the rise of the Civil Rights Movement in the mid-late 1950s and the advent of Medicaid and Medicare in the mid-1960s created a sense that the United States faced unique circumstances and policy developments that required home-made policy and political solutions (Berkowitz, 1996). This situation reinforced the idea of “American Exceptionalism” in social policy, which has long been a central aspect of U.S. scholarship on the topic (Béland and Hacker, 2004). As for Canada, it became less and less influenced by the United Kingdom over time, as the U.S. influence increased, a situation that created a backlash in academia leading to the emergence of a “Canadianization Movement” in the 1970s aimed at protecting Canada from excessive U.S. ideological influence (Cormier, 2004). Simultaneously, Canadians increasingly referred to the existence of universal health coverage as a defined aspect of their identity compared to the United States, a country that has created a uniquely fragmented and unequal health care system over time (Maioni, 1998; Street, 2008).

These remarks should not hide the fact that transnational and transatlantic lesson drawing remains a reality across and between Europe and North America. For instance, the 1996 U.S. welfare reform has impacted policy debates in Europe with regards to activation and workfare, especially the United Kingdom. Conversely, a discussion of the British and Swedish pension experiments has taken place in the United States in the context of the debate on Social Security privatization (Béland and Waddan, 2000; Norberg, 2023).

Organizing social policy research across the Atlantic

Beyond the sphere of policy advice, in the realm of academic research, comparisons between Europe, especially Western Europe, and North America, chiefly the United States, have long contributed to the international scholarship on welfare state development and restructuring. Before taking a quick look at some examples of transatlantic social policy research, it is crucial to examine how its production has been structured over time. Although global platforms such as the Council of European Studies (CES) and the Research Committee 19 on Poverty, Social Welfare and Social Policy of the International Sociological Association (RC19) have long provided academic spaces for North American and European scholars to meet and discuss their findings in comparative welfare state research, their existence cannot hide the impact of Europeanization on social policy research. European integration not only progressed at the political level but also significantly strengthened comparative European research on social policy and welfare state developments. A hallmark of this integration was the establishment of the Journal of European Social Policy in 1991, which has since become the leading academic journal in the field.

A decade later, in 2002, European scholars founded the European Network for Social Policy Analysis (ESPAnet). This network was designed to facilitate exchange and cooperation among social policy analysts in Europe and to provide a forum for the development of European social policy analysis as a field of research and teaching. Its work focuses on advancing knowledge in the analysis of European social policies, promoting a comparative approach to social policy analysis in Europe, and encouraging an interdisciplinary and multidisciplinary approach to social policy research.

Meanwhile, within North America, social policy research remains balkanized among traditional academic disciplines like economics, sociology, political science, and social work, leaving limited spaces for domestic interdisciplinary debates. This is especially the case in the United States, which does not even have a prominent social policy journal that would be the equivalent of the several European journals that have dominated the field for decades. ² This fragmentation of social policy research in North America means that scholars from different disciplines who work on social policy may never actually meet, in the context of large countries in which social policy is not an integrated scholarly field. Although less dramatic in Canada, which has a smaller academic system and social policy scholars typically keener to participate in international scholarly forums (alongside U.S. scholars who conduct comparative research), this lack of cohesion in North American social policy research is detrimental to structured transatlantic scholarly exchanges in the field.

Social policy research comparing Europe and North America

If we look at existing theories of welfare state development such as industrialism, power resources theory, and historical institutionalism, it is clear that their formulation featured at least some direct comparison between European countries and the United States, even if the focus of that research is not necessarily transatlantic in nature (e.g., Huber and Stephens, 2001, 2024; Lynch, 2006; Orloff, 1993a). This is also the case of the scholarship on welfare regimes, in which the United Stares is the archetypical “liberal” country (Esping-Andersen, 1990, 1999). Although perhaps less archetypically “liberal,” Canada is also understood as a liberal welfare regime, at least in areas such as pension and unemployment benefits (Myles, 1998). Like the broader scholarship on welfare state regimes, feminist research on gender and social policy has a strong transatlantic component that led to the creation of the journal Social Politics in 1994 and the publication of a large body of research that bridges the continental divide (for an overview of this literature see Orloff, 2009). Finally, Paul Pierson’s influential work on the politics of retrenchment came out of a comparison between the United Kingdom and the United States, which witnessed clear ideological convergence yet distinct policy outcomes during the Thatcher and Reagan years (Pierson, 1994). Yet, the focus of this research is not about systematically comparing Europe and North America. Moreover, U.S. poverty research has lacked comparative perspectives, largely focusing on behavior and demographics, whilst ignoring the politics (cf. Brady, 2019).

