Abstract
This article criticises the social policy literature for equating universalism to the universal coverage of citizens. The current so-called ‘universal’ social protection systems guarantee social citizen rights, while the revisited truly universalism guarantees social human rights for everyone. Crisp-set qualitative comparative analysis (csQCA) is used to map and track the level of exclusiveness or inclusiveness into social pensions in the existing 30 social pension programmes on 28 Latin American and Caribbean (LAC) countries. The article examines the various paths of eligibility requirements in social pensions conditioning three specific outcomes: (1) access for every older-age individual (truly universal), (2) access for every category of immigrant (no targeting by citizenship or residency) and (3) access for older-age immigrants with legal resident status (targeting by residency but not by citizenship). The research makes several contributions. First, it offers a useful inventory of the eligibility requirements for access to the 30 social pensions in LAC. Second, it proposes an analytical framework to redefine universalism after considering the migration-social policy nexus. Contrary to what the literature claims, there are no universal social pensions in the region. Third, the analysis indicates that only in two countries, Cuba and Jamaica, social pensions have immigrant-friendly targeting rules, requiring neither citizenship nor any length of residency to become a beneficiary. A total of 12 countries require citizenship and 24 of them a certain number of years of residency. Moreover, the overwhelming majority of social pensions are means tested. Finally, the csQCA allows identifying patterns of targeting mechanisms and is used to propose five exploratory regimes of inclusionary social pensions. The article calls for protected international mobility of the older-age population in the form of a truly universalistic system in which the entire aged population has the right to a social pension. Only then, countries would truly adhere to Article 22 of the Universal Declaration of Human Rights.
Everyone, as a member of society, has the right to social security and is entitled to realisation [. . .] of the economic, social and cultural rights indispensable for his dignity and the free development of his personality.
Introduction
International mobility of the older-age population is increasing worldwide. In the period 1990–2015, the number of older-age migrants worldwide increased from 25 to 42 million, and in the Latin American and Caribbean (LAC) countries, this number rose from 1.5 to 1.6 million (United Nations Population Division, 2015). If the number of international migrants – including older-age migrants – is increasing, and the global population is ageing, 1 are national social protection systems adapting to the fluid reality of the 21st century?
There is plenty of evidence that social rights of citizens are shaped by the type of welfare regime (Esping-Andersen, 1999; Franzoni, 2008; Haggard and Kaufman, 2009; Huber and Stephens, 2012), but what about the social rights of immigrants? On one hand, Soysal (2012) argues that international migrants enjoy citizenship rights even without the possession of legal status (see also Benton, 2010; Castles, 2002; Hammar, 1985; Joppke, 2007). On the other hand, research shows that long-term legal residents tend to enjoy social citizen rights and welfare entitlements, while other categories of immigrants do not (Bauböck, 2006).
Comparative welfare state research has not paid sufficient attention to the topic of immigrants’ access to social rights (i.e. the migration-social protection nexus; Sainsbury, 2006: 229). This is especially important in Latin America where international migrants have lower access to social protection in the host countries than individuals with a citizen status in the respective countries (Tokman, 2008: 19). Tokman concludes that the gap in social protection coverage in the region between citizens and international migrants is (1) higher in both the formal and informal sectors, (2) more than double for women than men, (3) higher for international migrants coming from the LAC region than from countries out of the region and finally, (4) the higher the social protection coverage for citizens the lower the gap with international migrants.
Social policy architectures 2 in Latin America have been fragmented by rules of access, providers and funding (Franzoni and Sanchez-Aconchea, 2018). However, we must ask if by including migration into the picture of the emerging Latin American welfare state, the result is an even more segmented social policy architecture? Moreover, does citizenship and legal residency act as stratifying mechanisms segmenting beneficiaries?
By focusing on the different eligibility requirements regulating the access to 30 social pension programmes in 28 LAC countries, 3 the primary purpose of this article is twofold: (1) to map and analyse the discriminatory effects targeting mechanisms have on the social protection coverage of older-age individuals relocating to LAC and (2) to revisit the concept of universalism with a human-rights approach after considering the migration dimension, discussing the shortcomings of the dominant social citizenship concept of universalism. More specifically, the article addresses the following questions: is there a gap in the access to social pensions between immigrants, citizens relocating to their nation-state and citizens residing in the host countries? Do eligibility requirements promote inclusiveness or exclusiveness of older-age immigrants into social pensions?
To respond to these questions, qualitative comparative analysis (QCA) is used to track and map the level of exclusiveness or inclusiveness into social pensions in the existing 30 social pension programmes on 28 LAC countries, relying on publicly available data from ECLAC (n.d.), HelpAge International (n.d.), Organisation for Economic Cooperation and Development et al. (2014), Social Security Administration (2016) and from national social security acts. In lieu of a truth-table, a five-level diagram is constructed, coding pension systems on five different eligibility requirements or targeting mechanisms (citizenship, legal residency status, geographical location, access to any other kind of pension, means-testing) and illustrating the combination of targeting criteria that characterise different pension schemes in different countries. The interaction of conditions (i.e. the configuration of conditions) helps to track the degree of ease an international older-age immigrant has to be covered by social pensions in the host country.
