European coordination of social security is one of the older achievements of the single market: a person who moves between member states does not lose their healthcare rights. Long-term care sits mostly outside that framework, and the difference surprises almost everyone who encounters it.
What actually coordinates and what does not
Sickness benefits coordinate. If you need medical treatment in another member state, mechanisms exist to cover it.
Long-term care is a different category. Whether it counts as a sickness benefit in cash, a social assistance benefit, or something else varies by country and by benefit, and the classification determines whether it travels at all. Benefits classed as social assistance generally do not: they are tied to residence, and they stop when residence changes.
The practical consequence is that a person who has contributed for decades in one country and moves to another usually re-enters the system as a new applicant under the destination country's rules, with the destination country's assessment and waiting periods.
Three systems, three incompatible scales
Even where a person stays put, families searching across borders hit a second wall: the assessments do not translate.
- Germany classifies into five Pflegegrade, assessed by the Medical Service on the basis of remaining independence.
- France uses the GIR scale, from 1 to 6, which drives the dependency component of the fee and the APA allowance.
- Spain grades dependency from I to III under the Ley de Dependencia, with regional administration on top.
- Italy works through regional multidisciplinary assessment with no single national scale.
These measure related things in incompatible ways. There is no conversion table, and building one would be misleading, because each scale is tied to the benefits it unlocks in its own system.
Who this actually affects
Two groups, both larger than the policy discussion suggests.
The first is people who worked abroad and return home to age. They often assume entitlements accumulated during their working life follow them, and discover otherwise at the point of need.
The second is adult children who emigrated while their parents stayed. They are searching from another country, in a system they left before they ever needed to understand it, usually in a hurry and often in a second language.
What can realistically be done
Not harmonisation. Long-term care is where national welfare traditions differ most, and there is no appetite to unify it.
What can be done is narrower: making each national system legible from the outside. What the local levels of dependency actually mean, who pays which share once public funding applies, what the real cost to a family is, and what does and does not transfer when someone moves.
That is unglamorous, slow work, and it is precisely the part families cannot do for themselves under time pressure.
Where we are
Kindrya works market by market, starting in Italy, because the rules that matter are national and regional. The cross-border layer is where we work on what those systems do not share.
Get in touch if this is your problem too.