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. Families assume long-term care works the same way. It half does — and the half that fails is the one that matters when a parent needs a bed.
What the rules actually say
Long-term care is not one of the branches listed in Article 3 of Regulation 883/2004. It has no chapter of its own. What happened instead is that the Court of Justice folded it into the sickness chapter: in Molenaar (C-160/96, 1998) the Court held that the cash benefits of the German care insurance were to be treated as sickness benefits in cash, which means they cannot be withdrawn merely because the recipient has moved to another member state. Regulation 883/2004 later added a definition of long-term care benefits in kind at Article 1(va), again inside the sickness chapter.
So the common summary — that long-term care simply falls outside coordination — is wrong, and we have corrected it here. Two things are true at once, and the distinction is the whole subject:
- Cash can travel. A benefit classified as a sickness benefit in cash is in principle exportable.
- Care in kind does not. Benefits in kind are provided by the institution of the place of residence, under that country's legislation, its assessment and its rates.
A place in a residential facility is a benefit in kind. That is why an Italian entitlement does not buy a bed in Valencia, and a Spanish grado III does not buy one in Bologna. The family is not being obstructed by anyone; they have crossed from one system into another, and the second one starts its own assessment from zero.
There is a third category that does not travel at all. Article 3(5) excludes social assistance from the regulation entirely — and in several countries the part that makes a placement affordable, such as the municipal top-up of the fee in Italy, sits precisely there.
The Commission proposed in December 2016 (COM(2016) 815) to give long-term care an explicit definition and chapter of its own. Anyone relying on that should check where the file currently stands rather than this article.
Four systems, four incompatible scales
Even for a family that has accepted it must deal with the destination system, a second wall follows: the assessments do not translate.
- Germany classifies into five Pflegegrade, determined under § 15 SGB XI on a points scale measuring remaining independence, on the basis of an assessment commissioned from the Medical Service (§ 18 SGB XI).
- France uses the GIR scale, from 1 to 6, produced by the AGGIR grid published as annexe 2-1 of the Code de l'action sociale et des familles. Only GIR 1 to 4 open access to the APA allowance.
- Spain grades dependency I to III under Ley 39/2006, scored by the baremo of Real Decreto 174/2011, and administered by the autonomous communities.
- Italy has no equivalent national scale. Access runs through regional multidisciplinary assessment, and the framework that defines what the health service owes is the DPCM of 12 January 2017.
These measure related things in incompatible ways. There is no conversion table, and building one would be misleading, because each scale exists to unlock the benefits of its own system and means nothing outside it.
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 that entitlements accumulated during their working life follow them, and discover at the point of need that the pension does and the care does not.
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. Nothing in the coordination rules helps them: the parent is resident in Italy, so Italy's rules apply, and the child's own country of residence is irrelevant to the placement.
What can realistically be done
Not harmonisation. Long-term care is where national welfare traditions differ most, and the 2016 proposal shows how slowly even a definition moves.
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 — and for families living in Spain or France with a parent in Italy, it is the only layer that is any use to them.