The article makes several contributions. First, it offers a useful inventory of the eligibility requirements for access to the 30 social pensions in LAC. Second, it proposes an analytical framework to redefine universalism in social policy after incorporating the migration dimension into the analysis. Contrary to what the social policy literature claims, the article confirms there are no universal social pensions in the region. Social pensions in Bolivia, Guyana and Suriname, are not ‘truly-universal’ because of the inclusion of citizenship and residency eligibility requirements as targeting mechanisms. Third, the analysis indicates that only in two countries, Cuba and Jamaica, social pensions have immigrant-friendly targeting rules, requiring neither citizenship nor any length of residency to become a beneficiary. Brazil’s scheme for rural workers requires neither citizenship nor residency per se, but a certain number of months of rural employment. A total of 12 countries require citizenship, 24 of them a certain number of years of residency, and the overwhelming majority of social pensions is means tested. Five social pension regimes are proposed taking into consideration universalism with a human-rights approach. The article calls for protected international mobility of the older-age population in the form of a genuinely universalistic system in which the entire aged population, regardless of immigrant status, has the right to a social pension. Only then, countries would truly adhere to Article 22 of the Universal Declaration of Human Rights.
The article is organised as follows. The following section briefly introduces the theoretical framework, situating social pensions in the social protection framework, and redefining universalism with migration and the new mobility paradigm in perspective. Later, the QCA and the explanatory factors are introduced. Finally, section ‘Results and discussion’ presents the main results of the research, interconnecting the discussion and conclusions.
A revisited ‘universal’ in social protection inclusive of all human beings
Social protection
Social protection, or social security, is considered a social development practice as it raises the household income while developing beneficiaries’ human capital by encouraging school attendance and raising health outcomes (Midgley, 2014). Therefore, social protection involves the transference of cash benefits to individuals and the provision of benefits in kind (e.g. public education, healthcare, housing). This article pays attention to cash benefits in the older-age population.
There are two broad available cash benefit options in the social policy menu: social insurance and social assistance programmes. Social insurance is a cash transfer based on consumption smoothing and collective risk sharing. It is, generally, a contributory programme where employers and employees contribute shares of the wages to fund cash transfers of workers at specific times of vulnerability (e.g. unemployment, disability, reaching retirement age). On the contrary, social assistance programmes are generally non-contributory programmes 4 using benefits to level up individuals living below a societal minimum standard (Cruz-Martinez, 2019b; Barr, 2012).
One of the ways in which the older-age population copes with non-random disadvantages accumulated across their life is pensions. Pensions are cash benefits that can be classified as social insurance (contributory pensions), social assistance (social pensions) or private schemes (individual capitalisation funds), which differs according to the funding sources and the ideology supporting them. Contributory pensions are funded via contributions or taxes, while the state usually finances social pensions, and individuals fund private pensions. Welfare residualism and (neo)liberalism could be considered as the ideologies supporting private pensions, while Keynesianism and the social security Bismarckian approach stands by contributory pensions. Social pensions can follow a residual approach if benefits are targeted to those considered as the ‘truly-deservers’, or can take a social democratic approach if benefits are guaranteed to all older-age individuals. The following subsection briefly describes the main difference between universalism and targeting to be able to define different types of social pensions and distinguish how specific eligibility requirements can discriminate between citizens and particular categories of immigrants.
Targeting versus universalism
Cash benefits such as social pensions can be assigned to all individuals (e.g. universal social pensions) or reserved to a group of individuals with specific characteristics (targeted social pensions). Targeting implies a range of techniques to identify those considered as the neediest and ‘deserving poor’. Following Gilbert (2000: 9–11), at least two ‘pure’ types of targeting mechanisms are identified: categorical targeting and targeting by means.
Categorical targeting uses an easily identifiable category as a proxy to identify a group in the population. Categories include a range of criteria such as age, employment status and geographical location. If categorical targeting is used as the only targeting mechanism, beneficiaries are expected to receive a universal flat-rate benefit. Nonetheless, as this article shows for social pensions in LAC, categorical targeting is usually used in conjunction with other types of targeting mechanisms (e.g. targeting by means).
Targeting by means involves means-testing to identify poor-income households. Means-testing might involve the corroboration of incomes (e.g. wages, contributory pensions) or assets (e.g. properties, capital investments). If targeting by means is used as the only targeting mechanism, beneficiaries are expected to receive a flat-rate benefit/service (e.g. public healthcare) or an incremental benefit conditional on the relative degree of need.
By definition, social pensions are targeted social assistance programmes. The reason for this is that – at least – age is used as an eligibility criterion by the state to identify the beneficiary group. However, once targeting by age is performed, a social pension can still be universal if every older-age individual could become a beneficiary. This is what we call universal targeting (Cruz-Martinez, 2019a; Cruz-Martinez, 2018). If the social protection programme demands other eligibility requirements, such as residency or citizenship, then the social pension could not be considered a universal cash transfer because not every older-age individual could become a beneficiary. However, when discussing these concepts and policy tools, scholars have traditionally connected universalism with the notion of citizenship (Kildal and Kuhnle, 2008; Koehler and Rabi, 2017; Willmore, 2007). Following Marshall (1950), universal social policy entails that citizens in a nation-state benefit from social protection as a social citizen right. Welfare benefits are thus considered as birth rights (Marshall, 1950). Likewise, the Economic Commission for Latin America and the Caribbean classifies a social policy as universal if it is ‘available for the citizenry as a whole’ (Cecchini et al., 2015).
