3. Key observations and concerns This inspection report identifies three key areas of concern. The first is the continued use of hotel APODs for lengthy periods of detention. The Commission has consistently expressed the view that hotel APODs should only be used in exceptional circumstances and for the shortest possible time.32 The key observations during these inspection visits confirmed the previously expressed view that hotel APODs are not appropriate to be used for lengthy periods of detention, with specific concerns relating to the conditions of detention outlined at [4.2] – [4.5]. The second key area of concern relates to the releases from hotel APODs that occurred from December 2020 onwards. While the Commission welcomes the reduction in the overall numbers of individuals detained in hotel APODs, the role of ministerial discretion and the way in which releases have been conducted have both been identified as areas that would benefit from review and improvement. The final key area of concern is the provision of post-release support. In particular, the Commission has concerns about the adequacy of post-release arrangements in terms of the support provided through the SRSS, the visa renewal process, and the continuity of medical care post-release. 3.1 Length of detention As at 31 July 2022, the average length of time that individuals had spent detained in hotel APODs was 69 days.33 The longest continuous period of detention in a hotel APOD was 634 days.34 Time spent detained in hotel APODs cannot be considered in isolation, with many individuals – particularly those within the Medevac cohort – having also spent lengthy periods detained in other immigration detention facilities. The average length of time spent in immigration detention in Australia continues to increase, reaching 806 days as at 31 January 2023.35 The Use of Hotels as Alternative Places of Detention (APODs) • 2023 • 17