ANNUAL REPORTOF UKRAINIAN PARLIAMENT COMMISSIONER FOR HUMAN RIGHTS 78 Due to high level of internal migration in Ukraine, many families do not live at their registered place of residence. It causes problems in accessing general secondary education at the place of actual residence of a child. In addition, a lot of families do not have the opportunity to prove the fact of living on the territory of the education institution. This problem is the most relevant for children living in rural areas in the territories of ATCs that have no schools, and for children living in small settlements. For a long time, the Commissioner has been monitoring the situation with provision of food for children with various types of food intolerances/allergies. There are many cases when the heads of education institutions refuse to provide special dietary food for children with intolerance to gluten and dairy products due to lack of appropriate regulations and funds for buying such food. As a result, children cannot get the food they need to maintain their health, making it difficult or even impossible for them to attend preschools and general secondary schools. CHAPTER 3 Example The Head of the Gluten-Free and Lactose-Free Nutrition in Ukraine Project contacted the Commissioner on behalf of the parents of children in need of special dietary food (city of Kyiv, Kyiv, Ivano-Frankivsk, Khmelnytskyi, Odesa, Rivne oblasts). During the consideration of the appeal, the Commissioner found out that the Institute of Public Health has developed a draft of the Sanitary Regulations for general secondary education institutions26 that recommend to organize dietary nutrition for students with various health disorders. At the same time, these Regulations did not fully regulate dietary nutrition for students with various health disorders. Therefore, in August 2019, the Commissioner sent comments to the Ministry of Health that were taken into account. One of the most common issues is the violation of children’s right to education due to the lack of vaccinations of children who have medical counter-indications against vaccination. In particular, such appeals were received from Vinnytsia, Zhytomyr, Dnipropetrovsk, Poltava, Cherkasy and Odesa oblasts. This is due to the fact that the legislation does not clearly provide for the need and does not define the template for submitting a vaccination document to education, training, health and other children’s institutions. In November 2019, the Commissioner sent a letter to the Prime Minister of Ukraine, emphasizing the need to improve the legislation in order to set forth a clear procedure for providing documents containing information on health condition of a child when enrolling in education institution. Currently, upon instruction of the Prime Minister of Ukraine, the Ministry of Health is making amendments to the template of primary accounting document #086-1/o “Certificate of a student of a secondary school on the results of mandatory preventive medical examination.” 26 http://moz.gov.ua/uploads/1/6845-pro_20180828_1.pdf.