In a globalised world with large numbers of individuals relocating to countries different from their place of birth, the social policy literature should question the normative prerequisite of citizenship for a human being to be considered a deserving individual. Citizenship status and immigration law invalidate the universal access of welfare benefits and hierarchise rights to welfare programmes. For instance, Könönen (2018) confirms the differential inclusion of non-citizens in Finland, one of the so-called universalistic or social democratic welfare states. Könönen (2018) demonstrates the existing legal hierarchies between non-citizens’ entitlements: ‘Non-citizens’ social entitlements differ depending on the nationality, the type of legal status and the form of employment, affecting their position in the labour markets and in the society’ (p. 53). Hayes de Kalaf (2019) evidences the role played by civil registries in the Dominican Republic to exclude ‘racialised others’ from social citizenship rights. Casey (2018) pays particular attention to the discriminatory attacks against the rights of ‘racialised’ others (i.e. immigrants, minority groups, refugees). Hence, citizenship and residency, along with other types of targeting mechanisms, act as powerful devices of exclusion and inclusion of social welfare programmes.
Citizenship refers to the recognition of being born in a specific nation-state by the so-called lottery of birth (i.e. the status of being a citizen from a particular country). Therefore, nation-centric and rigid social policy architectures with social citizenship rights discriminate among individuals because of the chance deriving from the lottery of birth. ‘States typically conceptualise [. . .] social contracts vis-à-vis citizens, rather than with migrants or other visitors’ (Noy and Voorend, 2016: 606). These authors differentiate citizen rights – those extended to every citizen – and human rights – those granted to every individual, citizen or not. Migration is transforming the traditional notion of citizenship and social citizen rights (Bauböck, 2006), signalling the gap between members with full rights to social welfare programmes (i.e. citizens and holders of long-term residence permits) and those living in the nation-state without rights to social welfare (i.e. short-term stayers, migrants with irregular status; Bosniak, 2000).
The literature presents the basic universalism as the next step in the Latin American emerging welfare states (Montero, 2008). Basic universalism, according to Molina (2006), is achieved through a combination of universal coverage of essential services, quality transfers for everyone and with the state as the leading provider. Filgueira et al. (2006: 21) agree with Molina and explicitly call for a basic universalism grounded on universal coverage of welfare programmes coping social risks with uniform standards for everyone and following the social-citizenship right approach. The limitation of the basic universalism proposal is that the social-citizen approach implies the provision of welfare benefits with a rights-based approach but only for citizens. Citizens represent the ‘everyone’; therefore, basic universalism proposes rights-based benefits only for those who meet the citizenship – and in several cases, residency – eligibility requirement.
More recently, the literature has defined universalism as a social policy output achievable in multiple ways. Countries can deliver universal policy outputs through a diverse set of instruments (e.g. social insurance and social assistance) and with welfare providers across different levels of government (Moreno, 2007; Pribble, 2013). Pribble (2013) proposed an operational measure to track the progress towards universalism using Latin America as a case study. The four criteria of a universal model according to her are universal coverage, little or lack of segmentation in the services and transfers, sustainable and equitable financing, and non-discretionary transfers. According to Cecchini et al. (2015: 41): A pure universal model would be one with full universal coverage (e.g. all families with children, all older adults, all unemployed, the whole population in the case of health-care access) based on objective criteria and underpinned by laws that guaranteed basic rights, adequate and homogeneous service quality, little or no stratification of transfers and sustainable financing based on general revenues (with a progressive tax base) or contributory models whose architecture, combined with provision, generated progressive effects.
Martínez Franzoni and Sánchez-Ancochea (2016) argues that the welfare system secures universal social policy outputs if the entire population living inside the national boundaries has access to generous transfer and services regardless of their class, citizenship, gender and status. Therefore, massive coverage of population needs to be combined with generous benefits – in terms of level and quality – and even distribution (i.e. equity in coverage and benefits). Martínez Franzoni and Sánchez-Ancochea call this the triangle of coverage, generosity and equity.
Language matters and shapes our thinking. Based on the social policy architecture framework, specifically on the eligibility criteria, this article argues that social protection programmes could be labelled as universal only if every individual living in a country is eligible. If citizenship, residency or other attributes act as a discriminatory mechanism, then at most, we could talk about universalism for citizens-residents, but we must not refer to universalism. By doing so, researchers and policymakers are excluding non-citizens, legal residents and non-legal residents from the category of human beings.
Re-examining the concept of universalism: citizenship and residency as discriminatory targeting mechanisms
‘Eligibility rules set out who is entitled to a programme and can exclude certain groups from social protection. These can include rules set in relation to targeting and conditionality’ (Hopkins et al., 2016: 4). One of the groups that can be excluded by eligibility requirements are non-citizens or at least different categories of immigrants such as skilled workers, long-term legal residents, refugees, undocumented migrants.
