1. Decisions of the Federal Social Court of March 9, 2016 on basic security for job seekers (SGB II)
1.1 – BSG, judgment of March 9, 2016 – B 14 AS 20/15 R
Offsetting of 30% is compatible with guaranteeing a humane minimum subsistence level!
Guiding principle (editor)
The legal authorization to offset 30% of the standard requirement over up to three years is compatible with the constitution.
Source: juris.bundessocialgericht.de
1.2 – BSG, judgment of March 9, 2016 – B 14 AS 3/15 R
Basic security for job seekers - Legality of the request to apply for an early old-age pension - Final regulation of the Unfairness Ordinance - Discretionary decision of the basic security provider - Constitutionality - Not in need of help due to pension receipt within the meaning of SGB XII
Guiding principle (based on the BSG judgment of August 19, 2015 - B 14 AS 1/15 R)
1. The unfairness regulation conclusively regulates the exceptional circumstances in which those entitled to benefits are not obliged to claim an early retirement pension.
2. The request to those entitled to benefits to apply for a priority benefit is at the discretion of the job centers.
Source: juris.bundessocialgericht.de
1.3 – BSG, judgment of March 9, 2016 – B 14 KG 1/15 R
When determining the maximum income limit for the child allowance in accordance with Section 6a BKGG, should the accommodation cost shares of all children living in the claimant's household be taken into account, regardless of whether they belong to the needs community within the meaning of SGB 2?
No!
Note to the court
1. When calculating the maximum income limit, the costs of accommodation and heating (KdUH) must be adjusted in advance using the head part method for those shares that are attributable to those who do not belong to the community of needs.
2. Only the remaining KdUH of the community of needs, consisting of the plaintiff and her other children Y and K, are to be divided in the ratio that results from the Federal Government's report on the level of the subsistence minimum for adults and children.
Source: juris.bundessocialgericht.de
2. Decisions of the Federal Social Court of December 3, 2015 on basic security for job seekers (SGB II)
2.1 – BSG, judgment of December 3, 2015 – B 4 AS 47/14 R
Unemployment benefit II - accommodation and heating - electricity costs for operating a heating system - not part of the standard requirement - no separate recording - estimate - recourse to civil law case law.
Electricity costs for a heating system must be taken into account as accommodation costs.
Guiding principle (editor)
The BSG senates responsible for basic security for job seekers have found that the assumption of the costs of the operating electricity of the heating system must generally be included in the calculation of the appropriate heating costs (see BSG judgment of July 7, 2011 - B 14 AS 51/10 R - No. 15; BSG decision of May 26, 2010 - B 4 AS 7/10 B - No. 8; BSG judgment of September 19, 2008 - B 14 AS 54/07 R - No. 18).
Source: juris.bundessocialgericht.de
3. Decisions of the state social courts on basic security for job seekers (SGB II)
3.1 - LSG NSB, judgment of October 6th, 2015 - L 6 AS 1349/13 - Appeal pending at the BSG under the ref.: B 14 AS 58/15 R
Principle Dr.
Manfred Hammel 1. Costs incurred due to a necessary move for relocating the telephone and internet connection of an employable person entitled to benefits as well as for the postal forwarding application can be claimed to the responsible job center with reference to Section 22 Paragraph 6 Sentence 1, 1. HS SGB II become.
2. These are neither transport costs for the actual moving goods nor other expenses directly related to the change of residence (such as the disposal of furnishings that have become unusable). However, these “re-registration costs” inevitably go hand in hand with a move, are directly caused by this move and are also necessary in order to guarantee and ensure that the exceptionally disabled applicant can be reached by post and telephone - also in relation to social benefit providers.
Sa: Costs for changing the telephone and internet connection as reimbursable moving costs
The LSG Celle-Bremen has decided that in the case of a move for which the job center has given an assurance (with regard to the expenses for the new accommodation), the costs for changing the telephone and internet connection are also included in the “actual” moving costs meaning count.
Source: Press release from LSG Celle-Bremen v. March 9, 2016 with full text of the decision: www.landessocialgericht.niedersachsen.de
3.2 – Baden-Württemberg State Social Court, judgment of May 21, 2015 – L 7 AS 980/12
Guiding principle (Juris)
The calculation according to Heikos 2.0 is also not suitable for determining the specific, individually appropriate heating costs. There is therefore no reason to deviate from the test based on a limit value developed in the case law of the BSG.
