Ε. Conclusions Findings Recommendations parallel operation of the DYEPs256 was implemented for the first time - is about to end (e.g. lack of explicit provision for the certification of attendance at a DYEP). As regards EU secondary law, indicative of the failure of the Greek State to specify a framework for the implementation of general rules, is the delay in the harmonisation of the domestic law with Directive 2013/33/EU, recast 29.6.13, on the reception of applicants for international protection. Despite the fact that the transposition deadline had elapsed since 20.7.2015, and only the provisions on detention had been included in Law 4375/2016, the draft law was posted to consultation in October 2016, and had not been submitted to the Greek Parliament since then. The Ombudsman has submitted detailed comments on wording, as well as substantial comments to the competent Ministry of Migration Policy, such as: • T hat there is a clear call for special care in the reception of vulnerable persons requiring international protection, with reference to the concepts of Article 10 of PD 141/2013, • T he addition of the conditions for the individual assess- ment and the necessity test for the implementation of any restrictions to the circulation of asylum seekers in the country, • T he transposition of all guarantees of the Directive re- garding detention (separate detention of asylum seekers from other administrative detainees, their physical and mental health a primary care of those responsible, openair exercise, etc.), • T he rewording of the possibility for the enrolment of mi- nors in school, in order to cover the cases of difficulties in the submission of all necessary documentation and deter any practices of refusal to integrate students in school, • F ree legal assistance also to minors for the defence of their rights before the competent authorities. • T he rewording of the obligation for medical examination regarding the terms, purpose and the right of refusal of the applicant, in order not to be considered as introducing a discrimination between Greeks and third- 256 Reception Facilities for the Education of Refugees. 88 country nationals with regard to taking measures for the protection of their health. • T he provision for medical and pharmaceutical care to be harmonised with the wording of the Directive that provides for the unhindered access of applicants to the necessary medical care. • A ccess of applicants to employment to be allowed also in cases where the completion of the application lodging procedure delays in general for reasons that are not the applicants’ fault, • T he regulation for social protection to specify the relevant allowances, terms of provision, the agency and the procedure, • T he right of appeal to be made more effective, with the designation of the competent Court, any provision for an administrative appeal, etc. Finally, it was noted that for our country’s obligation to establish mechanisms for monitoring and controlling the level of the conditions of the reception of asylum seekers, and in order to inform the European Commission, it would be useful to include the Greek Ombudsman as the primary independent constitutional institution, whose competence already covers the external monitoring of the reception conditions according to the Directive. As regards EU law, it should be noted that the surge in the migration-refugee flows caused diversions in the implementation of the regulatory framework, not only of the Greek State, but also at EU level. The main example of law by exception is the EU-Turkey Joint Statement of 18 March 2016, which is not an EU agreement with a third country, but is invoked in a series of acts: decisions for deportation due to readmission, readmission operations with the participation of FRONTEX, the decision for the appointment of a representative of the President of the European Commission in Greece for coordinating the implementation of the EU-Turkey Statement,257 the quarterly reports of the European Commission on the progress of its implementation, etc. The European 257 “Following the agreement reached today between the European Union and Turkey to return all new irregular migrants crossing from Turkey into the Greek islands as from 20 March 2016.” http://europa.eu/rapid/press-release_IP-16942_en.htm