Sainsbury (2012) argues that it is necessary to have a multidimensional approach when understanding the social rights of immigrants in the host country. She argues that to truly understand the variation in the quality of immigrants’ social rights, researchers need to go beyond the four conditions 5 used by Esping-Andersen (1990) to develop the typology of welfare regimes. Specifically, Sainsbury proposes to include two additional complementary conditions: the immigration policy regime (Boucher and Gest, 2015) or incorporation regime (Soysal, 1994), and the form of immigration (Morris, 2002).
The analysis of welfare regimes in shaping the degree of inclusion or exclusion of older-age adults in Latin American social pensions is out of the scope of the article, as it focuses on the structural, programmatic requirements of social pensions which includes or excludes older-age adults based on eligibility requirements. The novelty is the incorporation of citizenship and residency as targeting mechanisms; thus, the relevance to consider the form of immigration and the incorporation regime.
The incorporation regime ‘consists of rules and norms that govern immigrants’ possibilities to become a citizen, to acquire permanent residence, and to participate in economic, cultural and political life’ (Sainsbury, 2012: 16). Here, we are not interested in examining these inclusionary measures but the inclusion of individuals – citizens and non-citizens – into social pensions.
The form of immigration refers to the different ‘entry categories’ of non-citizens in a nation-state (e.g. legal residents, refugees, asylum seekers, ethnic citizens). 6 Sainsbury (2012) and Perna (2019) among other international migration scholars highlight the need to update the welfare regime literature taking into consideration the particular rights and restrictions to social rights depending on the category or type of immigrant. The literature mentions several categories: refugees, labour migrants, co-ethnic immigrants, family members and asylum seekers, among others. As Sainsbury (2012: 16) notes, ‘entry categories stratify the social rights of immigrants’. This article examines if citizenship and residency status stratify the social rights of older-age immigrants relocating to LAC.
International mobility of migrants is motivated by several reasons, including the insecurity created by conflicts, the search for upward mobility, family life and pleasure among others. Faist (2013) argues that in fact, spatial mobility has significant explanatory power on social mobility and social inequality. However, as Sheller and Urry (2006) claim, one of the social sciences’ scholarship limitations has been its ‘a-mobile’ or static perception of society. Following this argument of the new mobility paradigm, not considering citizenship-testing and residency-testing as targeting mechanisms in social protection programmes could be exposed as a ‘sedentarist’ limitation of the social policy literature.
According to Sheller and Urry (2006: 208–209) sedentarism, derived from the work of Heidegger (2002), ‘treats as normal stability, meaning, and place, and treats as abnormal distance, change, and placelessness’. This sedentarism and territorial nationalism in social policy could be used as an explanation to understand why residents and citizens are portrayed as the natural beneficiaries of social protection programmes, while irregular migrants – which does not meet citizenship or residency eligibility requirements – are not seen as customary deserving recipients.
A more inclusive society would incorporate non-citizens and would entitle them with more social rights than an exclusive society. While the previous sentence is valid and useful to merge the concepts of incorporation regime and the form of immigration, we must conduct a critical reflexion on what conditions a social programme must have to be considered universal.
Several social pensions have been widely classified as universal by scholars, think tanks and international organisations (e.g. Bolivia’s Renta Dignidad), even though cash benefits are not available unconditionally to all who meet the age eligibility (Cruz-Martinez (2019a); ECLAC, n.d.; HelpAge International, n.d.; Kidd, 2009; Ortiz et al., 2015; Willmore, 2007). This article argues that social protection programmes cannot be catalogued as ‘universal’ if citizenship and residency status acts as stratified mechanisms targeting the targeted older-age individuals. The article adopts the coverage dimension in Martínez Franzoni and Sánchez-Ancochea’s (2016) definition of universalism. Rather than massive coverage, universalism is understood as the total coverage of the population. The generosity and equity dimensions were not included in the empirical analysis and are left for a future research paper. Therefore, a universal social pension is a cash-transfer programme for the entire population above the age-eligibility requirement living inside the national boundaries regardless of their class, citizenship, gender and status.
As it was noted in the ‘Introduction’, higher numbers of older-age individuals are relocating to countries different from their place of birth. So what happens to an older-age individual if she/he migrates to LAC? Do immigrants have to meet the same categorical and means-tested targeting mechanisms as citizens? Is there any additional eligibility requirements limiting their inclusion as beneficiaries of a social pension scheme?
Empirical point of departure
Inclusion and exclusion of beneficiaries via targeting mechanisms
To answer the research questions and describe the level of inclusion or exclusion of social pensions in LAC towards older-age immigrants, five targeting mechanisms are used as explanatory factors in the qualitative comparative analysis, summarised in Table 1.
Description of targeting mechanisms.
