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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