Source: socialcourtsability.de
Legal tip:
Likewise LSG Niedersachsen-Bremen, judgment of April 3, 2014 – L 7 AS 786/11; legally binding after the rejection of the non-admission complaint by the local basic security provider by decision of the BSG of December 29, 2014 - B 4 AS 179/14 NZB.
3.3 – State Social Court of North Rhine-Westphalia, decision of February 15, 2016 – L 7 AS 150/16 B ER – legally binding
The applicant is entitled to the standard requirements according to SGB II, taking into account the amount for food and non-alcoholic drinks included in the standard benefit, because the exclusion of benefits in Section 7 Paragraph 4 Sentence 1 SGB II does not apply due to his stay in the specialist clinic, because the requirements of Section 7 Paragraph 4 Sentence 3 SGB II have been credibly demonstrated.
Guiding principle (editor)
1. In contrast to p. 1, anyone who is expected to be in a hospital for less than six months will receive benefits according to this book (No. 1). The return exception can only be assessed uniformly and solely from the perspective of admission to the hospital.
2. If the hospital accommodation is expected to last less than six months, the benefit system of SGB II remains. If the stay lasts more than six months, benefits are paid in accordance with SGB XII. In the event that a therapy prognostically lasts less than six months, but a similar measure characterized by a substantive, targeted connection took place immediately beforehand, both stay periods are added together (termination report 48/15: BSG, judgment of November 12, 2015 - B 14 AS 6/15 R; LSG Hessen, judgment of January 21, 2015 - L 6 AS 361/12).
3. According to the case law of the BSG, the decisive factor is the prognosis at the start of the accommodation and therefore not the approval of the pension insurance provider.
4. The reason for the order was credibly given by the applicant, because the EUR 39.90 per month paid by the SGB also LSG North Rhine-Westphalia, resolution of May 29, 2015 - L 19 AS 684/15 B ER - with an approval from the social welfare provider of EUR 107.73 per month; aA LSG North Rhine-Westphalia, resolution of December 17, 2015 - L 2 AS 1866/ 15 B ER).
Source: socialcourtsability.de
Legal tip:
The same result: SG Augsburg, judgment of December 7th, 2015 - S 8 AS 1018/15 and LSG NRW, decision of May 29th, 2015 - L 19 AS 684/15 B ER, nv
3.4 - State Social Court of North Rhine-Westphalia, decision of February 15, 2016 - L 7 AS 1681/15 B - legally binding
Approval of legal aid, because the question of whether and, if so, under what conditions, travel costs to carry out methadone treatment as an additional requirement in accordance with Section 21 Paragraph 6 SGB II must be covered by the provider of basic security for job seekers has not been clarified, contrary to the social court's assumption .
Guiding principle (editor)
1. It is true that the BSG decided in its judgment of May 26, 2011 - B 14 AS 146/10 R that the costs of medical treatment for those entitled to basic social security with statutory health insurance are covered either by the system of SGB V or (in addition) are covered by the control power. Due to the need for a supply of non-prescription medicines, there would generally be no unavoidable ongoing needs.
2. However, this fundamental statement is contradicted by the (more recent) decision of the BSG of December 12, 2013 - B 4 AS 6/13 R. Here the BSG stated that a medical need could be unavoidable within the meaning of the basic security law because of the subsidiarity of this benefit system if the statutory health insurance company or third parties were not obliged to provide the service, i.e. to cover the need.
3. If expenses for medically necessary treatment are excluded from the catalog of benefits of statutory health insurance, a claim to additional benefits could arise in principle. The conditions under which this must take place have not yet been conclusively clarified.
4. In its judgment of March 19, 2015 - L 6 AS 1926/14, the LSG North Rhine-Westphalia has legally decided that travel costs in connection with methadone substitution under medical supervision are an unavoidable special need within the meaning of Section 21 Paragraph 6 SGB II (aA LSG Saxony-Anhalt, resolution of September 25, 2013 - L 7 AS 83/12 NZB).
5. From a factual point of view, the legal dispute needs to be further clarified with regard to the affirmation of a fundamental ability to cover the claimed travel costs with regard to the further requirements of Section 21 Paragraph 6 SGB II. This applies in particular to the question of the irrefutability of the need.
