ESSEX PAPER 3: INITIAL GUIDANCE ON THE INTERPRETATION AND IMPLEMENTATION OF THE UN NELSON MANDELA RULES such as opioid substitution and antiretroviral therapy, has been underscored by the World Health Organization and UNAIDS, stressing that interrupting such treatment has serious health consequences.233 Continuity of care is also critical as a means of preventing overdoses in opioid-dependent prisoners in the immediate post-release period. Pre-release drug services should be coordinated with and linked to appropriate after-care.234 The Essex Group noted the importance of training and education of the prison administration on drug dependency. The Essex Group also noted the importance of reading the requirement to provide continuity of care together with Rule 2(2) of the Nelson Mandela Rules which provides that prison administrations need to ‘take account of the individual needs of prisoners, in particular the most vulnerable categories in prison settings’ and adopt ‘[m]easures to protect and promote the rights of prisoners with special needs’. When non-national prisoners are released, they may be transferred to their country of origin which may complicate the requirement to provide continuity of care. International standards and norms require states ‘to facilitate the continuation of medical treatment of foreign prisoners who are to be transferred, extradited or expelled, which may include the provision of medication for use during transportation to that State and, with the prisoners’ consent, the transfer of medical records to the medical services of another state’.235 Provision of Healthcare Free of Charge Rule 24 provides that health-care should be free of charge.236 The World Health Organization has clarified that ‘free of charge’ should be interpreted literally without any qualifications or ceilings. For example, ‘free of charge’ does not mean that prisoners should only be provided with free access to health-care facilities (such as being transported to a hospital but then being charged for the treatment needed) or that medications should be bought by the family.237 Rather, it means that access to health-care and all necessary treatment, care and medication must be free of charge. WHO, UNODC and UNAIDS, Technical Guide for countries to set targets for universal access to HIV prevention, treatment and care for injecting drug users (2009) available at: http://www.who.int/hiv/pub/idu/idu_target_setting_guide.pdf, p. 26, and WHO, Consolidated Guidelines on HIV Prevention, Treatment And Care For Key Populations (July 2014), available at: http://apps.who.int/iris/bitstream/10665/128048/1/9789241507431_eng.pdf?ua=1&ua=1 ,p. 5. 233  WHO, Preventing overdose deaths in the criminal-justice system, 2010 (updated 2014) available at: http://www.euro. who.int/__data/assets/pdf_file/0020/114914/Preventing-overdose-deaths-in-the-criminal-justice-system.pdf?ua=1 234  Council of Europe: Committee of Ministers, Recommendation CM/Rec(2012)12 of the Committee of Ministers to member States concerning foreign prisoners, 2012 available at: https://wcd.coe.int/ViewDoc.jsp?p=&Ref=CM/ Rec(2012)12&Language=lanEnglish&Ver=original&Site=CM&BackColorInternet=C3C3C3&BackColorIntranet=EDB021&BackColorLogged=F5D383&direct=true ) Rule 31.9. Further, reference could also be made to Rule 35.5 CM/ Rec(2012)12 and Council of Europe: Committee of Ministers, Commentary to Recommendation CM/Rec(2012) 12 of the Committee of Ministers to member States concerning foreign prisoners, 2012 available at: http://www.coe.int/t/ dghl/standardsetting/prisons/Rec(2012)12Commentary_E.pdf 235  Body of Principles for the Protection of All Persons under Any Form of Detention or Imprisonment (1988), A/ RES/43/173. Principle 24. A proper medical examination shall be offered to a detained or imprisoned person as promptly as possible after his admission to the place of detention or imprisonment, and thereafter medical care and treatment shall be provided whenever necessary. This care and treatment shall be provided free of charge. (http:// www.un.org/documents/ga/res/43/a43r173.htm ). 236  237  øller L, Stöver H, Jürgens R, Gatherer A and Nikogasian H, (eds.), Health in prisons, A WHO guide to the essenM tials in prison health, WHO Europe (2007), available at: http://www.euro.who.int/__data/assets/pdf_file/0009/99018/ E90174.pdf, at 10 (A WHO guide to the essentials in prison health) Penal Reform International and the Essex Human Rights Centre | 65