COUNCIL OF EUROPE ON HEALTH CARE FOR UNDOCUMENTED MIGRANTS      (March 2005)


 

The Committee on Social Rights of the Council of Europe, which has as a task to monitor the application of the European Social Charter, ruled that "legislation or practice that denies entitlement to medical assistance to foreign nationals, within the territory of a State Party, even if they are there illegally, is contrary to the Charter." This decision followed a complaint against the new French legislation filed by the organisation FIDH, supported by LDH and Gisti.

 

Change of the law

Complaint

Decision

Documents

 

Change of the Law

 

A law dating from 30 December 2002 changed the French law on access to health care for undocumented migrants. From then onwards, all undocumented migrants have to pay part of the medical treatment. On top of that, those who are not able to proof that they are in France for more than three months, do not receive state medical assistance (AME) anymore, but are only eligible for treatment for emergencies and life threatening conditions.

 

Complaint

 

The NGOs asked the Committee to rule that the legislation and practice at stake contravene to the provisions of Articles 13 and 17 of the Revised Social Charter.

 

 

Article 13 §§ 1 and 4:

 

"With a view to ensuring the effective exercise of the right to social and medical assistance, the Parties undertake:

 

1. to ensure that any person who is without adequate resources and who is unable to secure such resources either by his own efforts or from other sources, in particular by benefits under a social security scheme, be granted adequate assistance, and, in case of sickness, the care necessitated by his condition;

(...)

4. to apply the provisions referred to in paragraphs 1, 2 and 3 of this article on an equal footing with their nationals to nationals of other Parties lawfully within their territories, in accordance with their obligations under the European Convention on Social and Medical Assistance, signed at Paris on 11 December 1953."

 

FIDH stated that the law of 30 December 2002 constitutes a violation of the right to medical assistance provided for by Article 13 of the Revised Charter, because it ends the exemption of illegal immigrants with very low incomes from all charges. Since the new law, beneficiaries now have to pay a flat-rate charge for medical treatment outside hospital and a daily charge for in-patient hospital treatment.

 

FIDH considers that under Article 13§4, the condition of "lawful presence in the territory" only relates to the right to medical assistance on an equal footing with nationals. In other words, the fact that the persons concerned are unlawfully present may constitute a reason for them not to be entitled to exactly the same treatment as nationals, but in no way would it justify denying them all medical assistance.

Article 17 reads as follows:

 

"With a view to ensuring the effective exercise of the right of children and young persons to grow up in an environment which encourages the full development of their personality and of their physical and mental capacities, the Parties undertake, either directly or in co-operation with public and private organisations, to take all appropriate and necessary measures designed:

1. a. to ensure that children and young persons, taking account of the rights and duties of their parents, have the care, the assistance, the education and the training they need, in particular by providing for the establishment or maintenance of institutions and services sufficient and adequate for this purpose;

b. to protect children and young persons against negligence, violence or exploitation;

c. to provide protection and special aid from the state for children and young persons temporarily or definitively deprived of their family's support;

2. to provide to children and young persons a free primary and secondary education as well as to encourage regular attendance at schools."

 

FIDH stated that the restriction on the rights of children and young persons arising from the law of 31 December 2002 constitutes a violation of Article 17, as the introduction of patient charges denies them the rights set out in Article 17.

 

Decision of the Committee

 

The Committee stated on an introductory note that the Charter is a living instrument, dedicated to certain values which inspired it: dignity, autonomy, equality and solidarity. The Charter must be interpreted so as to give life and meaning to fundamental social rights.

 

Human dignity is according to the Committee the fundamental value and indeed the core of positive European human rights law - whether under the European Social Charter or under the European Convention of Human Rights - and health care is a prerequisite for the preservation of human dignity.

 

è Article 13

 

Given the existence of a form of medical assistance benefiting these persons, the Committee, being in doubt, considers that France does not violate Article 13 of the Revised Charter.

 

However, the committee stresses at the same time that

-         the concept of emergencies and life threatening conditions is not sufficiently precise

-         the competent body to take decisions in this field is not clearly identified.

-         there are numerous difficulties in the implementation in practice of the provisions applicable to illegal immigrants in France for more that 3 months

-         the costs to be met by the state are narrowly defined

 

è Article 17

 

The Committee considers that the situation in France is not in conformity with Article 17.

 

The Committee notes that

a) medical assistance to the above target group in France is limited to situations that involve an immediate threat to life;

b) children of illegal immigrants are only admitted to the medical assistance scheme after a certain time

 

It should be noted that the decision should still be validated by the Committee of Ministers of the Council of Europe. Usually the validation of collective complaints (such as this one) goes through an express-procedure. In this case however the ministers don't succeed in taking an express decision, since this decision would entail serious consequences for their respective states.

 

Documents

 

In English: http://www.coe.int/T/E/Human_Rights/Esc/4_Collective_complaints/List_of_collective_complaints/RC14_on_merits.asp#TopOfPage

 

En français:

http://www.coe.int/T/F/Droits_de_l'Homme/Cse/4_R%E9clamations_collectives/Liste_des_R%E9clamations/Bien_fond%E9_RC14.asp#TopOfPage

 

Press release of FIDH/LDH/GISTI : http://www.gisti.org/doc/actions/2005/ame/index.html

 

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