6. According to Section 21 Paragraph 6 Sentence 2 SGB II, the additional need is (only) unavoidable if it is not covered by donations from third parties and taking into account the savings opportunities of those entitled to benefits. According to this, the increased travel costs can only be covered if there are no adequate treatment options available at the plaintiff's place of residence or if the plaintiff cannot be referred to them for individual reasons.
Source: socialcourtsability.de
3.5 – State Social Court of North Rhine-Westphalia, decision v. 02/01/2016 – L 7 AS 2174/15 B – legally binding
Non-functioning heating - Heating of the apartment with electricity instead - Timely notification to the job center - Claim for damages against the landlord in accordance with Section 536 a of the German Civil Code (BGB) - No funds available - Conversion of a loan in accordance with Section 24 Paragraph 1 into a grant in accordance with Section 22 Paragraph 1 SGB II – Transfer of claims § 33 SGB II
The legal basis for assuming the electricity costs required to heat an apartment is not - as the job center wrongly believes - Section 24 Paragraph 1 SGB II, but rather 22 Paragraph 1 SGB II.
Contractual claims for damages also fall under the provisions of Section 33 SGB II.
Guiding principle (editor)
1. The assumption of electricity costs does not conflict with the fact that the applicant may have a claim for damages against the landlord in accordance with Section 536 a of the German Civil Code (BGB). The applicant's need existed in the month due.
2. A possibly existing claim for damages, which has yet to be asserted on the merits and is uncertain in terms of enforceability, does not represent any ready means (see LSG Sachsen-Anhalt, decision of October 27, 2015 - L 4 AS 652/15 B ER) with which the person affected can meet their needs.
3. The fact that the applicant was entitled to reduce the rent also does not eliminate the claimed need for heating costs, especially since the reduction in accommodation costs was immediately communicated to the job center and passed on to it. The interests of the JC are protected by the fact that the applicant's claim for damages is transferred to it in accordance with Section 33 SGB II. Contractual claims for damages also fall under this regulation.
Source: socialcourtsability.de
3.6 – State Social Court of North Rhine-Westphalia, judgment of 01/18/2016 – L 19 AS 411/15
Need for separate revocation decisions – The BSG has expressly made it clear that a formal change decision is required in accordance with Section 48 SGB X.
Guiding principle (editor)
1. The case law of the Federal Social Court must be followed, according to which §§ 31a, 31b SGB II in the legal situation existing as of April 1, 2011 do not regulate that the determination of the start, duration and amount of a reduction in unemployment benefit II At the same time, the binding effect of conflicting approval notices in the sense that they can be dealt with in another way (Section 39 Para. 2 SGB X) is no longer applicable.
2. Rather, there is (still) a need for a formal implementation of the identified reduction through a formal change to conflicting approval notices in accordance with Section 48 SGB B 14 AS 20/14 R).
3. In this respect, the provisions of §§ 31a, 31b SGB II are not regulations with a self-executing character nor are they special regulations to § 48 SGB X.
Source: socialcourtsability.de
3.7 – State Social Court of North Rhine-Westphalia, decision v.
02/24/2016 - L 19 AS 1834/15 B ER - and - L 19 AS 1835/15 B - legally binding Greek applicant is entitled to assistance with living expenses according to Section 23 Paragraph 1 Sentence 3 SGB XII in the amount of 80% of the standard need level I, because the applicant has been supported by Caritas with food, which he will not have to pay for afterwards.
Guiding principle (editor)
1. Section 23 Paragraph 3 SGB XII does not stand in the way of the applicant's claim to benefits. It can be left open whether the applicant, as a citizen of an EFA state, still had a right of residence to look for work within the meaning of Section 2 Paragraph 2 No. 1a FreizügG/EU during the period at issue in the dispute (cf. BSG deadline report of December 3, 2015 on B 4 AS 59/13 R).
2. Even if the applicant is a Union citizen without a material right of residence, he does not have a legal right to assistance with living expenses in accordance with Section 23 Para . 1 SGB , resolution of February 11, 2016 - L 3 AS 668/15 B ER, SG Dortmund, resolution of February 11, 2016 - S 35 AS 5396/15 ER).
