**2. Methodology**

In terms of methodology, we have based the research on to the Critical Frame Analysis originally produced in qualitative research on gender equality policies, having adapted it to our qualitative archival and documentary research of legal documents, administrative decrees, policy texts and media commentaries on immigration. As noted, in the Critical Frame Analysis*,* "*the concept of frames and framing is presented as a basic concept for the analysis, starting with defining a frame as an interpretation scheme that structures the meaning of reality, and a policy frame as an organizing principle that transforms fragmentary or incidental information into a structured and meaningful policy problem, in which a solution is implicitly or explicitly enclosed. Policy framing then can be seen as the process of constructing, adapting and negotiating policy frames*" (Verloo and Maloutas 2005, p. 2). The Critical Frame Analysis we have followed combines elements from policy theory, discourse analysis and immigration/crimmigration theory. As noted, "*unlike other approaches, frame analysis starts from the assumption of multiple interpretations in policy making, and addresses problems of dominance and exclusion connected to policy making. Implementation of policies is seen as a political process, subject to all mechanisms of political processes. Under conditions of multilevel governance, implementation is a complex process of transfer and translation: unitary concepts or frames, as presented in political decisions and policies at (sub) national and supranational levels contrast with a dynamic reality of multiple frames at national levels. This contrast between an assumed stable unity and a real dynamic diversity is seen as a «black box» of distortions in the implementation of policies. The shifts that occur during implementation often coincide with exclusion processes*" (Verloo 2005, p. 8).

We have thought Critical Frame Analysis as a suitable tool since it enables certain of our research questions to be answered such as the detection of similarities, differences and inconsistencies in the way immigration is perceived or understood as a problem in national and European levels, especially under the urgency of the COVID-19 pandemic circumstances. How are patterns at the national level connected to existing and developing frames at the European Union level? Which processes of exclusion result from dominant frames? What are the consequences of possible inconsistencies detected? We also considered most suitable to our analytic purposes the concepts of policy frames and framing dimensions, since within the Critical Frame Analysis, "*a policy frame is further specified as a specific configuration of positions on the dimensions of diagnosis and prognosis of the policy problem, roles attributed in diagnosis and prognosis and voice given* ... *Because not only discursive elements but also attributed roles and voice have an important place in this framework, the approach is labelled Critical Frame Analysis"* (Verloo 2005, p. 20). Whilst we agree with the critique that discourse analysis in general and frame analysis present certain problems for comparisons, especially on how to develop categories that can analyze discourses at various levels that allow for comparison (Van Gorp 2001), and that frame mapping (Riechert 1996) offers no viable alternative as based on frequency and co-occurrence of key terms in text, we felt convinced by the merits of the Critical Frame Analysis, despite the fact that frame analysis

needs further methodological development, especially by studying framing in connection to legitimacy and domination (Verloo 2005, p. 20).

Within the Critical Frame Analysis, a policy frame is considered as "an organising principle that transforms fragmentary or incidental information into a structured and meaningful policy problem, in which a solution is implicitly or explicitly enclosed. Hence, policy frames are not descriptions of reality but specific constructions that give meaning to reality and shape the understanding of reality. Research working with these or similar concepts is based on a constructionist approach to reality, where discourse, through its close connection to the construction of truths is seen as having important material and immaterial impacts. In implementation processes, policy frames are the medium, transferred and necessarily adapted from one level to another, from one area to another. Frame analysis is concerned with the (re)construction and negotiation of reality by social/political actors through the use of symbolic tools (Triandafyllidou and Fotiou 1998)—as cited in the original. Framing, then, can be seen as the process of constructing, adapting and negotiating frames (Verloo 2005, p. 20).

