National Preventive Mechanism that restrict freedom are often missing. The NPM sees its responsibility above all in sensitising the management and staff to the protection of the right to personal freedom and in referring to the notification obligations pursuant to the Nursing and Residential Homes Residence Act. Appropriate training and contact with the representatives of the residents as well as measures for ensuring the traceability of the care documentation are recommended. It is evident from the written reactions that the criticism is taken seriously and being dealt with. However, in practice the problems are usually very complex, in particular with regard to potential medication-based measures that restrict freedom. It can be assumed that there is a need for specific psychiatric help for persons who are severely impaired in their autonomy and taking part in society. Severe disability is more often accompanied by mental disorders and barriers to communication than in case of non-disabled persons. But the specific living conditions must be taken into consideration in particular when assessing the psychiatric symptoms, because persons with severe multiple disabilities have considerably fewer possibilities to control basic aspects of their life themselves. Professional psychiatric expertise is thus necessary for determining indications and diagnosis. The heightened sensitivity of persons with cerebro-organic disorders to adverse effects and their disguise as “mental disorders” requires experience and knowledge of prescribing psychotropic medication when dealing with this vulnerable group of people in particular. This should therefore not be performed by general practitioners in the view of the NPM. Psychiatric standards in psychotropic medication therapies Commissions frequently observe that the evaluation of treatment with psychotropic medication is inadequate. Treatment plans from professional medical experts with explicit therapy objectives are unavailable; traceable documentation of the course of the therapy is missing. The effects and adverse effects of the psychotropic medication are at most thematised in the daily documentation if there are behavioural disorders worth mentioning. Clients who attract attention by raging, shouting, kicking and hitting others, injuring themselves repeatedly, throwing objects around or destroying them, spitting out medication and ignoring pedagogical instructions are usually experienced and assessed as difficult, aggressive and dissocial. This transfer of the understanding of the illness to the field of pedagogical action has far-reaching effects. Many employees in residential facilities often only experience the residents under the influence of psychotropic medication, but see the same as a problem-solving universal remedy. As members of non-medical professions, they are neither authorised nor in a position to assess the advantages and disadvantages, effects and adverse effects of medication. In this way, factual grey areas can emerge between the attending doctors and the facilities about who has to make decisions on whether specific measures have to be initialised and if so, which measures these should be. Deficits due to unclear therapy objectives 157

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