Source: socialcourtsability.de
3.8 – State Social Court of North Rhine-Westphalia, decision v. 01/28/2016 – L 7 AS 2055/15 B ER – legally binding
Applicant complains that the sanction imposed goes too far insofar as it covers accommodation costs - complete loss of entitlement to benefits in accordance with Section 31a Paragraph 1 Sentence 3 SGB II
Guiding principle (editor)
1. According to this regulation, unemployment benefit II will no longer apply in the event of any further repeated breach of duty (in the sense of a breach of duty, cf. Senate judgment of January 29, 2015, L 7 AS 1306/14) in accordance with Section 31 SGB II.
2. The applicant only complained about the scope of the sanction, including its extension to the costs of accommodation and heating. But the latter is not illegal.
3. The elimination according to Section 31a Paragraph 1 Sentence 3 SGB II extends to the entire unemployment benefit II. This includes the standard requirements, additional requirements and the need for accommodation and heating (Section 19 Paragraph 1 Sentence 3 SGB II). The Senate has no constitutional concerns because it is up to the person concerned to fulfill their obligation to cooperate and thus prevent sanctions from being imposed. If he considers a requested act of cooperation to be unlawful, he has legal recourse - including urgent legal protection.
Source: socialcourtsability.de
4. Decisions of the social courts on basic security for job seekers (SGB II)
4.1 – Berlin Social Court, judgment of
September 7, 2015 - S 91 AS 27859/12 - legally binding Guiding principle (Juris)
1. On the right to sue when asserting a temporary community of needs
2. Within the meaning of Section 7 Paragraph 3 No. 4 SGB 2, the child of a member of a community of need is only someone who is either their biological child or is legally considered to be their child.
3. A broader interpretation of the provision is not necessary if those entitled to benefits actually perform the tasks of parents and have a family-like relationship with the child who is not biologically or legally their child (“social parents”). This applies in the context of temporary communities of need as well as if those affected live together permanently.
4. “Social children” are not a member of their “social parent’s community of need” as a partner falling under Section 7 Paragraph 3 No. 3 c) SGB 2.
5. The factual responsibility for the needs of the “social child” included in the standard needs does not allow these to become the “social parent’s” own needs, which could be taken into account as additional needs.
Source: socialcourtsability.de
4.2 - Berlin Social Court, judgment of November 30, 2015 - S 91 AS 1484/15 - legally binding - appeal was permitted
To interpret the legal consequences of Section 22 Paragraph 1 Sentence 2 SGB II in the event of a move while simultaneously establishing a new community of needs
Guiding Principle (Juris)
1. If a room in an apartment is used exclusively or predominantly for commercial purposes (study), the proportionate expenses allocated to this room are not expenses to secure the existential needs of accommodation and heating and therefore not as costs for Accommodation and heating within the meaning of Section 22 Paragraph 1 Sentence 1 SGB 2.
2. If the composition of the community of needs changes at the same time in the event of an unnecessary move, the legal consequence of Section 22 Paragraph 1 Sentence 2 SGB 2 is to be interpreted as meaning that the recognized need for accommodation and heating costs after the move for each individual beneficiary of benefits is at most is limited to the amount that the individual beneficiary viewed as his or her individual needs for accommodation and heating costs before the move.
This amount, which limits the entitlement to benefits, can be different for each beneficiary.
3. The view according to which those entitled to benefits after an unnecessary move with a change in the number of people in the community of needs in accordance with Section 22 Paragraph 1 Sentence 2 SGB 2 should be limited to benefits in the amount of their head part of the costs of the accommodation that they could reasonably have obtained , has no legal basis.
Source: socialcourtsability.de
5. Decisions of the state social courts on social assistance (SGB XII)
5.1 – LSG Schleswig-Holstein, judgment of June 12, 2015 (ref.: L 9 SO 47/12):
Principle Dr.
Manfred Hammel 1. A workshop for disabled people cannot assert individual claims from workshop employees for appropriate remuneration to the responsible social welfare agency as the cost bearer for measures in accordance with Sections 53 ff. SGB XII.
2. Taking into account the triangular relationship under social assistance law between the recipient of assistance, the institution and the social assistance provider, a direct claim to payment by the institution from the public provider can in principle be recognized. However, this claim to payment may not go beyond the assumption of debt declared to the recipient of assistance when the costs are assumed.
3. Objections regarding the assumption of costs, based on the reason and the amount, may only be raised by the recipients themselves against the funding body.
