我國社會救助法自民國69年制定到現在歷經多次修正，其間調整最低生活費用的計算方式、限縮家庭應計算人口、放寬不動產排除計算的範圍，更於2011年新增中低收入戶的規定，有逐步放寬審核門檻的趨勢。但依數據統計，低收入戶占全國的比例似未依歷來修法而有顯著上升的情形。社會救助法作為社會安全的最後一道防線，生活扶助制度在設計與操作上是否能符合現實情況，篩選出真正需要救助的人是本論文的研究目的。本文分為三部分，第一部分探討社會救助法下低收入戶資格審核、給付金額計算的內容及產生的缺失。第二部分是說明英國相關制度，概論英國社會安全體系以及社會救助制度的發展，並進一步介紹英國資產調查型的給付方案。第三部分則針對兩國的法制進行比較與分析，其中英國以福利促成工作的概念與實踐，有助於整合我國社會救助與就業促進等相關法規。英國資產調查的措施，例如：家庭應計算人口的範圍、收入與資產的核計及給付金額的計算方式，亦可作為我國之借鏡。The Public Assistance Act has been implemented in Taiwan since 1980 and revised many times. The latest revision of the Act in 2011 raises the poverty line for more people to get assistance, relaxes the scope of calculating the number of members living in the household and lists household-owned fixed assets, and adds new welfare measures for middle-to-low-income households. The government noted that with the new system implementing the low-income households will increase, and benefit more people. But according to the statistics, the proportion of low-income household to the total household is not over 2%. Still lots of people are not eligible to apply the payments. The Public Assistance law is perceived as safety net role: as long as people fulfilled certain qualifying conditions, they should not be allowed to fall below a certain minimum standard of living. Whether the framework of living support programme in public assistance act can provide the financial help to those people whose income are below a set minimum level and do not meet their need prompted this study.This thesis has three parts. The first part highlights the regulatory framework of living support programme in Social Assistance Law, as well as how the law is actually enforced in Taiwan. The second part focuses on British regulations which introduced British social security system and the historical development of social assistance. Furthermore, it illustrates the means-tested benefits, such as Income Support, Income-based Jobseeker’s Allowance, Income-related Employment and Support Allowance, Pension Credit and Housing Benefit. The last part does the comparative analysis between Taiwan’s current living support programme and the British means-tested benefits. The concepts of "welfare-to-work" and its application can help integrating the Public Assistance Act and Employment Service Act in Taiwan. Besides, the measure of British means test, such as the range of household, the calculation of income, assets and amount of benefit are worthy of learning for Taiwan.
