The Department of Children is still in talks with the HSE about undertaking "formal vulnerability assessments" of those applying for international protection or asylum here, two years after it became a legal requirement.

Under Regulation 8 of the European Communities (Reception Conditions) Regulations, which were signed into law in July 2018, a vulnerability assessment must take place within 30 working days of a person communicating their intention to seek asylum.

In the meantime, the Department said that the International Protection Accommodation Service (IPAS) does "takes account of vulnerabilities" when accessing a person's reception needs.

In a statement, the Department said it "also works collaboratively to ensure that any special accommodation arrangements are in place as required."

The Irish Refugee Council (IRC) described this statement as "contrary" to their experience.

IRC CEO Nick Henderson said the IRC had helped hundreds of people seeking protection over the last two years, and "for the majority... there has been no consideration of vulnerability or special needs".

"This is particularly the case for people placed in emergency accommodation or accommodation introduced in response to Covid-19," Mr Henderson said.

"We have had to engage in extensive correspondence to have people transferred to accommodation more suitable to their needs."

According to the regulations a vulnerable person is described as "a person who is a minor, an unaccompanied minor, a person with a disability, an elderly person, a pregnant woman, a single parent of a minor, a victim of human trafficking, a person with a serious illness, a person with a mental disorder, and a person who has been subjected to torture, rape or other form of serious psychological, physical or sexual violence".

The Movement of Asylum Seekers in Ireland (MASI) said it visited a number of direct provision centres and emergency accommodation sites over a period of 90 days last year.

MASI spokesperson Bulelani Mfaco said it was "appalled to find asylum seekers without access to material supports" including mothers who had difficulties getting baby formula and those with chronic illnesses who struggled to get their medication.

Mr Mfaco said he is also aware a person with a disability being assigned accommodation in a centre without disability access, and of LGBTQ+ people being placed in shared bedrooms or centres where they have experienced homophobic abuse.

The Department of Children, Equality, Disability, Integration and Youth recently took over responsibility for the direct provision system from the Department of Justice.

It its statement the Department of Children said that discussions with the HSE were "ongoing...  to enable formal vulnerability assessments to be undertaken... by the end of 2020".

Adding that this would "encompass vulnerabilities that are health-related and those relating to the person's identity or personal circumstances".

The report of the Advisory Group chaired by Catherine Day, which was published in September, said these assessments were "legally required" and said they "must be carried out within 30 days for all applicants and include special reception and procedural needs".