The first two targeting mechanisms are citizenship and residency status. Both are categorical targeting mechanisms – as it was previously mentioned – even though they are not usually considered as such in the social pension’s literature. Citizenship ‘generally denotes full membership in a political community, comprising a set of rights and/or political obligations’ (Craig, 2002). An individual is considered a citizen of a nation-state if one or both of their parents are citizens (jus sanguinis), by the place of birth of the individual (jus soli), or by years of legal residency (naturalisation). Social pensions targeting citizenship will exclude all different categories of immigrants residing in the nation-state – regardless of their status.
Meanwhile, residency refers to the current place of residence and the legal status of the individual. Therefore, social pensions targeting residency will exclude citizens with a legal permanent residence in another nation-state as well as immigrants without legal residency status. Generally, a specific amount of years of legal residency prior to the application of the social pension is required.
Geographical targeting is also another type of categorical targeting. This mechanism ‘selects different districts, villages or regions – often on the basis of [income] poverty data where [deprivation] is known to be chronic, or on the basis of other criteria (such as proneness to earthquakes, flooding [or other] natural disasters’ (Slater and Farrington, 2009: 9). This type of targeting will include as beneficiaries only those living at predetermined specific locations inside the nation-state.
Pension-testing is a categorical targeting. Beneficiaries are targeted, taking into account if the individual is a pensioner (category) or not of a contributory, foreign or private pension. Therefore, pension-testing excludes individuals entitled/receiving any other kind of pension. ‘Pension’ is the label used for this type of targeting in Figure 1.

Targeting older-age adults in Latin America and the Caribbean: examining eligibility requirements and immigrant-friendly social pensions in a five-level diagram after csQCA.
Finally, means-testing identifies the beneficiaries based on assessments of income, assets or wealth. Generally, those with incomes below the poverty line – or alternatives monetary thresholds – are included as beneficiaries.
Research technique: csQCA
The purpose of the QCA is to transform information from data into a truth-table where different combinations of conditions producing a specific result can be identified. In this research, QCA is used to determine if it is possible to identify a universal or an inclusive immigrant-friendly social pension programme by examining five categorical and means-tested targeting mechanisms as causal conditions.
Ragin’s (1987: 84) intention with this technique was to develop a strategy as a midpoint between the case-oriented approaches (qualitative) and variable-oriented approaches (quantitative), where the best features of both could be integrated into one method. Ragin (1987) rejects the argument that through QCA a single causality is determined, rather a number of different paths that might have allowed the corresponding final outcome to be determined. In his next books, Ragin (2000, 2008) calls for a justification of the use of crips (dichotomous) versus fuzzy sets. The main distinction between the two is the degree to which they satisfy membership criteria. With crisp-set QCA (csQCA) variables can only have two values, which have to be determined by the researcher based on a defined threshold. It distinguishes full-membership (1) versus non-membership (0) (i.e. in vs out, high vs low). On the contrary, with fuzzy-sets QCA (fsQCA), membership scores can vary from 0.0 to 1.0. This article relies on csQCA, as social pension programmes either incorporate an eligibility requirement as a targeting mechanism or not.
Therefore, the article examines the various paths of eligibility requirements in social pensions conditioning three specific outcomes: (1) access for every older-age individual living in the country (truly universal), (2) access for every category of immigrant (no targeting by citizenship or residency) and (3) access for older-age immigrants with legal resident status at the moment of application and who meet any other requirement (targeting by residency and no targeting by citizenship).
Variables in the csQCA are used to portray the stratifying mechanisms of eligibility requirements and to identify a potential universal or inclusive immigrant-friendly social pension. The csQCA tracks the set of causal conditions that must be met in each case to become a beneficiary. In addition, the csQCA allows identifying patterns of targeting mechanisms, tracing commonalities across social pension’s programmes in the region and could be even used to propose exploratory regimes of inclusionary social pensions.
Causal relationships between targeting mechanisms of eligibility requirements (explanatory factors) and the three outcomes are examined through Boolean algebra principles and comparative analysis. Qualitative data binary matrices (0, 1) are used to describe the presence or absence of specific characteristics or conditions. A case exhibits a ‘1’ in the explanatory variable presenting the favourable features for the desired outcome. Therefore, cases with a ‘0’ in the explanatory variable exhibit unfavourable features for the desired outcome. A social pension exhibits a ‘0’ in the csQCA if the programme has an eligibility requirement for any of the five targeting mechanisms. For example, a social pension with a ‘0’ in the citizenship factor denotes that only citizens can become beneficiaries, while a social pension with a ‘1’ denotes that both citizens and non-citizens can become beneficiaries.
The absence of the citizenship, legal residency, means, geographical and pension eligibility requirements lead to the first desired outcome: access to a social pension for every older-age individual living in the country (truly universal). The analysis of necessary conditions in the fsQCA software presents with an error, as expected, because all five tested conditions are necessary for the desired outcome.
The absence of at least citizenship and legal residency eligibility requirements leads to the second outcome being examined: access for every category of immigrant. The analysis of necessary conditions in the fsQCA software confirms, as expected, that citizenship and residency conditions have a consistency score of 1.0.