4. In relation to the social assistance provider, only the individual recipient of assistance has a right to reimbursement of further costs due to the highly personal entitlement to integration assistance in accordance with Sections 53 ff. SGB XII.
5. If a facility provider does not agree with the regulations made as part of the remuneration agreement in accordance with Section 75 Paragraph 3 Sentence 1 No. 2 SGB Workshop employees can be requested from the responsible social welfare agency.
6. This remuneration agreement only covers the framework conditions for the claim that the individual recipient of assistance can assert against the social welfare provider.
7. The facility is only entitled to payment on the basis of the social welfare provider's assumption of responsibility in the form of the assumption of costs for the individual person in need of assistance through the approval notice.
5.2 – Schleswig-Holstein State Social Court, judgment of March 18, 2015 – L 9 SO 41/12 – legally binding
Social assistance – basic security in the event of reduced earning capacity – admission to a workshop for disabled people
If the technical committee of a workshop for disabled people is in favor of admitting a disabled person into the facility and the person concerned works in a WfbM, he or she is considered to be fully incapacitated within the meaning of the fourth chapter of SGB XII.
Note from the court
1. According to the will of the legislature, as expressed in Section 136 Para. 1 SGB IX, the workshop for disabled people accommodates various groups of people who receive support for their economic performance in accordance with their abilities.
2. Because of the abstract possibility of achieving a transition to the general labor market in the entry and vocational training areas in accordance with Section 136 Paragraph 1 Sentence 3 SGB IX, the legal assessment of Section 45 Sentence 3 No. 3 SGB XII, which permanent full disability for workshop employees. According to the opinion of the specialist committee of a workshop on admission, they are considered to be permanently and completely disabled (LSG Niedersachsen-Bremen, judgment of February 26, 2009 - L 8/13 SO 7/07; LSG Berlin-Brandenburg, judgment of August 21, 2008 - L 23 SO 269/06; Schellhorn in Schellhorn/Schellhorn/Hohm, Commentary on SGB XII, 18th edition 2010, § 41 Rn. 16; Blüggel in jurisPK-SGB . 93; aA Wahrendorf in Grube/Wahrendorf, Commentary on SGB XII, 4th edition 2012, § 41, Rn. 37; Kirchhoff in Hauck/Noftz, SGB in accordance with Section 43 Paragraph 2 Sentence 3 No. 1 SGB VI is considered to be fully incapacitated.
5.3 – State Social Court of North Rhine-Westphalia, decision v. March 7, 2016 – L 12 SO 79/16 B ER – legally binding
Bulgarian citizens are not entitled to assistance with subsistence according to the 3rd chapter of SGB R, B 4 AS 44/15 R), from December 16, 2015 (B 4 AS 15/14 R, B 14 AS 18/14 R, B 14 AS 33/14 R) and from January 20, 2016 (B 14 AS 15 /15 R, B 14 AS 35/15 R)
Guiding principle (editor)
1. The assessment of earning capacity alone is the decisive demarcation criterion and consequently determines the responsibility of the respective provider. Section 21 of the SGB Decision of February 11, 2016 - S 35 AS 5396/15 ER -).
2. Both the BSG's interpretation of Section 23 SGB XII and Section 21 Sentence 1 SGB XII contradict the clear will of the legislature expressed in the legislative motives.
3. It is not understandable how the BSG, in applying Section 23 Paragraph 1 Sentence 3 SGB
4. The exclusion of EU foreigners whose right of residence arises solely from the purpose of looking for work or who have no material right of residence at all, like the applicants, does not violate Article 1 Paragraph 1 and Article 20 Paragraph 1 GG.
5. By excluding benefits for EU foreigners who derive their right of residence solely for the purpose of looking for work, the legislature has standardized the subordinate status of the German social benefit system to that of the country of origin. This is not constitutionally objectionable (as a result: LSG Rhineland-Palatinate, decision of November 5th, 2015 - L 3 AS 479/15 B ER -; dated February 11th, 2016 - L 3 AS 668/15 B ER - ; SG Dortmund, resolution of November 23, 2015 - S 30 AS 3827/15 ER; Senate, resolution of August 20, 2015 - L 12 AS 1188/15 B ER -).
