The cycle of constant visa renewals appears to be unnecessary with respect to the Medevac cohort given the particular circumstances of this group. An additional concern is that there appear to be cases where delays in renewals have resulted in individual visas lapsing, which then simultaneously also removes an individual’s access to relevant services. RECOMMENDATION 22: The SRSS program should be independently reviewed, to ensure that eligibility criteria are appropriately defined and that an appropriate duration and level of support is being provided. One option that would address this issue within the existing legal framework would be for the Minister to make a determination lifting the 5.2 Visa Renewal Process Another key issue that was consistently raised was the uncertainty and complexity of the visa renewal process for those who had been released on a Bridging visa E (subclass 050) (BVE). Under s 46B of the Migration Act transitory persons holding a bridging visa are barred from making a valid visa application unless the Minister personally determines that they may do so. This is a process colloquially referred to as ‘lifting the bar’. The window for making an application once the bar has been lifted may only be for a limited period of time. This is a process that has been described as complicated, burdensome and unnecessarily stressful by both the individuals concerned and the advocates assisting them. For example, one community service organisation described the process as follows: ‘the administrative process of seeking a bar lift, waiting for the Minister’s decision to lift the bar, re-applying for a bridging visa (which requires a fresh application) and ultimately being issued a very short-term visa is causing immeasurable harm to the individuals directly affected’. It also creates an additional burden on the Minister, and a considerable workload for the Department. bar for each future BVE extension application made by a member of the Medevac cohort. The visa renewal process would then become an administrative process that could be completed by the Department, as opposed to a process requiring Ministerial intervention on each occasion. RECOMMENDATION 23: The Minister should make a determination lifting the bar for each future BVE extension application made by a member of the Medevac cohort so as to allow the visa renewal process to become an administrative process completed by the Department. The Use of Hotels as Alternative Places of Detention (APODs) • 2023 • 55