on the rapid closure of these institutions and creation of protective social system that includes a network of services (integrated services and educational, psychosocial and protection measures and support mechanisms) for children that are in conflict with the law. Children should not be punished for events related to so called status-related offences for which the adults are not criminally liable. The reaction to these violations should be subject to a policy of in the area of caring for the child, not of the sanctioning system. Strategic goals of the Action Plan for implementation of the Concept of state policy in the field of justice for the children (2013-2020) and in the Roadmap for implementation of the Concept of state policy in the field of justice for the children (2013-2014), are adequate, but it is a still a matter of concern the implementation of activities for achievement of strategic objectives. The above documents do not impose deadlines for the implementation of the reform in the field of the services. VIII. SOCIAL AND MEDICAL SOCIAL INSTITUTIONS FOR CHILDREN 1. Social institutions for children In 2014 the process of deinstitutionalisation of children with disabilities entered the final phase, namely the removal of children from homes for children with mental retardation and infant homes and their placement in centres for family-type accommodation (CFTA). The NPM inspected 20 small CFTAs (groups of homes). Upon inspection the team identified some deficiencies on the part of SACP and the Agency for Social Assistance (SAA) in the placement of children in these centres. Thus, as a national ombudsman, acting as a NPM, I have sent an official statement to the institutions responsible for the process of deinstitutionalisation of children with disabilities. My strong recommendation is not to mix children with persons with disabilities in CFTA, as the needs of these two categories are different and this leads to very great difficulties for staff in caring for them. Users of the new social service need to be prepared adequately for their relocation in CFTA. During the inspections performed in the home for children and young people with mental retardation (HCAMR) – city of Kula, HCYMR - village of Gomotartsi, HCAMR – city of Berkovitsa, orphanage – city of Pleven, the team of the NPM found that estimates of the needs of children with disability performed before bringing them out in order to determine where they will be accommodated are subject to constant change. This leads to many problems, both in the work of the staff in the home where the child is and for the teams of CFTA, where it will be transferred. As for children with disabilities need longer preparation for their move, this leads to mental health problems for the children. During the inspections in different HCAMR the team of the NPM found that health care for children with severe disabilities do not meet the needs of the children and thus directly endanger their health and their lives. An example of this is the lack of qualified staff at night – there are no medical professionals and the medications to children on severe medical therapy are given by carers. It is important to note that training to work with children with disabilities of the personnel in CFTA is insufficient, leading to inability to adequately respond in a crisis situation or even to identify such. According to the director of CFTA – city of Cherven Briag, there was a high turnover and replacement of more than half of the staff of the social services. This problem also occurs in other CFTAs. There are cases of children transferred back from CFTA to the homes from which they had been transferred. The team of the NPM believes that it is necessary to have a clearly set criteria and approach 38