Ε. C  onclusions Findings Recommendations 1. Limited use of funding Lack of coordination Diffusion of responsibilities Except perhaps for the involved state services, all other agencies working on the management of the issue, as well as the Greek Ombudsman, find that what is missing is an authority which will both coordinate and monitor, and to a certain extent, make the decisions. The following observations were made during the on-site inspections of the independent authority at the Reception and Identification Centers (hotspots) and in accommodation facilities: a) Low level of expertise in many involved agencies, and especially their heads with regard to their subject matter. In many cases this became more prominent by their frequent change; b) Zero control and accountability regarding the progress in each unit (e.g. open accommodation centers) and possibly lack of planning;232 c) Exceptionally low capability of response and adaptation to the changing circumstances. 1.1. General comments Coordination at a central or regional level continues to be a first priority and the coordination and management of each unit or each action/intervention a second one. In practice, despite the attempts by many involved parties to coordinate at a local level, the capabilities for the effective handling both of the daily problems, as well as the planning - even if short-term - were usually limited. This was because there was no institutional framework to describe the methods of their cooperation, to define who has decision-making power and the monitoring mechanism. 1.2. The issue Lack of funding was one of the problems which the Greek authorities invoked. of funding supply of funds for the management of the flows from the spring of 2015 and up to this day. The developments that led to the funding deficit are particularly interesting, and we therefore present them below in detail: The now single Asylum Migration Integration Fund (AMIF), competent also for the funding of pre-removal centers and the returns of third-country nationals, could have supplied the relevant funds approved in the summer of 2015 by the European Commission for the 2014-2020 national programme. However, the merger of ministries, with the creation of a “super-ministry” of Interior in January 2015 was followed by the creation of an independent service as a single managing body in the Ministry of Interior in July 2015 headed by a Special Secretary.233 The consequent regulatory acts authorised by this law were then issued, followed by the procedures for the staffing and certification of the managing authority. Law 4375/2016 (Articles 75, 76 et seq.) established in the Ministry of Finance a Special Secretariat for the Coordination and Management of Programmes. The independent service (now the “Special Service for Coordination and Management [...]”) was transferred from the Ministry of Interior to the Ministry of Finance, as the authority responsible for the national programmes and was included under the newly established Special Secretariat. Various regulatory acts and the amendment of the legislation followed three months later, in July 2016,234 with which part of the competences of the responsible authority with relation to the preparation and submission of the payment requests, was transferred to the Special Service responsible for the NSRF.235 In December the European Commission advocated the need for its full activation.236 A typical example of the consequences of these regulations and changes are the Pre-removal Centers (Detention Centers) for third-country nationals. A catalytic role in the bad living conditions and the lack of essential services in the Detention Centers was held by the lack of stable funding, both for the Detention Centers and also the return operations of individuals in detention. Detention was an However, in contrast to the Greek government, the European Union and the European Commission claim immediate and adequate 233 Article 9, par. 6 et seq. of Law 4332/2015. 232 The changes in the number of the flows and the constant movements may make planning harder but not impossible, because they ultimately have to be taken into consideration during the planning. 236 https://ec.europa.eu/neighbourhood-enlargement/sites/near/ files/20161208-4th_report_on_the_progress_made_in_the_implementation_of_ the_eu-turkey_statement_en_0.pdf 234 Article 65(1) of Law 4403/2016. 235 Special Service “Certification and Verification Authority of the Co-financed Programmes” of the General Secretariat for Public Investments and NSRF. 81

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