44  Ioanna Kotsioni j Detention of Migrants and Asylum-Seekers 2009 and 2014. This was MSF’s most extensive programme in immigration detention centres, in which nearly 10,000 individual medical and mental health consultations were provided.12 The article contains reflections on the implications of this situation for humanitarian action, made on the basis of policy engagement, experience on the frontlines, and a deep engagement in the everyday dilemmas of aid. The structure of the article is as follows. The next, second section examines the proliferation of detention in recent years. The third section looks more specifically at detention in Greece between 2009 and 2014, which is the period of concern for this article.13 The fourth section considers the impact detention has on the health of migrants and refugees, and outlines MSFs activities in detention centres. The fifth section considers the dilemmas, debates, and implications of working in detention centres for humanitarian agencies, and the sixth section looks at the consequences of advocating more forcefully for the rights of detainees – something that has particular implications for a humanitarian aid agency. The main points are brought together in a conclusion. 2 . P R O L IF E R A T IO N O F IM M IG R A T I O N D E T E NT IO N In the course of the last two decades, the detention of migrants and asylum-seekers has become institutionalised in migration management frameworks and relevant legal instruments, and the practice has proliferated. In the European Union (EU), the administrative incarceration of migrants awaiting return and asylum-seekers awaiting decision on their asylum claim was legitimised by the EU Returns Directive and the EU Reception Conditions Directive,14 although both Directives pose stringent preconditions on detention. In the United States (US), congressional appropriations laws have included a quota on immigration detention beds since 2009, mandating the Department of Homeland Security to maintain no fewer than 34,000 immigration detention beds filled on a daily basis.15 No other law enforcement agency is subject to a statutory quota on the number of individuals it must detain.16 Alongside the privatisation of the detention system, this has made the incarceration of migrants a lucrative business in countries where it is outsourced to private agencies, such as the US and the UK. In the US, during 2012 alone, 478,000 people were detained in 250 detention 12 MSF, Migrants in Detention – Lives on Hold; MSF, Invisible Suffering. 13 Following the change of administration, after the national elections of Jan. 2015, the widespread and lengthy use of immigration detention stopped. The population of detained migrants has been drastically reduced and the length of detention does not exceed six months. 14 See Directive 2008/115/EC of the European Parliament and of the Council of 16 December 2008 on common standards and procedures in Member States for returning illegally staying third country nationals, OJ L 348/98, 24 Dec. 2008; and Directive 2013/33/EU of the European Parliament and of the Council of 26 June 2013 laying down standards for the reception of applicants for international protection (recast), OJ L 180/96, 29 Jun. 2013. This last Directive replaces Directive 2003/9/EC (OJ L 31/18, 6 Feb. 2003), except for the United Kingdom and Ireland which are still bound by the 2003 version. 15 Department of Homeland Security Appropriations Act, 2010. 111 (H.R. 2892). 16 National Immigrant Justice Center (NIJC), Immigration Detention Bed Quota Timeline, Mar. 2014, available at: http://immigrantjustice.org/sites/immigrantjustice.org/files/Immigration_Detention_Bed_ Quota_Timeline_2014_03_1.pdf (last visited 22 Feb. 2016).