CAT/OP/DEU/2 27. While being fully aware of the fact that it is the responsibility of the State Party to ensure transparency and inclusion in the designation of NPM members, the SPT recommends to the NPM to make public its vacant posts so as to enable civil society organizations and other stakeholders to contribute to the State Party's designation process and thereby ensuring its compliance with article 18, paragraph 2 of the Optional Protocol. 28. As regards its composition, the SPT observed that the NPM did not have the adequate in-house medical, psychological and other related expertise such as in the areas of social work, security, pedagogy and children, which limits the NPM capacity to effectively monitor the places of deprivation of liberty. Moreover, the NPM has only occasionally engaged external experts, primarily due to limited resources. 29. The SPT recommends, in the context of selection, expanding the NPM membership to include medical, psychological and other related expertise in order to allow the mechanism to carry out its activities in accordance with the Optional Protocol.7 In order to cover missing specializations, the NPM should explore creative ways of strengthening the human resources at its disposal by, for example, engaging external expertise, setting up internship programmes or partnering with universities and civil society. 30. The SPT witnessed a partial lack of efficient team work in the preparation and conduct of the inspection visits by the Federal Agency and the Joint Commission (see below methodological recommendations), the lack of an established common strategy as to which detainees and personnel to privately interview and, to some extent, incoherent methods of work. The functioning of the NPM could be improved with a clearer division of roles between individual team members during the inspection visits, better communication and an enhanced coordination of work between the Federal Agency and the Joint Commission. In this regard, the SPT was encouraged to hear from both institutions during the meetings on 9 and 11 April 2013, that the Federal Agency and the Joint Commission further aim to work as an effective collegial body, as envisioned by the Optional Protocol. 31. The SPT recommends that the NPM develop clear guidelines in order to plan and carry out efficient monitoring and that its members and staff undertake further training jointly, in order to enhance their ability to efficiently perform, collectively and individually, the visiting capacity entrusted to them under the Optional Protocol.8 The SPT also recommends that the NPM members improve coordination of working methods including the harmonization of the Working Guidelines of the Federal Agency and the Rules of Procedure of the Joint Commission into the common Rules of Procedure, regular information sharing, common visiting and interviewing strategies, updating the NPM webpage, and most importantly, improved collaboration and division of roles during the preparation and conduct of the visits. 32. To the SPT knowledge, the Federal Agency and the Joint Commission do not submit regularly proposals concerning existing or draft legislation in their NPM capacity, in accordance with article 19 (c) of the Optional Protocol. One of the reasons for this may be the lack of clear legal basis for the mechanism to comment on draft laws, and /or the lack of human resources within the NPM to effectively carry out this function. 33. In order to fully discharge its mandate in accordance with article 19 (c) of the Optional Protocol, the SPT recommends that the NPM take proactive steps to submit proposals and comments, at both Federal and State level, regarding existing or draft 7 8 CAT/OP/12/5, para. 20. CAT/OP/12/5, para. 31. 7