the constitutionally guaranteed rights. Although in force, application of the Law by Decree on Medical Protection and Safety is impeded by significant challenges due to the lack of relevant bylaws. The report does not make reference to the policies needed to enhance the health system in the light of a natural population increase of 2.5 percent, continuing rise in the number of older persons, and health care gaps revealed by the COVID-19 pandemic. This requires that the government state estimated budgets and plans to increase the number of hospitals, primary health care centres, beds, medical staff, and list of medicines and health services to be provided to service recipients. Additionally, the report does not provide the ratio of hospital beds to the population, nor does it show the extent to which the list of medicines available at MoH pharmacies for the health insured are adequate and inclusive, and the availability of drugs for chronic and perilous diseases. Dozens of complaints are filed to the ICHR in relation to the right to health. In 2020, the ICHR received 42 complaints on unavailable health care services, eight on the lack of access, and 102 on the quality of health services. The Commission also monitored a surge in deaths caused medical malpractice, up from eight in 2019 to 16 in 2020. In 2019, the ICHR received complaints, involving 66 violations. These included five complaints on unavailable vaccinations and medicines, 37 on lacking basic medical services, one on unavailable treatment centres in remote areas, and 13 on liability for medical errors. The latter featured seven complaints on deaths following medical treatment, including five in 2019 and two in 2018 and 2017. Seven complaints concerned the quality of medical service provision, including five resulting from the purchase of medical services (patient transfers). By contrast, in 2018, the ICHR received 48 complaints, including five on unavailable vaccinations and medicines, 32 on the lack of basic medical services, three on unavailable treatment centres in remote areas, and eight on liability for medical errors. Against this background, the ICHR recommends that: o Health be considered as a right, rather than a service. This right should be enshrined in the Palestinian Basic Law. o The Law by Decree No. 13 of 2018 on Medical Protection and Safety be put into effect. o A law on health insurance be approved to replace the current Regulation on Health Insurance, based on World Health Organisation (WHO) standards of health care provision. o The existing health system be improved in view of the significant challenges that came to light in the context of the COVID-19 pandemic.8 In addition to paying 8 Within the framework of its persistent activity, the ICHR carried out the National Inquiry into Health Insurance 2019-2021, an exercise that is at the core of the work of national human rights institutions. Informed by international human rights benchmarks and WHO standards, the inquiry adopted a public wide approach through a quantitative survey conducted by the PCBS in 2019. It also used regional focus groups 14