longer than three months in some cases. Yet, the Asylum Service and EUAA continue to process
asylum claims before individuals have undergone a vulnerability assessment, and routinely
disregard or deny special procedural guarantees afforded by EU law, even where they are
specifically requested by the applicants in writing and/or orally prior to the interview. They instead
insist on completing the interview under the border procedure. The medical cards issued to people
undergoing reception and identification procedure do not clearly indicate whether and when a
vulnerability assessment was conducted.658
The organisations further report that:
[o]n the one hand, the RIS consistently issues referrals of the individuals concerned to the
competent authorities (i.e., the Asylum Service and Hellenic Police) stating that the reception and
identification procedure has been completed without a finding of vulnerability. On the other hand,
the exact date of the medical check and vulnerability assessment is not marked in the case file of
the person. The Foreigner’s Medical Card (Κάρτα Υγείας Αλλοδαπού) issued on the day the
reception and identification procedure takes place automatically carries that same date. The card
may be amended following an assessment, in which case a re-issuance date is indicated.
However, this is not necessarily the date on which the vulnerability assessment takes place. This
means that asylum applicants are referred to the Asylum Service with a Medical Card which in
most cases precedes the actual medical check and vulnerability assessment.659
Based on GCR’s information from the field, in 2024 and 2025, the main problems arising in the context of
Reception and Identification procedures continued and included the lack or complete absence of
psychosocial assessment, the difficulties in carrying out referrals from RIS to public hospitals, the low
quality of the medical screening and psycho-social support, the classification of vulnerability and nonvulnerability and the lack of information on the outcome of the procedure.660 As mentioned in the Regular
procedure and Fast-track border procedure, many asylum applicants continue being forced to attend their
personal interview with the Asylum Service without a prior assessment of their vulnerability, including
pregnant women.
RSA reported that according to information obtained by the RIS, as of 11 November 2024 in the CCAC
of Kos, Leros, Lesvos, Samos and Chios, there were only 2 doctors in Lesvos (a general doctor and a
gynecologist), 6 psychologists except in the CCAC of Kos, 9 social workers, 25 nurses, 2 midwifes and 2
radiologists in Lesvos and Samos.661
As per the same report:
Critical gaps in medical personnel in the Medical Control and Psychosocial Support Units in the
CCAC therefore persist even after the completion of the PHILOS programme at the end of June
2024 – at that time there were only two doctors on Lesvos and two on Leros for first-line health
care and psychosocial support. The HIPPOCRATES programme implemented by the
International Organisation for Migration (IOM) was launched in September, however, serious
gaps remain in staffing of positions in the CCAC. Staff would not suffice to cover the population
in the facilities even if all advertised positions were filled. […] The absence of doctors entails more
than an inability of the state to deliver absolutely necessary medical care to the thousands of
people living in the island facilities. It also poses a serious barrier to screening procedures which
by law include a medical check and vulnerability assessment prior to the registration of an asylum
application. The lack of medical staff is particularly critical for vulnerable cases with chronic and
serious illnesses, such as diabetic patients. Furthermore, it renders connection with and referral
658
659
660
661
Equal Rights Beyond Borders, HIAS Greece & Refugee Support Aegean, Τhe state of the border procedure
on the greek islands, September 2022, available at: https://bit.ly/40VTZrM, p. 4.
Ibid., p. 15.
For a detailed description of the issues during the procedure of the vulnerability assessment, See ECRE,
AIDA, Country Report: Greece, 2021 Update, May 2022, available at: https://bit.ly/3MRVkLf.
RSA, Refugee facilities on the Aegean islands, 10 December 2024, available at: https://tinyurl.com/s9r9nzaj.
148