liberty may access available resources provided by the national health insurance system for their medical treatment. The NPM is of the opinion that prior to launching a structural reform a medical, statistical and economic analysis of the work of the healthcare establishments should be made to establish whether all options for addressing the major problem of understaffing have been exhausted. This analysis should further estimate the costs, benefits, and expected results of the reform and study the provision of medical service in places of detention in other countries. In this regard the NPM has the following suggestions for restructuring the penitentiary healthcare system:  Transform the medical centres in the places of detention into healthcare practices within the meaning of the Healthcare Act. These healthcare practices should provide emergency care; healthcare for chronically ill persons; assessment of the inmates’ complaints to be attended by a GP; health promotion; access to national programmes and screening tests; anti-epidemic and sanitary hygiene work; medication. The healthcare practices should complement the work of GPs and provide medical care out of the GPs office hours.  Primary care for persons deprived of their liberty should be provided by GPs designated by the Regional Health Insurance Fund. The NPM is of the opinion that this is the hardest but most important part of the restructuring. It may lead to problems such as formal service by GPs and medical care ultimately provided by the healthcare practices. This is why the support and cooperation of the Bulgarian Medical Association and the National Health Insurance Fund should be sought.  Hospital treatment of persons deprived of their liberty should be performed in hospitals outside the penitentiary system, namely in healthcare establishments that have concluded partnership agreements with the National Health Insurance Fund. The NPM suggests to use regional hospitals to that end since the State is represented in their management boards and may intervene, through the Ministry of Health, where appropriate.  The NPM proposes that he in-house hospital for persons deprived of their liberty are transformed into inpatient continuing care units.  Problems may occur in relation to clinical pathways that are subsidized by healthinsured persons. Therefore the body providing the required additional susbsidy should be specified in law. In view of the significance of the upcoming reform, the NPM suggests that the restructuring is piloted first in several prisons. Currently three places of detention – the prisons in Burgas and Vratsa and the reformatory of Boychinovtsi have enrolled in GP practices and have in fact started applying the proposals for reform described above. The analysis of their medical and statistical indicators, organisation of the medical service, and interaction between GPs and medical centres for ensuring timely and quality healthcare to people deprived of their liberty will be crucial for conducting the reform nation-wide. 28