educational programmes (especially the lack of provisions for their consistent attendance and the leak of students, the groups on the move, etc.). The Greek Ombudsman considers an imperative need the stable flow of financing for the Pre-removal Centers from the regular funds of the relevant European fund with the required completion of the relevant internal procedures of the Administration and the central managing authority. The detention conditions in the Preremoval Centers, at least in some of them, must change immediately. Under the weight of the rapid developments, the spotlight of the media and the criticism turned towards other areas of the management of the refugee/migrant issue, leaving the Pre-removal Centers, at least for now, in the shadows. A modern state governed by the rule of law must however manage rights issues regardless of the constantly changing media coverage or criticism. Funding of the Detention Centers 1.5. Concluding remarks The lack of central planning and coordination of the involved agencies and services, in combination with the failure of the immediate and appropriate use of the EU and domestic funds are key reasons for the failure of the State to ensure the fundamental living conditions in all temporary reception and accommodation sites and in the hotspots. The diffusion and overlap of competences, on one hand between the services of the Ministry of Migration Policy itself, and on the other between this ministry and the other involved public agencies and services, international organisations, NGOs, etc., on the subject of meeting the subsistence needs of the refugees and migrants, creates obstacles in the effective and immediate handling of the problems and makes accountability impossible. Despite the over-production of regulations, there is still an absence of institutional arrangement in areas where it is much needed, such as the way of operation and the (re)distribution of competences and coordination in the open accommodation facilities or wherever there is more than one agencies operating in the same site (for example in Moria). The solutions must be flexible in order to adjust to the changes in the conditions (increase-decrease of the flows, changes in the profile of the arrivals, etc.), but also to lay down rules and methods for controlling their implementation. The General Secretariat for Reception of the Ministry of Migration Policy has not been able to date to fulfil its role as a central coordinating and supervisory mechanism for the management of the population that continues to live in the accommodation facilities. The better coordination of the services and agencies that operate in the accommodation facilities and the effective supervision of their operation by the General Secretariat for Reception, must be a top priority for Administration. Moreover, the funding of state agencies and humanitarian organisations by the European Union did not manage to ensure the fundamental living conditions of all the refugees and migrants staying in the country, despite the establishment of services for the absorption and use of the funds available for this purpose. The acceleration of the procedures for the better absorption of the European and national funds, intended for the accommodation of the refugees and migrants residing in the country, must take place immediately. This however must not be to the detriment of the proper management of the funds in order to finance specific needs, or their transparent and published use, making them open to control and criticism. 2. Regulatory framework, shortcomings and deviations in the implementation The way in which the migration/refugee phenomenon was handled at the regulatory level, had two main characteristics: a) lack of clear rules and implementation criteria and b) distance between the provision and the implementation of the legislation. Usually, the lack of clear rules is a result of a multitude of provisions, resulting in an inversely proportional relationship between quality and quantity of the legislative regulations. 2.1. The lack of clear rules The provisions of the law, mainly after the EU-Turkey Statement (Law 4375/2016) pertained to multiple facilities for refugees and migrants, which meant that they were never implemented in practice, as mentioned below. Also, the EU-Turkey Statement has as its main assumption a framework for the fast implementation of readmission for those who do not lodge an asylum application or for those whose relevant application has been dismissed in a final judgement, a framework which was not provided for 85

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