Third, the presence of the residency eligibility requirement and the absence of at least the citizenship eligibility requirement lead to the third outcome being examined: access for older-age immigrants with legal resident status. The next section unveils the need to distinguish, in addition, if immigrant-friendly social pensions require a specific amount of time of legal residence at the moment of application. The analysis of necessary conditions in the fsQCA software confirms, as expected, that the citizenship condition has a consistency score of 1.0 in the immigrant-friendly path without any specific time requirement of legal residence. However, the absence of means-testing also has a consistency score of 1.0, due to none of the cases following the third path target social pensions by means (see Ragin and Davey, 2016 for more details on the fsQCA analysis).
A multiple truth-table is constructed showing the favourable (1) and unfavourable (0) targeting conditions for a truly universal social pension (not shown here). The absence of targeting mechanisms is considered the favourable condition for a universal or an immigrant-friendly social pension. Instead of the truth-table, a five-level figure – one level for each targeting mechanism besides age – is built to display and trace more easily the combination of targeting mechanisms in the 30 social pensions. The figure reveals a binary map with the combination of conditions necessary for the social pension to be truly universal or – at least – open to granting access for older-age immigrants with legal residency status. Figure 1 not only helps to identify distinct targeting mechanism trajectories but also facilitates visualising the gaps in the access to social pensions for individuals with different immigration statuses.
Results and discussion
Figure 1 illustrates the high level of stratification that is created due to the targeting mechanisms of social pensions. Access to cash transfers of social pensions in LAC is linked to the legal status of older-age individuals. This creates a hierarchical and stratified system in which eligibility to social assistance is limited by – at least – five different levels of targeting mechanisms. The ‘truly-deservers’ of social pensions are then identified taking into account a combination of the following conditions: the citizenship of an individual – lottery of birth – place, duration and status of residence, the existence of additional sources of revenue (e.g. contributory pensions, salary, assets) and the relative perception of being considered in poverty, mainly assessed through monetary instead of multidimensional approaches.
The 30 social pension programmes followed 11 different targeting paths, meaning that there are 11 unique combinations of eligibility requirements. This multiplicity of targeting mechanisms co-occurs (i.e. the older-age population must meet two or more eligibility criteria), or develops in parallel (i.e. different groups of beneficiaries are selected according to a different combination of targeting measures). Let us briefly describe the various types of multiple targeting mechanisms with two social pensions in the region.
For example, the Dominican Republic’s social pension, ‘Pension de asistencia social’, follows the simultaneous type. Beneficiaries must have an income below the minimum legal monthly wage, must be legal residents and cannot be considered as dependents of a contributory pension holder. However, Colombia’s social pension, ‘Programa Colombia Mayor’, follows the parallel type. First, beneficiaries must be Colombian citizens with 10 years of residency immediately before the application, with insufficient means to live according to the National SISBEN poverty index and be living in one of the selected municipalities where the programme is operating. Once the citizenship-, residency-, and means-testing are applied, different pension levels are established, taking into account the level of contribution to the ‘Beneficios Económicos Periódicos’ means-tested individual account.
The more used targeting mechanisms are means-testing (25 programmes), residency-testing (24 programmes) and pension-testing (22 programmes). Citizenship-testing is used in 12 social pensions, while geographical-testing is applied only in 3 programmes. The most relevant for the object of study in this article is the residency-testing and citizenship-testing, as they are responsible for including or excluding different categories of immigrants.
None of the programmes followed the first path; therefore, none is truly universal, meaning that at least more than one targeting measure is implemented besides age eligibility. 7 A total of 12 programmes have 2 targeting mechanisms, this being the least number of targeting mechanisms exhibited among the 30 social pensions in the region. The Cuban ‘Pensión de asistencia social’ and the Jamaican Programme for Advancement through Health and Education have means- and pension-testing, while Bolivia’s ‘Renta Dignidad’, Guyana’s Old Age Pension and Suriname’s ‘Algemene Oudedags Voorzieningsfonds’ exhibit citizenship- and residency-testing. Antigua & Barbuda’s Old Age Assistance Programme, Chile’s ‘Aporte Provisional Solidario’, Costa Rica’s ‘Programa Régimen No Contributivo’, Trinidad & Tobago’s Senior Citizens’ Pension and Venezuela’s ‘Gran Misión Amor Mayor’ use means- and residency-testing to select beneficiaries. The Mexican social pension, ‘Pensión para Adultos Mayores’ exhibits pension- and residency-testing and, finally, the Brazilian ‘Previdencia Rural’ implements pension- and geographical testing.
Of these 12 programmes, only three followed the second path in the QCA: Cuba, Jamaica and Brazil’s ‘Previdencia Rural’. These three are the only ones without targeting by citizenship and residency. However, only social pensions in Cuba and Jamaica are considered as ‘immigrant-friendly’. In both cases, social welfare legislation uses the wording ‘any person’ who meets the following criteria is eligible for the social pension. The criteria for both programmes is living in monetary poverty and not receiving any other pension. 8 The article is not arguing here that social pensions in Cuba and Jamaica are the best in the region in terms of effective coverage, or replacement rates. These two are the most immigrant-friendly social pensions in the region. Now, taking a more in-depth look into the social assistance pension in Cuba, ‘the monthly average social assistance benefit was 154 pesos in 2013 or US$6.16 [. . .], 41 percent less than the average social insurance pension [and not enough] to cover basic food needs’ (Mesa-Lago, 2017: 116). This means that a social pension can be immigrant-friendly without being the model to follow in terms of effective coverage and replacement rates.