Thus, the methodology of the Critical Frame Analysis helps to overcome the abovementioned problems by analyzing the dimensions of frames rather than constructing a hierarchical set of codes or typologies of frames. These dimensions allow for a comparable description of various positions. Yet, categorizing beforehand can follow a grounded theory approach (Strauss and Corbin 1997). In addition, Critical Frame Analysis helps to "*track the inner (explicit or implicit) logic of processes of policy frames as a crucial element of exclusion and track the discursive histories that are present in the public discourse, within political institutions (like parliamentary debates and documents), civil society (NGOs) and the media. In order to put the accent on power relations involved in policy texts, Critical Frame Analysis therefore will also have to pay specific attention to the role of various actors in framing processes. More specifically, attention for who has voice in defining the problem and who has voice in suggesting suitable courses of action to resolve the problem, is needed, as well as specific focus on the attribution of responsibilities (for causing the problem or for solving the problem)*" (Verloo 2005, p. 22).

Without wishing to duplicate theories and methods, we are following Critical Frame Analysis in that we are framing crimmigration as a policy problem that is a policy frame which has a typical format connected to politics and policy making. We also start according to the critical frame approach from the general assumption that a policy (proposal) will always contain an implicit or explicit representation of a diagnosis of a situation, a phenomenon or a problem, connected to an implicit or explicit prognosis of what is coming and a call for action. In other words, the analysis is based on the assumption that there is a problem, that some solution to this problem is proposed (including ideas on the causes of or responsibilities for the problem, on the ends that can be reached through the use of certain means and on the desirability of certain outcomes) and that it is made clear who has to do something and what has to be done. The key sensitizing questions used to energize the texts are quite similar to the template proposed in the article of Verloo (2005), so there is no need to duplicate its code and categories scheme here. Suffice is to say that the basic structure consists of the dimensions of Diagnosis, Attribution of Responsibility (renamed Roles in Diagnosis), Prognosis and Call for Action (renamed Roles in Prognosis). The dimension of Voice has been also added in our analysis, since policy frames do not always originate in specific actors but also may commence in institutions (administrations, cabinets, committees, etc.) in our case as well. So, on the one hand, theoretical notions from discourse analysis may be used while, on the other, analysis may be facilitated in terms of exclusion/inclusion and power. At a more detailed level, based on discourse analysis, we have also used the sub-element of the Form (form of argumentation, dichotomies, metaphors) within the dimensions of Diagnosis and Prognosis. In addition, the analysis includes within the dimensions of Diagnosis and Prognosis, Carol Bacchi's critique on policy theory, especially her "what's the problem represented to be?" approach (Bacchi 1999). Furthermore, based on Giddens' structuration theory (Giddens 1984), the Critical Frame Analysis is suitable for placing emphasis on the distribution of and access to

various resources, next to the rules (interpretations and norms) connected to migration or refugee issues. Thus, normativity maybe separately accessed and highlighted as well as the impact assessment of policies.

### **3. The Healthcare Aspects of Crimmigration**

The COVID-19 pandemic and the measures undertaken to confront it have a tremendous, but to a large extent, differentiated impact on both societies and individuals at a global level, which was dependent on the socioeconomic status of each society and the specific population group. Especially, the identity characteristics of population groups are proven to be crucial towards the protection of the individual members against the pandemic. These characteristics are mainly interrelated with citizenship status and membership. From the beginning of the pandemic, migrants and refugees residing in open/closed facilities became—once more—unseen as the focus of the dominant narrative was the declared and/or implemented policies for the citizen population, contrary to the Commissioner Johannson statement during the Committee on Civil Liberties, Justice and Home Affairs meeting on 2 April. As she has stressed, *"refugee camps, in countries of first asylum, are severely ill-equipped to support a large number of persons who already live in precarious conditions. The spreading of the virus in such contexts may result in a massive humanitarian crisis [* ... *] To fight xenophobia, discrimination and racism, and to help vulnerable migrants, I will also make the consultation with civil society, employers, trade unions and other relevant organizations to develop options to protect and support migrants and refugees*" (Johansson 2020).

