institution of social support or protection as per case. A copy of the medical screening and psychosocial support file is transmitted to the Head of the institution where the person resides or is being referred. In all cases the continuity of the medical treatment followed shall be ensured, where necessary. The assessment that a person is vulnerable shall have as only consequence the immediate provision of special reception conditions.’ According to Article 80 (3) of the Asylum Code, ‘In case of doubt, the competent Receiving Authorities shall refer the unaccompanied minor to the age assessment procedures as per the provisions in force. In the case where the abovementioned referral is considered necessary and until the completion of the procedure, special attention should be paid to the particular characteristics of the minor, especially those related to their gender or cultural peculiarities’ (see below). Since the end of 2019, the authority competent for carrying out medical checks has been the National Public Health Organisation (EODY), which was established by L 4633/2019 as the successor of KEELPNO. The number of asylum seekers identified as vulnerable by the Reception and Identification Service in the border regions in 2022 was not provided. The average time between the completion of a 14-day quarantine period imposed upon arrival to all newcomers and the completion of the medical/psychosocial examination/ vulnerability assessment in the border regions in 2022 was not provided. The low quality of the process of medical and psychosocial screening (if any) has remained a source of serious concern. Vulnerabilities are often missed, with individuals going through the asylum procedure without having their vulnerability assessment completed first. As RSA and other civil society organisations have recently reported “Severe delays persist when it comes to conducting vulnerability assessments even after the reception and identification procedure formally ends: The time delay ranges from ten days to longer than three months in some cases. Yet, the Asylum Service and EUAA continue to process asylum claims before individuals have undergone a vulnerability assessment, and routinely disregard or deny special procedural guarantees afforded by EU law, even where they are specifically requested by the applicants in writing and/or orally prior to the interview. They instead insist on completing the interview under the border procedure. The medical cards issued to people undergoing reception and identification procedure do not clearly indicate whether and when a vulnerability assessment was conducted” 453 At the same report, it is also mentioned that “On the one hand, the RIS consistently issues referrals of the individuals concerned to the competent authorities (i.e. the Asylum Service and Hellenic Police) stating that the reception and identification procedure has been completed without a finding of vulnerability. On the other hand, the exact date of the medical check and vulnerability assessment is not marked in the case file of the person. The Foreigner’s Medical Card (Κάρτα Υγείας Αλλοδαπού) issued on the day the reception and identification procedure takes place automatically carries that same date. The card may be amended following an assessment, in which case a re-issuance date is indicated. However, this is not necessarily the date on which the vulnerability assessment takes place. This means that asylum seekers are referred to the Asylum Service with a Medical Card which in most cases precedes the actual medical check and vulnerability assessment.”454 Based on GCR’s information from the field, a lack or complete absence of psychosocial assessment, difficulties in carrying out referrals from RIS to public hospitals, the low quality of the medical screening and psycho-social support, the classification of vulnerability and non-vulnerability and the lack of information on the outcome of the procedure,455 were the main problems concerning the vulnerability assessment in the context of Reception and Identification procedures during 2022. As mentioned in the 453 454 455 Equal Rights Beyond Borders, HIAS Greece & RSA, Τhe state of the border procedure on the greek islands, September 2022, available at: https://bit.ly/40VTZrM, 4. Equal Rights Beyond borders and others, see above, p. 15. For a detailed description of the issues that exacerbate the procedure of the vulnerability assessment see AIDA report on Greece 2021. 108

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