that a structural reform of the health care in the penitentiary system is required, allowing for external referrals, in line with the European Prison Rules. Persons deprived of their liberty are entitled to the type and number of medical services paid by the National Health Insurance Fund under the term and procedure of the National Framework Agreement. At the same time the Ministry of Justice has ensured medical care for the inmates in the medical centres and specialized hospitals set up with the prisons and detention facilities. Thus there is overlap and double funding for the health care of the persons deprived of their liberty. Directorate General “Execution of Punishments” (“DGEP”) reports annually understaffing in the medical centres and specialized prison hospitals, which is a bad indicator about the quality of the health care. This fact is largely due to the lack of specialists in the healthcare system in general, on the one hand, and the unwillingness of the Ministry of Justice to improve the working conditions for the specialists in the system, on the other hand. The NPM is of the opinion that the success of the reform in the prison health care is intrinsically connected with improving the living conditions and the social inclusion of inmates. Our recommendations not to allow inmates to act as hospital attendants and to ensure that only medical staff but not guards administer medication to inmates have not been implemented to date. In 2019 the NPM established further lack of publicity regarding some rules in the places for deprivation of liberty due to the persisting practice for these rules to be established by an order of the Minister of Justice and not be issued in a legal act. This concerns the initial distribution of the inmates and the lists with allowed personal belongings. The procedure established in the Administrative Procedure Code to notify the persons concerned about pending issuance of administrative acts (orders) is not followed. The NPM has further established incorrect delegation of powers by the Minister of Justice to the heads of open-type prison hostels, which allows the latter to add items to the list of allowed personal belongings and thus establish unequal conditions for serving time under the same regime. Unfortunately, the statutory requirement set forth in Article 46 of the Execution of Punishments and Remand in Custody Act for the Minister of Justice to present before the Council of Ministers the Ombudsman’s recommendations for closing down places for deprivation of liberty which do not meet the requirements (such as the Sofia Prison, Kremikovtsi Prison Hostel, Keramichna fabrika Prison Hostel in Vratsa) continues not to be met. Meetings with inmates continue to be contactless, despite the renovated facilities in many detention centres. The requirement has further been set forth in a law, which runs contrary to the recommendation of the Committee for the Prevention of Torture in the opposite sense. The Sliven Prison is an exception: meetings there have never been carried out behind bars. Maximum two visits per month are allowed throughout the system for deprivation of liberty. Meetings with lawyers are as a rule carried out behind bars (with the exception of the Burgas Prison). Extended meetings allowed as a bonus, which should take place in family environment, are transformed into contact meetings without bars, in the presence of guards and under video surveillance. This does not allow for any possibility of private life for inmates serving under special or strict regimes and increases their isolation. Wrong use of restraining means (handcuffs) continues within the whole system for execution of punishments when opening external units in medical establishments. Restraining continues for days, without taking into account risk assessment or the health condition of the inmates. 8