Source: socialcourtsability.de
a. Opinion: Prof. Dr. Ulrich Weimer, presiding judge at the BSG in his contribution: Doubtful decisions on basic social security benefits for EU citizens:
Courts may not deny legal protection, printed in Social Security 2/2016, 44
Sa:
“Fundamental judgment of the BSG: Social assistance for Union citizens” by Attorney Eva Steffen, Cologne
Source: ANA-ZAR, issue 1/2016, 2 - tinyurl.com (PDF)
dav-auslaender-und-asylrecht.de
5.4 - LSG Baden-Württemberg judgment of February 25, 2016 - L 7 SO 3734/15
Guiding principle (Juris)
1. The legality of a request for information according to Section 117 Paragraph 1 Sentence 1 SGB XII does not require that the recipient of assistance is actually and demonstrably entitled to maintenance. Only if a civil law claim is obviously excluded according to objective, substantive law can a clearly pointless request for information that has nevertheless been issued be revoked (in this case denied).
2. There is no right to information in accordance with Section 117 Paragraph 1 Sentence 1 SGB
Source: dejure.org
5.5 - LSG Baden-Württemberg judgment of February 25, 2016 - L 7 SO 3588/14
Guiding principle (Juris)
With regard to the forecast decision to be made as to where a person has established their habitual residence, no different criteria apply to homeless persons (following BSG, judgment of March 24, 2015 - B 8 SO 20/13 - juris para. 13, 17)
Source: socialcourtsability.de
5.6 – Baden-Württemberg State Social Court, judgment of 02/25/2016 – L 7 SO 262/15
Guiding principle (Juris)
1. Court receipt stamps regularly provide evidence of the time and place of receipt of a letter or pleading. The evidence provided by the receipt stamp can be refuted in accordance with Section 418 Paragraph 2 ZPO (in this case denied).
2. When it comes to the question of whether the person obliged to undertake the funeral can be expected to bear the necessary costs of the funeral (§ 74 SGB ).
Source: socialcourtsability.de
6. Decisions of the state social courts from other codes, but in connection with SGB II/SGB XII
6.1 – Schleswig-Holstein State Social Court, judgment of 01/19/2016 – L 7 R 181/15 – The appeal was allowed
The transition from basic security benefits according to SGB II to a (needs-covering) old-age pension is a mass phenomenon, so the question of an existing claim to reimbursement for the transition month also arises in many other cases
Guiding principle (editor)
1. The basic security provider has no claim to reimbursement against the pension insurance provider if the pension is paid out to the insured person on time.
2. Continuing payment of basic security in the form of a loan in the transitional month appears to be clearly preferable to constructing a claim for reimbursement, especially since this is more in line with the dogmatics of basic security law, because if there is certain knowledge of the inflow of income that meets needs in the respective month of need, the basic security provider may legally no longer provide any subsidies at all due to a lack of need for assistance (but Behrend is different in jurisPK-SGB II, § 24 Rn. 108; Berlin-Brandenburg State Social Court, decision of August 11, 2010, L 5 AS 1010/10 B PKH).
Source: socialcourtsability.de
7. No right to change fund for social assistance recipients
Kassel (law). Social assistance recipients are only allowed to freely choose their health insurance once. After that, however, they are not entitled to a change in health insurance, the Federal Social Court (BSG) in Kassel ruled on Tuesday, March 8, 2016 (ref.: B 1 KR 26/15 R). According to the law, the original election was “final.”
Source: www.juraforum.de
8. New technical information from the Federal Employment Agency on Section 7 SGB II - Contribution by Claudius Voigt, GGUA
The Federal Employment Agency has published new technical information on Section 7 SGB II. These are binding for Jobcenter-gE (joint facilities), but not for Jobcenter-zkT (option municipalities).
On over 80 pages, the BA presented the eligibility requirements for SGB II benefits for foreigners in great detail, both for third-country nationals and for Union citizens. In many places the Federal Employment Agency has tightened its previous legal opinion, and in some other places it has changed, supplemented or clarified based on case law. The social courts are not bound to the technical information. In many cases of social counseling, the information can provide arguments for enforcing benefit claims for clients. Parts of the new information will be presented and evaluated below.
Source: www.fluechtlingsinfo-berlin.de
Author of the case law ticker: Willi 2 von Tacheles – alias Detlef Brock
Source: Tacheles legal ruling ticker, www.tacheles-socialhilfe.de
