In most of the inspected institutions the material and technical facilities are obsolete and dilapidated. In some places there is no accessible environment for people with disabilities. The lack of access infringes fundamental human rights and the dignity of the people with disabilities. Maintenance of inaccessible architectural environment is considered discrimination within the meaning of Article 5 of the Anti-Discrimination Act. Another finding of the NPM that causes concern is that very few people from those placed in residential social institutions use community-based services, which may be a reason for potential difficulties with their relocation to new social services and their future inclusion in the community. This circumstance is in conflict with the Common European Guidelines on the Transition from Institutional to Community-based Care. An example of such findings is the second inspection conducted by the NPM of the Home for Adults with Dementia (HAD) in the village of Gorsko Kosovo, Suhindol Municipality. During the inspection and after conversations held with people placed in the institution, the NPM found systemic neglect by the employees. During the previous inspection of that home in 2013 the NPM made recommendations to the Ministry of Labour and Social Policy and to the Mayor of Suhindol Municipality to improve the provided care but most of these recommendations were not implemented. In 2019 until the date of the inspection (9 December 2019), there were 24 death cases in the home; at the end of 2019 they are 28 in total, and the capacity of the home is 60 persons (men and women). The NPM considers that the rate of death incidence is high, even in view of the nature of their diseases, and it is possible to be due to the poor quality of the provided service. During the inspection, there were 57 persons placed there, and many people were confined to bed, most of them in a state of cachexia and restrained. The NPM found a case of recently placed person with bedsores, which had not been treated for 4 days because the nurse was absent. All persons placed in the Home have general practitioner but the NPM found that on admission of new persons the general practitioner did not get familiar with the health status of the patients. The recipes for the medicines from NHIF were prescribed afterwards, based on data obtained from the nurse. Doctors from the Medical Centre in the city of Pavlikeni visit the home twice a month. The NPM recommends that when persons are admitted to HAD, the doctor should promptly assess their health status and if they have leading diseases that require specialised medical assistance and care that cannot be provided in the home, the doctor should refer them to the respective medical establishment. The NPM established bad sanitary and living conditions of the persons placed in the Home and insufficient space in the rooms as compared to the number of persons, which leads to lack of privacy. The Home has two sanitary units and one shower. The corridor of the bedrooms is separated from the administrative part by a door which is locked. In a conversation with the director of HAD, he stated that the corridor and the door to the yard are locked during most of the day. The people placed in the Home do not use any community-based social services and in practice they spent most of their time in their rooms. Even their meals are organised on tables set in the corridor in front of the sleeping rooms. There is a canteen which is on the floor below the sleeping rooms, but without access to people with disabilities and it is not used by them. In this connection the NPM considers that the measures taken are not sufficient to prepare the persons for reintegration in the community. In this regard the NPM should note the adverse judgments by the ECtHR against Bulgaria for violation of Article 3 of the Convention for the Protection of Human Rights and 42

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