The OMC inclusion and national social NGOs: From enthusiasm to ...

checked regularly whether a sneaky erosion of national competencies can happen” 22 . Also,one finds in Germany a strong rejection of everything that has to do with quantified targetsetting at the European level, ranking, and naming and shaming strategies 23 : “It is notacceptable to us if the useful, necessary and openly qualitative comparison is overlaid by afactual grading of even some sort of ranking” 24 .Here, the consultation of the relevant actors resembles the one in France with the exceptionsof the regions (Länder) who repeatedly and officially voiced their dissent with the OMCinclusion. Unlike in France, the NAP process has had different ministerial affiliations over theyears in Germany which are important as no institutional continuity could be assured at thetop levels of political leadership; yet, as in France, the people at the working level whocoordinate the process have largely remained the same since 2001, changing from oneministerial affiliation to the other.Comparable to the CNLE in France, there is in Germany a so-called permanent advisoryboard gathering regional and local representatives, social partners, NGOs and a fewacademics which has been created as a consultative body for the National Report on Povertyand Wealth (NARB) and was extended, in 2002, to the consultation process of the OMCinclusion. Whereas the CNLE meets every 1-2 months, this board convenes 1-2 times a year.However, this body has not been used in order to discuss general issues related to theimplementation of the OMC inclusion (see also Miebach 2004: 28). The regions can use thesecond chamber, the Bundesrat, to issue opinions and decisions.For the three rounds, there were consecutively one, two and again one meeting(s) 25 . In 2004,the government proceeded to a voluntary update of its NAP deemed necessary in the light ofthe so-called Agenda 2010. The advisory board was consulted once but without apparentimpact. Finally, in 2005, the advisory board was not consulted at all. While there was noparliamentarian debate in 2001, there have been debates 26 on the NAPs in 2003 and 2005,however after their transmission to the Commission. However, the Parliament received the22 “We shape the change!”, Ministry for Health and Social Affairs, 2004: 45.23 See the opinion of the German government (9.3.2005) on the communication of the Commission of 9 February2005 – COM (2005) 33 final. This evaluation was confirmed by all interviews conducted with the implied civilservants as well as with a German participant of a peer review.24 Ulrike Mauscher, Parliamentary Secretary of State in the Ministry for Work and Social Order, at the meetingof the conference of regional ministers for work and social affairs (ASMK) in November 2001.25 Friedrich 2006 and Miebach 2004 come to the same conclusions about the nature of the consultation processesof the first two rounds.26 “Debate” should be taken with caution: 45 minutes were accorded to six parliamentarians, advancing theirrespective proposals without any further discussion and without any particular reference to the document or tothe larger European context