Høyesterett

Avlasterdommen

Avlaster II-dommen har store og uoversiktelige konsekvenser. Det er lett å peke på problemene dommen medfører. Her følger noen råd både til NFU-lag og til våre nasjonale myndigheter.

Avlaster II dommen

En avlaster i Ålesund gikk til sak mot kommunen og krevde at hun skulle regnes som ansatt i kommunen. Vanlig praksis er at støttekontakter og avlastere ikke ansettes, men har oppdragskontrakter. Et ansettelsesforhold reguleres av arbeidsmiljøloven og tariffavtaler, noe en oppdragskontrakt ikke gjør. Forskjellen kan gi store konsekvenser for den ansattes oppsigelsesvern, betaling og arbeidstidsreguleringer.

Høyesterett slo fast at avlasteren i Ålesund var å betrakte som en ansatt. Høyesterett uttalte seg bare om denne ene saken. Dommen gir ingen klare skillelinjer som forteller når personer med oppdragskontrakt er å betrakte som ansatte. Det vises til en del kjennetegn med ansettelsesforhold (se dommens pkt. 58). Oppsummert kan en si at når oppdragsgiver har rettslig adgang til å utøve ledelse og kontroll (se dommen pkt. 65), så er det snakk om et ansettelsesforhold.

Stortinget og regjeringen fortjener ros

5888 barn under 18 år har privat avlastning og kan bli rammet av dommen (se NOU 2016: 17, side 90). Hvor mye avlastning barna har, vet jeg ikke, men mange har avlastning en helg per måned, noen færre har trolig avlastning to helger i måneden.I tillegg vil jeg regne med at det finnes et hav av ulike vedtak og praktiseringer.  Det er disse 5888 barna og deres familier som står i fare for å miste tilbudet.

Avisen Sunnmørsposten varslet at flere tusen barn står i fare for å miste avlastningstilbudet. I Ålesund betrakter politikere situasjonen som en et valg mellom hvilke lovverk de skal bryte, – helse- og omsorgstjenesteloven eller arbeidsmiljøloven. Flere kommuner jobber med de private avlastningsordningene for tiden. Jeg har ikke hørt om noen som har funnet de gode løsningene.

– Alvorlig, sa arbeids- og sosialminister Anniken Hauglie (H) til NRK og varslet at hun vil finne en løsning så snart som mulig. Det er svært positivt og lover godt når statsråden ser alvoret og tar tak i saken.

 

 

Hva NFU-lag bør gjøre

Selv om flere statsråder sterke ønsker om å sikre det private avlastningstilbudet, så vet alle som kjenner feltet at statskverna maler sakte. Vi får håpe at regjeringen kommer med gode løsninger, men situasjonen er alvorlig og vi kan ikke sitte å vente på at regjeringen løser floken.

NFU-lag må gå i dialog med kommunen og forsøke å få til best mulig løsninger. Her er noen råd:

  1. Høyesterettsdommen gjaldt en sak. Det kan være avlastere hvor kommunens rettslige adgang til å utøve ledelse og kontroll er såpass liten at forholdet ikke kan regnes som et ansettelsesforhold. Hver oppdragsavtale med private avlastere må vurderes individuelt.
  2. I en del tilfeller vil avlastningen kunne ha et såpass lite omfang at den ikke er i strid med arbeidstidsreguleringene. Dette gjelder trolig spesielt støttekontaktordningene.
  3. Kommer en i konflikt med arbeidstidsreguleringene eller andre ansettelsesforhold, kan en forsøke med andre ordninger enn avlastningsordninger. De mest aktuelle alternativene til avlastning eller støttekontakt er:
    • Brukerstyrt personlig assistanse (BPA)
    • Omsorgslønn
    Velger en alternativ til avlastning, så må en huske på av avlastningen er gitt med enkeltvedtak. Enkeltvedtak kan ikke endres med mindre de er til partens gunst. Alternative ordninger er derfor kun aktuelle dersom tjenestemottakeren foretrekker den alternative ordningen.
  4. Først må en sjekke om de ansatte avlasterne er omfattet av en tariffavtale og hvilke arbeidstidsordninger tariffavtalene gir åpning for. Hvis det ikke foreligger en slik tariffavtale, så er det arbeidsmiljølovens regler som gjelder. Kommer en i konflikt med arbeidstidsreguleringene, kan en i visse tilfeller benytte seg av arbeidsmiljølovens unntaksregler. Har en avlastning fra fredag klokken 16.00 til mandag klokken 08.00, så er det 64 timer. Så lenge har en arbeidstaker normalt ikke lov til å arbeide sammenhengende. Men arbeidsmiljølovens § 10-12, gir under visse forutsetninger noen mulighet for slike arbeidstidsordninger. 
  5. Arbeidstilsynet kan gi dispensasjon for å arbeide ut over 13 timer sammenhengende dersom arbeidet er av passiv karakter.
  6. Avlastere og støttekontakter som i utgangspunktet har en ordinær fulltidsjobb, kan nå ha en ulovlig høy stillingsbrøk. Har en et barn på avlastning annen hver helg, så vil vedkommende ha 182 prosent jobb. Dette kan være i strid med ansettelsesvilkår og tariffavtaler. I noen tilfeller kan dette problemet løses ved å reforhandle avtalene.

Kommunene kan ikke, uten videre, si opp avlastere. Når avlasteren er ansatt, så kreves en saklig grunn for oppsigelse. Usaklig oppsagte avlastere kan saksøke kommunen. Det er i alles interesse av hver avlasteravtale vurderes individuelt.

Enkeltvedtak om tjenenester gjelder uavhengig av om avlastere er ansatte eller har oppdragskontrakt. Forvaltningslovens § 35, sier at vedtaket ikke kan endres med mindre det er en fordel for familien som har avlastningsvedtaket.

Økonomiske konsekvenser

De fleste støttekontakter og avlastere vil trolig få bedre betalt, de vil få feriepenger og pensjonsordning som ansatte. Regningen må betales av kommunen. De fleste kommunene vil trolig har økonimisk rom for slike merutgifter, men for de kommunene som allerede er økonomisk skviset, kan slike forhold være katastrofale.

Kostnadsnøklene i inntektssystemet til kommunene bygger på gjennomsnittsbetraktninger av kommunenes kostnader i tidligere år. De økonomiske konsekvensene av avlasterdommen ligger ikke i premissene for kommunefinansieringen. Inntekttsystemet kan heller ikke benyttes for å belyse saken.

Vi skal være glade for at helse- og omsorgsminister Bent Høie og arbeids- og sosialminister Anikken Hauglie har engasjert seg i avlastersaken. Vi får håpe at de også får kommunal- og moderniseringsminister Jan Tore Sanner med på laget. Jeg ser ikke hvordan en skal sikre situasjonen til alle de 5888 barna. Kommunene ser heller ikke løsningen for alle. Det minste som bør komme ut av statsrådenes engasjement, er en oppskrift til landets kommuner som viser hva kommunene bør gjøre for at alle de 5888 barna i privat avlastning kan få opprettholdt tilbudet.

Jens Petter Gitlesen

3 november 2016

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