INSTITUTION OF THE HUMAN RIGHTS OMBUDSMAN OF BOSNIA AND HERZEGOVINA Protection Institutions in the Federation of BiH (2014-2020), as a framework strategic document aimed at improving conditions for the development of a protection system that will ensure quality improvement life, non-discrimination, protection of human rights and freedoms for all beneficiaries of social protection, through the transition from institutional care to communitybased social care. The Strategy was adopted by the Government of the Federation of Bosnia and Herzegovina Conclusion V No: 1395/14 of 10 July 2014 and it was developed in accordance with the EU Guidelines for the Transition from Institutional Care to Community Support Services and the UN Guidelines for Alternative Child Care. ... In accordance with the aforementioned Conclusion, this Ministry has also prepared an Action Plan for the implementation of the Strategy, to which the Government, by Decision V No. 1591/17 of 7 December 2017, approved. ... Therefore, it can be concluded that the Federation Ministry of Labor and Social Policy is aware of the existence of problems in the subject area, that the strategic documents have been adopted, but that the problem arises when implementing the strategic documents. In this regard, we point out the need to involve all relevant actors who will, through concrete measures, contribute to improving the position of persons with mental and intellectual disabilities placed in social care institutions. 9.2. Rights of persons with disabilities in the field of social protection Complaints in the Institution show that the legislation in Bosnia and Herzegovina is based on a medical rather than a social model. Therefore, the focus is not on exercising the rights of persons with disabilities in relation to residual capacity, which international standards insist on. Example: Ombudsmen became involved in the process of adopting the Law on Amendments to the Law on Social Protection of the Republika Srpska in 2019 423, and submitted a comment to the Republika Srpska Ministry of Health and Social Welfare 424 on the Draft Law on Amendments to the Law on Social Protection of the Republika Srpska. After having reviewed the Draft Law on Amendments to the Law on Social Protection of the Republika Srpska, it was established that Article 35a. of the draft law stipulates that the right to personal disability shall be exercised, among other things, by persons who are dependent on assistance and care of another person in meeting basic living needs and whose damage/illness occurred in the developmental period and have physical damage from 80% to 100% ( Article 35a (1) (a)), persons with intellectual disabilities who are dependent on the assistance and care of another person to meet basic living needs and who have suffered a developmental impairment/illness and have a physical impairment of at least 70% (Article 35a (1) (v)) and hearing impaired persons who have suffered a developmental impairment/disease and have a physical impairment of at least 70% (Article 35a (1) (g)). 423 424 Official Gazette of the Republika Srpska, No. 37/2012 and 90/2016. Ž-SA-02-522/19 102