Ε. Conclusions Findings Recommendations The Ombudsman noted that each public policy needs, in addition to a specific operational implementation plan, officials implementing it at each administration level, from the head of the services at the level of revocable general secretary to the practitioner in the field (in this case, at the RICs). The intermediate administration levels, such as services of the ministry that provide guidelines and coordinate the RICs, are extremely crucial for the effective implementation of any policy. The level of administrative coordination and organisation after the explosion of the mixed flows in 2015 and the critical last nine months of 2016 after the EU-Turkey Statement, cannot be considered to have met the demands of the reception of refugees and migrants. The Ombudsman puts forward the need for the organisation of central and regional migration policy services (staffing with permanent and adequate personnel, specific operation instructions, duties and targets), without of course negating the possibility of a flexible scheme which will be related to the increase or decrease of the flows and/or their geographical shift. The clarification not only of the competences of each agency in the temporary accommodation sites across the country (Ministries of National Defence and Migration Policy, UN, NGOs, Police), as well its establishment, in parallel to the few common specifications (housing, medical and other services, etc.) in each site is still a priority, one year after the closing of the borders. The Ministry of National Defence underlines that it is not responsible for the temporary accommodation sites, bearing in mind that its legal competence for the operation of the temporary accommodation sites (Law 4368/2016, Article 96(1)) pertains “exclusively” to the transport, accommodation, food and health care of the hosted refugees and migrants at these temporary sites246 and that their creation and appointment of their administration is the responsibility of the Ministry of Migration Policy. From the Ombudsman’s consecutive visits to temporary accommodation sites across the country, the conclusion is that each agency performs (at best) its proportion of the work, without however an overall coordination with adequate on-site staff by the competent ministry or in any case without having someone who is responsible for the Competences and coordination in the open facilities 246 32 facilities with the direct contribution of the armed forces. 84 coordination and decision making. In short, what is missing is a sense of “ownership” and an overall administration, with a specific plan for each site and common specifications for services. 1.4. Specific issues of shortcomings, coordination, competences and funding The effective protection of unaccompanied minors cannot be realised without the prior implementation of a reliable system for their identification, registration and supervision through the guardianship institution, rendering now necesUnaccompanied sary the establishment of the releMinors vant framework. The seamless and safe operation of the facilities where the unaccompanied minors are living, both inside the safe zones and in the other areas, is an imperative requirement. Therefore, the issue of internal rules of operation of these facilities is an immediate priority, in order to have a uniform treatment to meet the specific needs of the minor. Finally, it is also recommended to limit the time of stay in safe zones and to transport the minors to appropriate facilities, as imposed by the child’s best interest, which is a legislative guide of a broader range for decisions related to minors. The lack of coordination between services of the co-competent ministries, and often within the same ministry, is apparent also in the field of the educational integration of the refugee populations. This dysfunction often results in serious delays in the implementation of the programming, e.g. the transfer of teachers to other positions after their appointment to DYEPs, resulting in gaps, delay in the start of the operation of kindergartens, vagueness and sometimes contradicting instructions to the educational system structures. Frequently, the instructions are different or even conflicting, depending on the Directorate of the ministry that provides them (e.g. as regards the conditions and the method for the enrolment of the third-country nationals in school, the obligation for the enrolment of children above 15 years old).247 We further note the shortages observed in relation to the planning and implementation of the sustainability of the Educational integration 247 The Ombudsman had found in practice that in certain cases, depending on the service and/or the competent department of the Ministry of Education, wherever a question was submitted regarding the enrolment or attendance of the children from third countries in the educational system, a different reply was given, due to the different approach of the issue (e.g. difference of opinion between the Directorate of the Ministry of Education that handles student issues in general and the Team for the Management, Coordination and Monitoring and Education of the Refugees of the same ministry).