Although the ‘Previdencia Rural’ social pension does not target by citizenship or residency, it does require beneficiaries with a history of 180 months’ work in rural areas that must not exceed a yearly quota of 90 days in non-agricultural economic activities. The logical explanation for this requirement is to grant social rights to farmers who are generally working in the informal sector – thus not contributing to the social insurance pension. However, for this reason, it is not considered as an immigrant-friendly social pension.
Finally, which countries followed the third path and thus could be granted with the ‘consolidation prize’? Out of the 15 social pensions following the third path in the QCA that target beneficiaries by residency but not for citizenship, only 6 have no requirements for a given period of legal residency as an eligibility requirement (e.g. 5 years prior to application). These are Bahamas’ Old Age Non-Contributory Pension, Belize’s Non-Contributory Pension Programme, Costa Rica’s ‘Programa Régimen No Contributivo’, Dominican Republic’s ‘Pensión de asistencia social’, El Salvador’s ‘Pensión Básica Universal’ and Saint Kitts & Nevis’ Old-age social assistance. However, the Bahamas have an additional employment-testing that limits even more the access of international migrants to social pension coverage (i.e. if claimant is not an insured person, she/he must be a citizen or a resident who has continuously worked for a period longer than 12 months within the last 15 years preceding the claim).
Legal residents in Belize, Costa Rica, Dominican Republic, El Salvador and Saint Kitts & Nevis are treated as equals to citizens regarding eligibility, although different categories of migrants with legal resident status are socially created. Faist (2013: 1642–1643) argues that the reproduction of discursive social inequalities in public debates and public policies creates mechanisms of hierarchisation. Highly skilled international migrants are labelled with the category of ‘mobile’ individuals in contrast to other low-skilled international migrants – with or without legal residency – who are labelled as ‘labour migrants’ in a pejorative way. Mobile is then a category to refer to those ‘wanted and welcome’ while labour migrants is a category used for those ‘wanted but not welcomed’ (Zolberg, 1987). The second favoured entry-category is refugees with convention status. As Sainsbury (2006: 230) recalls, ‘the Geneva Convention has accorded [refugees with convention status] the same treatment as nationals with respect to public assistance and social security benefits’. Undocumented older-age migrants, older-age refugees without convention status and international older-age migrants inside alternative entry categories are then left with minimal chances to claim social pensions in LAC. These have only the opportunity to become beneficiaries in Cuba and Jamaica, if and only they met the pension and means eligibility requirements.
The csQCA results reveal distinct groups of countries with similar paths of targeting mechanisms in the 30 LAC social pensions. A typology of social pensions is proposed taking into account these groupings and the inclusiveness of older-age adults (citizens or non-citizens) into social pension programmes. Table 2 shows the five social pension regimes with a human-rights approach. None of the countries has a universal social pension, where every individual is entitled to a cash transfer. Jamaica, Cuba and Previdencia Rural in Brazil are in the immigrant-friendly targeting regime. Citizenship and residency eligibility requirements are absent in these three cases, although the Brazilian social pension has rural employment requirements that impede access for immigrants. The legal-residency targeting regime includes all social pensions without citizenship requirement and without a specific legal-residency time requirement. The social pensions in Belize, Costa Rica, Dominican Republic, El Salvador and Saint Kitts & Nevis are in this regime. Although the Bahamas have a legal-residency targeting, the employment requirement limits the access of immigrants.
Social pension regimes with a human-rights approach.
Note: Social Pensions of Brazil 2 (Previdencia Rural), Bahamas, Bolivia, Guyana and Suriname have an asterisk (*) to highlight its particularity within its classification in a regime. Social pensions in Brazil and Bahamas have an additional targeting mechanism (employment requirement) which limits, even more, the inclusion of older-age migrants into the social assistance programme. Social pensions in Bolivia, Guyana and Suriname are immigrant-unfriendly but universal for citizens with legal residency in each of the countries.
The long-term legal-residency targeting regime includes all social pensions without citizenship requirement but with a specific legal-residency time requirement. Finally, social pensions with citizenship testing are classified in the immigrant-unfriendly regime. Although Bolivia, Guayana and Suriname do not target by means, pensions or geographical region, their citizenship and residency requirement disable the access to different categories of migrants. They could be located in a sixth regime called universal social pensions for citizens and legal residents. However, they should not be labelled as universal social pensions.
Conclusion
Citizenship acts as a filter, including the deserving individuals and excluding the non-deserving ones (Voorend, 2013). This article criticises social policy literature for equating universalism to universal coverage of citizens rather than humans. The current so-called ‘universal’ systems guarantee social citizen rights, while the truly universalism proposed in this article is reserved for those programmes guaranteeing social human rights for every individual residing in a nation-state.
