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The most severe critics shall be made on the multilevel internal governance. The imbalances and the lack of coordination and cooperation between the three levels of administration involved (national government, regional administrations and local authorities) may lead to describing the management of this policy as a relative failure.
How the national regulation of this Minimum Subsistence Income fits in with the Regional Minimum Income policies raised dysfunctions from the outset. Firstly, because the national regulation sets a difference between the Basque Country (Euskadi/País Vasco) and Navarre (Navarra) and the rest of regions due to the different tax collection system of these two regions as well as to the attribution of powers by an agreement on the National Social Security Institute. This was seen by the other regions as an unequal treatment. Secondly, although the regulation also envisaged the possibility of promoting an agreement with the rest of regions and/or local authorities, the fact is that the national Minimum Subsistence Income began developing in parallel to the Regional Minimum Income policies of all regions except for these two (which were set decades ago). This postponed sine die the agreements between administrations. The national government argued that it had better information than the regions to implement these policies (e.g. data on personal income and Social Security), but did not consider the lack of employees of the national administration to deal with deploying this mechanism. Thirdly, it led to confusion amongst regional authorities, beneficiaries and potential beneficiaries. Finally, it filled social service departments in local councils that were already understaffed. This last aspect, which has perhaps received less attention than it should, is essential and explains to a large extent the failure in implementing a policy to all citizens that are subject to benefit from it. This is also stated by social services from municipal level as well as by regional Ombudsmen.
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Overall, the lack of coordination and cooperation between the different levels of administration on shared powers led to the relative failure of a very good initiative. This situation may improve once the planned agreements between the national administration and the regions are concluded and the social services of the regional governments are provided with resources.
