| Summary: | Background In 2012, the Government of Spain enacted Royal Decree-Law (RDL) 16/2012 and Royal Decree (RD) 1192/2012 excluding undocumented immigrants from publicly funded healthcare services. We conducted a policy implementation analysis to describe and evaluate the legal and regulatory actions taken at the autonomous community (AC) level after enactment of 2012 RDL and RD and their impact on access to general healthcare and HIV services among undocumented immigrants.Methods We reviewed documents published by the governments of seven ACs (Andalucía, Aragón, Euskadi (Basque Country), Castilla-La Mancha, Galicia, Madrid, Valencia) from April 2012 to July 2018, describing circumstances under which undocumented immigrants would be able to access free healthcare services. We developed indicators according to the main systemic barriers presented in official documents to analyse access to free healthcare across the participating ACs. ACs were grouped under five access categories: high, medium-high, medium, medium-low and low.Results Andalucía provided the highest access to free healthcare for undocumented immigrants in both general care and HIV treatment. Medium-high access was provided by Euskadi and medium access by Aragón, Madrid and Valencia. Castilla-La Mancha provided medium-low access. Galicia had low access. Only Madrid and Galicia provided different and higher level of access to undocumented migrants in HIV care compared with general healthcare.Conclusions Implementation of 2012 RDL and RD across the ACs varied significantly, in part due to the decentralisation of the Spanish healthcare system. The challenge of healthcare access among undocumented immigrants included persistent systemic restrictions, frequent and unclear rule changes, and the need to navigate differences across ACs of Spain.
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