IMPLEMENTATION UNDER NATIONAL LAW 2.6.6. LACK OF SPECIALISED STAFF A prominent finding across all six partner countries and beyond has also been a lack of specialised staff – medical staff, psychologists, psychiatrists – in prisons as well as psychiatric institutions. For example, in one detention facility in Austria, medical care was not available after 3:30 pm or on weekends. In another detention facility, three psychiatrists were available for a total of 22 hours per week for an estimated 800 detainees, more than 100 of which were in preventive detention.244 Furthermore, experts in Austria have reported that prisons (and also special prison departments for persons with intellectual and/or psychosocial disabilities) do not have sufficient staff from the general health field and still primarily depend on prison staff (carrying weapons).245 This was also confirmed by the latest CPT report in 2023. The Bulgarian Ombudsman Institution, in its 2020 Annual report, noted that psychiatric hospitals exhibited insufficient numbers of doctors, nurses and paramedics, creating conditions for untimely and low-quality treatment of patients, as well as risk in terms of monitoring and care for patients with aggression and auto-aggression.246 In prisons, prison officers are usually not trained to interact with persons with intellectual and/or psychosocial disabilities and are not able to provide specialised care, also due to constraints in staff time and resources. In general, a shortage of people working in the forensic field and in social work and related fields has been reported in Slovenia and other countries. It was reported during the consultation workshops that in Croatia, to alleviate the lack of support for persons with disabilities in prisons, there are sometimes paid assistants, who are fellow detainees and assist them in their daily life. In Slovenia, due to a shortage of psychiatrists in prisons, detainees often have to wait a long time to access psychiatric support, and it has been observed that in the evening and on weekends, the medicinal therapy, including psychiatric, is not distributed by medical staff, 68 but prison guards.247 On the other hand, some interviewed psychiatric experts reported positive experiences regarding availability and the quality of psychiatric care in prisons. They also mentioned that the assessment and referral mechanisms in place have led to significant decreases in suicide rates in Slovenian prisons in the last ten years.248 2.6.7. MONITORING, SAFEGUARDS AND HAVING A VOICE Experts have highlighted that NPMs and monitoring bodies perform crucial tasks in monitoring places of deprivation of liberty, including where persons with intellectual and/ or psychosocial disabilities are held. However, one challenge for NPMs that has been raised was the many inconsistencies in international standards, and a lack of guidance specifically for monitoring the deprivation of liberty of persons with intellectual and/or psychosocial disabilities. Furthermore, NPM visits can be limited in time and scope, and their purpose is not to give a voice to individual experiences. Experts have raised the need to give detainees the opportunity to have their voice heard and share their experiences of detention and grievances beyond filing formal complaints. NGOs were suggested as potentially suitable to fill that role and to develop “living libraries” of persons with intellectual and/or psychosocial disabilities who experienced detention. External research can also describe situations and analyse perspectives of persons concerned, but access to institutions can be highly restricted. Experts (including from Austria, Bulgaria and Lithuania) have noted that persons with intellectual and/or psychosocial disabilities – whether they are held in prison, but particularly if they are in a compulsory treatment regime – are often not aware of the possibility to file a complaint. If they are, individuals are often either not able to access support to file a complaint or they are discouraged from filing a complaint, as this might be perceived as non-compliance and draw negative repercussions (such as the administration of additional medication, as experts from Slovenia have noted).