Many of the individuals detained in hotel APODs have significant and complex mental health issues. Individuals are able to access mental health support from the IHMS health service, and referrals to specialist external providers (including torture and trauma counselling) can be made when an initial IHMS assessment indicates that this is required and the service cannot be offered by the IHMS staff team. However, some individuals indicated to us that they had not been able to access mental health support in a timely manner when they needed it most, that there were numerous barriers making it more difficult than it should be to access the mental health support that they needed, and that they felt the mental health care provided was inadequate. Comments made to the Commission during interviews included that there was ‘no follow up’ and that ‘If I had proper counselling I think I could deal with it better’. A further concern consistently raised by community service providers with the Commission was a perception that medication for mental health was overprescribed in hotel APODs, and that there was a focus on using medication to control symptoms experienced by detainees rather than implementing strategies to make longer-term and more sustainable improvements to mental health. It is widely recognised that lengthy stays in detention are a significant risk factor for mental ill-health, and that these negative impacts worsen as the time spent in immigration detention increases. As discussed above,77 community service organisations consistently emphasised the marked deterioration in mental health that they observed amongst those released from hotel APODs later in 2022 when compared to those who had been released earlier. Both the length of time spent detained in hotel APODs and the continued uncertainty around both releases and future pathways appeared to be significant factors contributing to the worsening mental health of detainees. In the 2019 Report, the Commission expressed alarm about the mental health of the broader detention population and concluded that ‘current treatment practices appear inadequate to deal with this problem’.78 The Commission made a number of recommendations relating specifically to mental health care, including that the Department ‘should commission a group of independent mental health experts to conduct a comprehensive review of the mental health care provided in immigration detention’.79 The Department agreed in principle with this recommendation and commissioned ‘a holistic review of mental health services to detainees’ in early 2020.80 This review was conducted during the period 7 May 2020 – 12 July 2020 and the report was provided to the Department on 15 July 2020 (2020 Departmental Review). The Department has indicated that the recommendations contained within the 2020 Departmental Review will be addressed, however it has also indicated that it will not be releasing the report publicly81 and is not considering a follow up review.82 Based on the limited information that is publicly available, the Commission considers that the 2020 Departmental Review does not adequately address the recommendation made by the Commission the 2019 Report. The Commission is particularly concerned that no detention centres were visited during the review, only two detainees were interviewed, and it does not appear that any external service providers with experience in providing mental health services to detainees were interviewed.83 The Use of Hotels as Alternative Places of Detention (APODs) • 2023 • 43