Linz, 13.8.2010

Dear ladies and gentlemen,

FIFTITU% - Networking Center for Women in Arts and Culture in Upper Austria issues a statement on the draft of a federal law amending the Commercial Social Insurance Act and
the Artists' Social Insurance Fund Act are amended
(Artists' Social Insurance Structure Act - KSV-SG) issues the following statement:

FIFTITU% welcomes the initiative and the present draft law, which probably means an improvement for artists. We see this draft as a step in the right direction.

In particular, we hope that the establishment of an artists' service center (§189 a and b) will make it easier to obtain information and process
of insurance situations. A planned contact point for advice and support in social insurance matters, in particular to improve the compatibility of
self-employed and employed artistic work is something we expressly welcome.

However, it should be critically noted that the draft in question does not represent a real improvement in the social and economic situation of artists.
Many artists find themselves in precarious working and living situations in which the planned measures will only bring about minor positive changes.

As an association that supports women in art and culture, we consider gender-equitable language to be important and meaningful. We therefore welcome the use of the internal I in the present draft, but agree with the demand of the IG Bildende Kunst to change the title to "KünstlerInnen-
Social Insurance Fund Act".

(Statement of the IG Bildende Kunst,

http://www.igbildendekunst.at/fileadmin/user_upload/IGBK_Dateien/igbk_on...

13.8.2010, p.7)

In addition to the points mentioned, FIFTITU% agrees with the content of the Austrian Cultural Council's statement in the following arguments:

(1) The KSVF shall, in addition to examining the artists' properties after
The KSVF must also be given the opportunity, in addition to the examination of the artist's
characteristics after submitting an application for suspension of those artists who do not receive a grant from the fund,
Time-consuming procedures by means of a simple application from the artists, without this being directly linked to the notification of suspension.

(2) The possibility of suspension exclusively on the first day of the following month is problematic insofar as in artistic professions the working time periods are quite short (e.g. only by the day), in quick succession, and always
unpredictable (e.g. agreed on the eve of starting work). It would be desirable to have the option of a suspension notification on the day following the application, or a retroactive suspension option.

(3) For the purpose of monitoring, we propose the establishment of an advisory board for the service center as §189e - with the involvement of interest groups representing the arts and
Cultural practitioners.

(4) ad §22a (5): The immediate notification must also be applied to the KSVF (regarding the transmission of the suspension notification to the SVA) and the SVA (regarding the entry in the social insurance data) so that claims to
Unemployment benefit or benefits from compulsory insurance are not affected by delays in transmission.

(Statement of the Austrian Cultural Council p.3

http://kulturrat.at/agenda/agenda/imag/gesetz/stellungnahme_ksvsg_kultur...

13.8.2010)

We also support the following arguments from the Cultural Council's statement:

(1) Artists' Social Insurance Fund Act (K-SVFG)
The necessary changes to the K-SVFG on the occasion of the present amendment to the law should be taken as an opportunity to review the entire K-SVFG or at least to amend it in line with the realities and necessities for social security for artists. We would like to refer here to the immediate demands package of the Austrian Cultural Council,
that unfortunately almost completely survived the last amendment to the K-SVFG:
-> http://kulturrat.at/agenda/sozialerechte/forderungen/ksvfg
In order to fulfill the objective of the upcoming amendment to the law, at least § 2 K-SVFG, the definition of artists, would have to be amended to the effect that it is not artistic aptitude but the profession-specific work situation that is to be used for assessment.

(ibid. p.3)

(3) Representation of artists in the SVA
Due to the social insurance allocation of freelance artists to the SVA since the early 2000s, but at the latest with the establishment
of the Social Insurance Service Center for Artists in the SVA, it has become necessary to include representatives (at least one) in the SVA's self-governing structure. This must also be ensured by law.

(ibid. p.4)

We thank you for your initiative and
remain with kind regards,

FIFTITU%
Networking center for women in art + culture in Upper Austria