for Medical and Pharmaceutical Activities conducted inspection in 10 psychiatric institutions from January 1, 2019 to December 3, 2019.357 The external control mechanisms focus on patients’ complaints, which, in the absence of a proper, accessible procedure for filing complaints about the deficiencies in psychiatric care and human rights violations, fails to ensure the required degree of state control. In particular, the work of control mechanisms is not thorough or coordinated and in case of detection of violations, their elimination is not strictly controlled. In view of all the above, it is important that the grounds for carrying out external oversight/monitoring of the supervision of the provision of psychiatric care and monitoring of patients' rights be defined in the Law of Georgia on Psychiatric Care. It is necessary to clearly state who shall carry out the monitoring, as well as to define the relevant mandate, composition and timetable. At the same time, any conflict of interest should be ruled out to ensure impartiality. In addition, it should be a flexible mechanism for responding to violations and forwarding information on violations to the relevant body in a timely manner. The Public Defender believes that the monitoring body/bodies should meet the following 3 criteria:358 1. Systemic: Monitoring should be thorough and system-oriented. The monitoring report should assess the provision of quality psychiatric care based on biopsychosocial model and respect for the patients’ rights. The report should include specific recommendations. 2. Proactive: Monitoring should be carried out ex officio and should be regular. 3. Transparent: The reports developed by the mechanism should be public. The Public Defender is aware that in June-July 2018, the Ministry of Internally Displaced Persons from the Occupied Territories, Labour, Health and Social Affairs of Georgia, with the technical support of the Council of Europe, developed a questionnaire for the evaluation of psychiatric service providers based on the WHO QualityRights tool kit.359 In March-May 2019, 11 psychiatric institutions were evaluated according to the above-mentioned questionnaire in terms of human rights protection. The Ministry of Internally Displaced Persons from the Occupied Territories, Labour, Health and Social Affairs plans to implement this type of monitoring in the state monitoring programme.360 The Public 357 Letter No. 02/1557 of the Regulation Agency for Medical and Pharmaceutical Activities, December 3, 2019. In 2018, the Public Defender issued a recommendation on regular, systemic and proactive monitoring of psychiatric institutions, which has been endorsed in the resolution of the Parliament of Georgia on September 20, 2019. 359 Letter No. 01/20057 of the Ministry of Internally Displaced Persons from the Occupied Territories, Labour, Health and Social Affairs, November 27, 2019. 360 The response of the Government of Georgia of November 21, 2019 to the report of the European Committee for the Prevention of Torture on its visit paid to Georgia on September 10-21, 2018, available in English at: <https://rm.coe.int/168098e29c>, [last accessed: 10.01.2020]. 358 116