There is an epistemological need for welfare states to evolve its conception of a deserving individual from citizens to human beings. Simply put, social citizen rights must be conceptualised as social human rights. As noted above in the Universal Declaration of Human Rights, access to social protection is supposed to be granted to every individual. However, a nation-centric and rigid conceptualisation of universality excludes individuals not belonging to the citizens of a state.
The three key findings of the article are as follows. First, the form of immigration allows distinguishing different social rights to particular categories of immigrants, at least regarding access to social pensions in LAC. Second, eligibility requirements promote the exclusion of older-age immigrants into social pensions, except in two cases, which are available for ‘any person’ meeting the additional means- and pension-testing mechanism. In contrast to what Sainsbury (2012) proposes, there are significant and visible differences between the social rights of citizens and non-citizens. The Jamaican and Cuban social pensions are the only two social pension programmes in Latin America that are friendly towards older-age individuals relocating to the region because citizenship and residency are not eligibility requirements acting as targeting mechanisms.
Third, there are no universal social pensions in the Latin American region. In contrast to what the social pension literature claims, the Bolivian, Guyanese and Surinamese social pensions are not ‘truly-universal’ due to the inclusion of citizenship and residency eligibility requirements as targeting mechanisms; Figure 1 shows how international migrants residing in these nation-states do not have automatic coverage in the social assistance programmes.
It is also relevant to acknowledge the limitations of this article with the purpose to overcome them in future research. The comparative research was conducted with secondary data from a diverse set of sources, and also recurring to national social security acts. Therefore, the article shows a ‘de jure’ picture that might not necessarily be the ‘de facto’ reality. There might be additional informal eligibility requirements acting as targeting mechanisms that are not represented in the data (e.g. affiliation with a political party, family member of a political elite). To overcome this limitation, future fieldwork-based research should be incorporated to present a closer picture of the ‘de facto’ reality. Finally, this research used five targeting mechanisms in addition to the age eligibility requirement. Future research might incorporate additional targeting mechanisms – such as employment requisites – to see if they have a discriminatory effect on international migrants’ access to social pensions.
Efforts are needed to move towards protected international mobility of the older-age population, where migrants would be able to integrate into the host societies without reproducing cross-border inequalities. Social pensions guarantee a basic social protection floor for older-age population and could be their only or primary source of income. Tokman (2008) adds a list of factors which should be considered to promote a protected and non-discriminatory international mobility: free circulation of people, regularisation of individuals without residence legal status, the promotion of social mobility to spatial international migrants through entitled social protection as a human right, and the development of transferable social protection rights among net migration emitters and receivers. Specifically, in the case of older-age migrants, the last two could be highlighted as the most relevant. With more integration and cooperation between countries, individuals meeting the eligibility requirements for contributory or non-contributory pensions in their previous country of residence or place of origin would be entitled to cash benefits in the new country of residence. To support this, social justice arguments based on the rights of individuals to entitled social protection must be raised.
Social pensions must be seen as a means to an end. This social assistance programme increases income security and political support to conduct the necessary reforms to implement an institutionalised welfare system with a mix of contributory and universal social welfare policies. Social policy needs a ‘postnational deterritorialization process’ to adapt to liquid modernity (Bauman, 2000; Sheller and Urry, 2006). Instead of stratifying and excluding migrants, truly universal social pensions could promote inclusive welfare.
After revisiting the concept of universalism as truly universalism with social welfare entitlements for all, we must ask how to achieve universal access. The institutional arrangements of ‘universal’ social rights coverage in a transnational context could be an option. Citizens across the European Union can transfer their contributions and social welfare entitlements across nation-state borders. Therefore, the integration or collaboration of emerging welfare states could be a viable option to consider. Scholars of the transnational school argue, according to Voorend (2013), that nation-states must grant social rights to immigrants residing in their territories following the recognition of the human right legislation, which overcomes the exclusionary distinction between national and foreigner (Jacobson, 1996; Sharma, 2006; Soysal, 1994). This inclusionary responsibility of 21st century nation-states devaluates the importance of citizenship over human rights (Sassen, 1996).
Supplemental Material
Appendix – Supplemental material for Rethinking universalism: Older-age international migrants and social pensions in Latin America and the Caribbean
Supplemental material, Appendix for Rethinking universalism: Older-age international migrants and social pensions in Latin America and the Caribbean by Gibrán Cruz-Martínez in Global Social Policy
Footnotes
Acknowledgements
A large part of this paper was written while the author was a Postdoctoral Research Fellow at the University of Agder. The author would like to thank Roberta Perna, his colleagues at the Department of Global Development and Planning (UiA) and participants of the ‘Social Policy in Emerging Welfare States’ section in the 2018 ECPR General Conference, and the 2017 SLAS Annual conference, who provided much appreciated comments on earlier drafts of this article. Shortcomings, of course, remain his responsibility.
Funding
The author(s) disclosed receipt of the following financial support for the research, authorship and/or publication of this article: The author(s) received financial support for the research of this article from the University of Agder and the Spanish Ministry of Economy, Industry and Competitiveness (FJCI-2016-29871 & GOWPER-CSO2017-85598).
Supplemental material
Supplemental material for this article is available online.
