A/HRC/22/49/Add.1 allocated to the Ministry for Human Rights and Refugees has been about €1.5 million each year. These levels of funding are only a fraction of the levels considered adequate for full implementation. 37. A positive practice was the appointment in 2011 of four regional Roma coordinators and one Roma coordinator within the Ministry for Human Rights and Refugees. Coordinators support the implementation of national action plans. They work with communities and authorities to help inform and influence policy and programmes, to raise awareness within communities, and assist in the implementation of projects. There is also a Roma Board within the Council of Ministers, comprised of members from Roma associations. A ―Roma Census‖ was begun in November 2009 to provide a needs assessment, establish a database of Roma, and inform activities under the action plans. Data was collected on issues relating to citizenship and registration, health care, education, employment and housing. NGOs noted flaws in the data collection and a lack of incorporation of findings into action plan programmes. They called for the survey to be continued. 38. Many Roma lack identity and other documentation required for access to services and social assistance. Many children have not been registered due to factors such as home births and lack of information. Human Rights Watch reported that Roma displaced by the war or who have moved for economic reasons are often not registered in the localities where they live, leaving them unable to gain access to services that require registration in a canton or municipality. According to estimates from the Office of the United Nations High Commissioner for Refugees (UNHCR), up to 10 per cent of Roma are not in the public registry.12 Lack of a permanent address is a barrier to registration for those in informal settlements. UNHCR estimates that 5,000 people, mainly Roma, are at risk of statelessness and face obstacles to effective citizenship and access to their rights and entitlements. 13 A. Education 39. Access to quality education remains a significant concern for Roma. Despite education being key for Roma inclusion, the Action Plan on the Education Needs of Roma was finalized and adopted only in 2010. Its objective is to provide Roma with equal access to quality education at all levels. Evidence indicates that Roma access to education is uneven, with some localities achieving higher enrolment and retention rates and others demonstrating very little Roma inclusion in education. Information provided by UNICEF reveals that enrolment rates for Roma are comparatively low: only 2 per cent at preschool level, compared to 13 per cent for non-Roma; 69 per cent at primary school level, compared to 98 per cent for non-Roma; and only 23 per cent at secondary school level, compared to 92 per cent for non-Roma. 40. Roma representatives commonly expressed concern about high drop-out rates from primary and secondary schools. While few reliable statistics exist, evidence suggests negative rather than positive trends in some localities. Roma representatives in Kakanj, for example, noted that in 2010/11 a total of 146 Roma children were in school. In 2012 the total was 104; much of the decrease was due to drop-out. Attendance in secondary schools is particularly poor for Roma. In 2011, 11 children were in secondary school, while in 2012 the figure had dropped to only 3, according to community representatives. 12 13 Cited in Human Rights Watch, ―Bosnia and Herzegovina‖, country summary (January 2012). Available from www.hrw.org/sites/default/files/related_material/bosnia_2012.pdf. ―2012 UNHCR country operations profile – Bosnia and Herzegovina‖. Available from www.unhcr.org/pages/49e48d766.html. 11