place on the day following the expiry of validity of the residence title, in the absence of renewal, extension or withdrawal of the status of international or temporary protection”. 1509 According to Guidelines provided by the Registration Department of the Insurance Directorate of the General Directorate for Contributions, “the service of third country nationals for the issuance - activation - re-activation of AMKA will be provided by the Ministry of Migration and Asylum by 22.12.2024. Until this date, third country nationals will be served by e-EFKA and Citizens' Service Centres” (Κέντρα Εξυπηρέτησης Πολιτών - KEPs).1510 It should be noted that, in the Guidelines of the Ministry of Labour and Social Affairs, there are neither templates of residence permits of beneficiaries of international protection issued by the Headquarters of the Hellenic Police, nor templates of certificates of submission of renewal applications of residence permits for both beneficiaries of international protection granted international protection status either by the Asylum Service or the Headquarters of the Hellenic Police. 1511 The Ministerial Decision 12184/2022 that came into effect on 16 March 2022 provided that the prescription of medicines, therapeutic operations and diagnostic examinations for patients without health insurance will be possible, only by doctors of public hospitals and Primary Health Care structures.1512 This Ministerial Decision affected the vast majority of beneficiaries of international protection, since most of them do not have health insurance and will therefore no longer be able to visit private doctors. As of 1 July 2022, it is impossible for private doctors to prescribe the uninsured patients under Article 38 Law 4865/2021,1513 in conjunction with Ministerial Decision (M.D) 30268/30-05-2022.1514 The exception from this provision are (a) uninsured people up to 18 years old; (b) uninsured patients with intellectual or mental disabilities, autism, down syndrome, bipolar disorder, depression with psychotic symptoms, cerebral palsy or severe and multiple disabilities, amputees who receive the extra-institutional allowance with a disability rate of 67% or more, as well as those who have a certified disability of 80% or more, for any condition; (c) uninsured patients with conditions included in the list of diseases for which medicinal products are administered with reduced or no contribution by the insured person, including patients suffering from AIDS; (d) the prescription of all vaccines without exception to all uninsured patients. 1515 All the above apply to every person residing legally in Greece and there is no specific provision for beneficiaries of international protection. As of March 2023, the “Evangelismos” General Hospital of Athens, the “Aiginitio” Hospital and “Dromokaitio” Psychiatric Hospital of Athens had no interpreters. Conversely, the “Dafni” Psychiatric Hospital of Athens only had interpretation for Arabic and the “Alexandra” General Hospital of Athens covered Arabic, Farsi, French and Lingala. 1516 Thus, access to health care is extremely difficult is for beneficiaries of international protection. According to a survey conducted by UNHCR from July 2022 until June 2023 with 424 beneficiaries of international protection “[t]wenty-nine per cent of respondents had difficulty accessing healthcare because of language barriers, challenges to securing appointments and lack of information on the national health care system”, while the number of households that have at least one member with specific needs is 36%. 1509 1510 1511 1512 1513 1514 1515 1516 Article 7(2) JMD Φ80320/109864/2023. See RSA and Stiftung Pro Asyl, Beneficiaries of international protection in Greece, Access to documents and socio-economic rights, March 2024, available at: https://bit.ly/3KT41TT, p. 20. Registration Department of the Insurance Directorate of the General Directorate for Contributions, Παροχή Οδηγιών για την απόδοση και τη λειτουργία του Αριθμού Μητρώου; Κοινωνικής Ασφάλισης (ΑΜΚΑ), prot. no. 530132, 10 April 2024, available in Greek at: https://bit.ly/3xmJ3ts. Ministry of Labour and Social Affairs, Οδηγίες για την απόδοση και τη λειτουργία του Αριθμού Μητρώου Κοινωνικής Ασφάλισης (ΑΜΚΑ), prot. no. Φ80320/25192, 01 April 2024, available in Greek at: https://bit.ly/3RBmkRb. Ministerial Decision 12184/2022, Gov. Gazette 899/B/28.2.2022. Law 4865/2021, Gov. Gazette 238/A'/04-12-2021. Ministerial Decision 30268/30-05-2022, Gov. Gazette, B', 2673/31.05.2022. Article 11(1) Ministerial Decision 30268/30-05-2022 Gov. Gazette 2673, Β', 31-05-2022. RSA and Stiftung Pro Asyl, Beneficiaries of international protection in Greece, Access to documents and socioeconomic rights, March 2023, available at: https://bit.ly/3KT41TT, p. 26. 292

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