believing that the beneficiary’s completely legitimate intentions, such as the wish to get health care in the place of factual residence - constituted the grounds for the refusal of request. LAW ON GENERAL ADMINISTRATIVE PROCEDURE In late February 2016, the new Law on General Administrative Procedure was adopted. The implementation of most provisions was postponed for June 2017, but in early June 2016 the provisions emphasising, to a greater extent than the previous law, the duty of the authorities to collect evidence on which official records are kept ex officio began to be implemented. The implementation of the provision on introducing a misdemeanour liability of public officials who do not try to obtain information ex officio, or fail to provide the data on which official records are kept at the request of another authority, also began.33 Given that the rules of administrative procedures are applied in most procedures whose purpose is the registration of the facts of birth and citizenship into civil registry books, and in all the procedures of issuing ID cards, health cards and other personal documents to citizens, the said amendments to the Law on General Administrative Procedure should make it considerably easier for citizens to conduct the aforementioned administrative procedures and obtaining of personal documents. As mentioned in the introduction, since the beginning of the implementation of these provisions Praxis has monitored whether the authorities acted in accordance with the said rules, primarily through the experiences of its beneficiaries. We also conducted interviewees with 10 employees of administrative authorities who assessed the implementation of the new law from their perspective and pointed to certain problems that hinder the process of obtaining evidence. In addition, Praxis submitted a freedom of information request to the Ministry of Public Administration and Local Self-Government, asking for the information and data on how the Ministry was overseeing the implementation of the Law on General Administrative Procedure and the number of cases in which the competent authorities had obtained evidence ex officio, and if not - the number of procedures in which it was established that the officials had violated their duty and the number of such cases in which requests for initiating misdemeanour procedures had been submitted. The Ministry of Public Administration and Local Self-Government informed Praxis that it did not possess the information on the number of cases in which evidence was obtained or was not obtained ex officio and in which the officials’ liability had been established and in which misdemeanour procedures had been initiated. As regards the oversight of the implementation of the Law on General Administrative Procedure, the Ministry responded that within the framework of the project Good Governance - Citizen-Oriented a document had been prepared “whose purpose is to define indicators for measuring progress in the field of data exchange in local self-government units, and to define the criteria that will identify good practice of data exchange and therefore define the basis for assessing the degree of data exchange efficiency of each local selfgovernment unit in this field.” The Ministry also stated that the local self-government units that complied with the said criteria would have the possibility to qualify for joining the “Good Governance Club” and that in 16 local self-government units the meetings had been held with 33 Articles 9, 103 and 207 of the Law on General Administrative Procedure, Official Gazette of RS, no.18/2016 23

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