In Greece, living conditions in open/closed facilities are harsh and inadequate (AIDA-ECRE 2021). In particular, "*social distancing is impossible when 1200 people share a single tap*". During the first months of 2020, "*over 40,000 refugees are [currently] being detained in five hotspot facilities on Lesvos, Chios, Samos, Leros and Kos*" (Bilgin and Fyssa 2020). Alarming analyses of media stated that evacuated measures for the camps must have taken place and that people living in them were very concerned (Medecins sans Frontieres 2020; Papanicolaou 2020). In addition, the camp at Moria, which was built for 2757 in 2020, accommodated 18,985 persons, which is 6.8 times over its capacity, without taking into account that the majority of refugees are living in olive groves adjacent to the camp in self-made shelters and tents. (Bilgin and Fyssa 2020). Greek Authorities implemented specific measures to the said facilities (Greek Ministry of Migration and Asylum 2020; Mitarakis 2020), but most of them are "*cosmetic in nature*" because they ignore the real existing conditions that can exacerbate the transmission of the disease as the "*general hygienic rules*" were de facto impossible to be followed by the population living therein (Bilgin and Fyssa 2020). This was much more so especially in view of the tangible reality of the "*prolonged reception*" that created a limbo situation for the host migrant-refugee populations and persistently deteriorating living conditions in camps and hotspots (Tsiganou et al. 2020). Furthermore, the social control of migrants has been intensified through a new legislative Act which foresees that the administrative detention can reach up to 36 months (Law 4636/2019). The Act also provides the State can replace the open facilities in force with closed reception and identification centers and create new pre-departure detention establishments (Law 4686/2020). In addition, according to a new controversial but still pending Legislative Order, areas suitable for the establishment of 'closed' detention centers may be requisitioned for reasons of public interest, in order to address the extremely urgen<sup>t</sup> need to avoid endangering public order and public health (Legislative Act, Government Gazette A'28/10.02.2020).

In terms of access to healthcare, in July 2019, the criteria for third-country nationals and European citizens to receive Social Security Number (AMKA) became extremely strict in Greece. It is to be noted that AMKA is necessary for contacting the Greek Administration in the most important occasions as a result, until the advent of COVID-19 in 2020, a large part of the migrant and refugee populations in Greece has ceased to have unimpeded access to public health facilities, following the decision to abolish the AMKA for foreign nationals1. Among those who did not have access throughout the reporting period were children and unaccompanied minors (Amnesty International 2019), in violation of the general principles of the World Health Organization, the International Convention on the Rights of the Child and the European Directive 2013/33/EU. During this same period, there was no transitional legal provision until the Joint Ministerial Decision 717/2020 (Government Gazette B 199/31.01.2020) which was issued in the advent of the pandemic and foresees the Temporary Insurance and Health Care Number (PAYPA), which ensures the temporary access of the asylum seekers to the health care system and their potential access to the labor market, six months after their asylum application is submitted. In fact, PAYPA came into force in April 2020, that is almost nine months after the ban of asylum seekers from the healthcare system and four months after the pandemic seized the country and the world (Aggelidis 2020). PAYPA is assigned at the local Asylum Offices/Units, where the relevant application is to be registered. The rejection of the asylum application implies the automatic deactivation of PAYPA, while, on the contrary, in case of acceptance of the application, its AMKA is foreseen. Thus, the populations in question need to have their Special Security Number updated every time their status changes (applicant, claimant, beneficiary) in order to have access to health services. Any obstruction or delay cancels the said access. In addition, in case of a negative decision, their access to health services is nullified.

In any case, the above new legal arrangements make the migrant and refugee populations subject to a regime of constant control, intensified through health provisions since they are being permanently put under Damocles' sword for one of the basic human rights, that of access to health. Additionally, in violation of the principle of non-discrimination, the new conditions arising from the measures implemented to combat COVID-19 pandemic have unjustifiably extended the quarantine measures for the hosted migrant and refugee populations and, therefore, their perpetual exclusion. To mention an example, while the first 'quarantine' period (initial lockdown during March–April 2020) ended for the entire population in Greece, it continued exceptionally only for the migrant-refugee populations 'hosted' in camps, without, however, the measure to be officially justified as based to any 'epidemiological situation' within the camps/reception structures (Fouskas 2020) 2.