In fact, overall, comparative transatlantic research on welfare state development and restructuring has been somewhat limited. Not only in political discourse are the United States of America regularly portrait as the (neo-) liberal antipode to the European Social Model that is said to dominate policies in European countries; very often the welfare arrangements of North America, especially the United States, are considered as residual, liberal and being dominated by means-tested public and private provision (but see the critical assessment by Alber, 2010; Alber and Gilbert, 2009). The lack of a politically relevant socialist or social-democratic party had already been identified by the European sociologist Werner Sombart ([1905] 1976; cf. Lipset/Marks, 2000) at the beginning of the 20th century as a key factor explaining “American Exceptionalism” (Lipset, 1996). According to the power resources theory – with its emphasis on the strength of organized labour and social democracy (Huber and Stephens, 2001, 2024; Korpi, 1983; Stephens, 1979) – and the importance of Christian democracy (Van Kersbergen, 1995), it is not surprising that the United States has historically developed a less comprehensive and qualitatively different welfare state than Scandinavian and northern continental European countries. Organized Christian democracy and social democracy had no substantive role in the development of the U.S. welfare state (Lipset/Marks, 2000). Moreover, Americanization, liberalization or a convergence to the liberal model, for which the United States is often understood to be archetypical (Esping-Andersen, 1990; Ferragina/Seeleib-Kaiser, 2011), have been identified as trends observable in a number of European welfare states (Seeleib-Kaiser, 2013; Walker, 1999). Alesina and Glaeser (2004) highlight as the main contributing factor of the institutional design of the US welfare state's ethnic heterogeneity – which with increasing ethnic diversity, so it could be argued, would lead to less generous welfare states for the ‘least deserving’ in Europe.

Yet, as highlighted by Alber (2006, 2010) some of the characterizations of the liberal US welfare state do not square well with the empirical reality that is dominated by public provision with social insurance systems at its core; the US federal pension system known as Social Security is a more universal, redistributive, and generous scheme than the public pension systems in a number of European countries. US public expenditure for healthcare per capita in purchasing power parities is highest among the OECD countries (OECD, 2023: 156). Based on outcomes, the United States in a number of dimensions achieves outcomes that are very similar to or within the divergence found in the European Union (Baldwin, 2009); this is especially the case in health care, which, however, is primarily privately provided and funded in the US (OECD, 2023: 125 ff.).

Irrespective of these observations, two core differences between European countries and the US remain: the lack of universal healthcare coverage (Einav and Finkelstein, 2023) and of the social right to minimum income protection for able-bodied needy people ³ (Seeleib-Kaiser, 2013). In combination with high rates of incarceration this lack of social protection has significantly deepened inequality in the United States (Western/Becket, 1999) and contributed to the depth of poverty (Brady, 2009). In addition to these macro comparisons, a number of transatlantic comparative welfare state studies have focused on specific social policy programs and outcomes, highlighting differences and commonalities (cf. Gangl, 2004; Janoski, 1990; King, 1995; Mahon et al., 2012; Misra et al., 2007; Orloff, 1993b). Finally, as far as Canada is concerned, although the country remains classified as a liberal welfare regime, in some policy areas at least, the province of Quebec is much closer to the social-democratic regime, a situation that draws attention to the scope of internal territorial variation within highly decentralized federal countries (Daigneault et al., 2021; van den Berg et al., 2017). Also, Canada is clearly distinct from the United States in the area of health care as universal coverage across the country was achieved by the early 1970s (Maioni, 1998).

With our Special Issue, we aim to build on the mid-range approach in comparative research and address issues highlighted by modern classics, such as Sombart’s work on the relevance of Social Democracy (Sombart, 1976). Machtei, Huber, and Stephens re-analyse the Meltzer-Richard model, demonstrating that partisan governments, rather than the median voter, are directly related to redistribution and significantly influence the generosity of social policy. This ties into the long-standing academic discourse on the role of Social and Christian Democracy in explaining the divergent trajectories of North American and European welfare states. Harell and Larsen explore the impact of ethnic diversity on perceptions of deservingness in heterogeneous societies. They find that the negative portrayal of large Muslim minorities in Western Europe challenges highly re-distributive schemes like social assistance, paving the way for unforeseen political innovations that differ from the American “master narrative.”

Filauro and Parolin highlight the effectiveness of political interventions for the poor during emergencies, such as the COVID-19 pandemic. They note that the United States saw the largest post-tax/transfer declines in poverty rates from 2019 to 2020, suggesting a marked improvement in poverty reduction and emphasizing the importance of policies focused on income support.

Anderson and Weaver examine the politics of old-age poverty in an era of austerity, arguing that politics and institutions interact to shape policy continuity and change in response to shifting old-age poverty risks. They assert that effective policy responses require continuous updates to existing policy parameters as these risks evolve.

Gingrich, drawing on recent literature in American political economy, investigates regional inequality trends within Canada, Europe, and the United States. She argues that understanding geographic inequality in North America and Europe necessitates analysing both broad national institutions and specific local institutions that influence the concentration of populations in particular areas.

Conclusion

With this Special Issue we aim to reinvigorate the transatlantic comparative research on social policy in Europe and North America. Standing on the shoulders of giants the contributions in this issue also highlight the diversity and nuances as well as the commonalities and differences in social policy developments on both sides of the Atlantic. Current geopolitical constellations and domestic developments, such as the rise of the populist right (Rathgeb, 2024), once again lead us to search for new approaches on both sides of the Atlantic. Simultaneously, this Special Issue could also be understood as an attempt to stimulate comparative social policy across different continents and regions of the world, as reviving the transatlantic research traditional is a point in the direction of breaking away from what we could call “methodological continentalism,” which like “methodological nationalism” is problematic in a global context in which countries and scholars from all over the world can learn from policy experiments taking place all over the globe. From this perspective, the transatlantic research tradition points to the added value of transcontinental social policy research in general, within and across both the Global North and the Global South.