It needs to be stressed also that the failure to provide an accessible environment is a violation of the requirements enshrined in: 1. The United Nations Convention against Torture and Other Cruel, Inhuman or Degrading Treatment or Punishment; 2. The United Nations Convention on the Rights of Persons with Disabilities; 3. The Integration of Persons with Disabilities Act; 4. The Territorial Development Act; 5. Ordinance No. 4 of 1 July 2009 on the design, execution of works, and maintenance of buildings in accordance with the requirements for accessible environments for the public, including for persons with disabilities (Наредба № 4 от 1 юли 2009 г. за проектиране, изпълнение и поддържане на строежите в съответствие с изискванията за достъпна среда за населението, включително за хората с увреждания). Repeat inspections revealed that a major problem facing all eldercare institutions is the shortage of specialist and non-specialist staff to support resident beneficiaries in their day-today activities. Yet another issue came to the fore again, i.e. the lack of medical specialists motivated to deliver high-quality services to persons in residential care establishments. In such a context, the NPM has recommended to the MLSP:  Earmark budgetary resources for salary increases for medical staff, as current salary scales are the main impediment to filling the numerous job vacancies available, which in turn undermines the provision of quality health care to HEPD residents;  Regulate the possibility to add new staff positions for practitioners directly involved in delivering services to eldercare beneficiaries, as well as for auxiliary and support staff. In a letter Ref. 92-644 of November 6, 2015 the MLSP provided the following response to the NPM recommendation:  Financial planning for staff wages in the social service system complies with the expenditure standards for the upkeep of the social services. The Council of Ministers adopted Decision No. 859 of November 3, 2015 amending Decision No. 276 of 2015 establishing standard salary scales for state-delegated activities in both volume and value indicators. According to the said CoMs Decision, the average 2016 increase to standard salary scales, compared to 2015 scales, is two percent for all specialised institutions and three percent for community based social services. The only exceptions are the following services: social rehabilitation and integration centre, public support centre, family-type placement centre for seniors, elderly day care centre, centre for social work with street children, vocational training social centre, and transient home. Funding for them is to remain at 2015 salary scales level;  Changes to staff establishment plans for residential care facilities would contravene the MLSP-approved Staffing Methodology for Specialised Institutions and Community-Based Social Services. The NPM finds that the approach taken by the MLSP to the Ombudsman’s recommendation is an attempt at evading the main issue identified by the inspection teams, i.e. that the quality of eldercare at social institutions for seniors depends largely on the staff. The increase in standard salary scales for state-delegated activities by just two or three percent is symbolic and reflects rather the increase to the country’s minimum wage rate. As to remuneration of specialists in the field of social care, the Ombudsman, acting as NPM, expressed the opinion that the minimum wage increase would create a real problem at social 76