During her Union Budget speech five years ago, Finance Minister Nirmala Sitharaman had announced a vehicle scrapping policy under ‘health and wellbeing’ but had not mentioned mental health at all. I was so deeply disappointed by this omission that since then, I chose not to review any Union Budget (All references to “I”/“my” in this article refer to the first author).

My disappointment was especially exacerbated particularly by the timing. The Union Budget 2021-22 was presented during the COVID-19 pandemic, after the first wave had already upended lives, livelihoods and collective mental resilience, and barely two months before the devastating second wave arrived.

That five year long disappointment was finally punctuated by the words “applied psychology and behavioural health” in the Budget 2026-27 speech today.

Under the section “Creation of Professionals for Viksit Bharat”, FM Sitharaman stated that “Existing institutions for Allied Health Professionals (AHPs) will be upgraded and new AHP Institutions established in private and Government sectors. This will cover 10 selected disciplines, including optometry, radiology, anesthesia, OT Technology, Applied Psychology and Behavioural Health and add 100,000 AHPs over the next 5 years.”

Later, “reaffirming [her government’s] commitment to mental health”, the Finance Minister declared that “There are no national institutes for mental healthcare in north India. We will therefore set up a NIMHANS-2 and also upgrade National Mental Health Institutes in Ranchi and Tezpur as Regional Apex Institutions.”

Let’s unpack these announcements and the budgetary allocations for mental health beyond the headlines. This article does not attempt an exhaustive analysis; rather, it offers a preliminary commentary to frame the key issues and implications.

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Allied Health Professionals

The National Commission for Allied and Healthcare Professions Act, 2021 was passed by the Parliament of India five years ago. Only now has the government announced a dedicated scheme for the development of allied health professionals.

The government has allocated ₹1,000 crore under the Scheme for Allied Health Care Professionals (AHPs). As stated earlier, the scheme will cover 10 disciplines, and over the next five years, add an average of 20,000 AHPs per year. Of these, the average number of mental health, no, behavioural health professionals (BHPs) to be added is 2,000 per year.

This raises a critical question. India already has hundreds of institutions offering courses in psychology and graduating thousands of students. Will this scheme cover them or is it limited to only 2,000 BHPs?

Wait, there won’t be 2,000 psychology professionals, actually.

The category titled “Community Care, Behavioural Health Sciences and Other Professionals” is a broad umbrella that also includes ecologists, environmental protection officers, occupational and safety health officers, social workers, podiatrists, and palliative care professionals. Consequently, the actual number of psychology professionals supported under the scheme may be lower than even 500 per year.

And before we consider this lower number also, what about the tens of thousands of psychology graduates already in the system, trained and qualified, yet struggling to find clear pathways, formal recognition and meaningful employment?

NIMHANS-2

It is true that North India does not have a dedicated national mental healthcare institute. In that context, the announcement of establishing a NIMHANS-like institution is a welcome step. However, it remains only an announcement. No dedicated budget has been allocated by the government for setting up the new NIMHANS.

Similarly, no budgetary provision has been announced for the upgradation of the “National Mental Health Institutes in Ranchi and Tezpur as Regional Apex Institutions.”

It is possible that allocations for these institutions may have been subsumed under other budget heads. However, a review of allocations under the Ministry of Health and Family Welfare indicates that no funds have been specifically earmarked for these institutions under any head.

Tele MANAS

The National Tele Mental Health Programme (Tele MANAS) seeks “to provide universal access to equitable, accessible, affordable and quality mental health care through 24x7 tele-mental health counselling services as a digital component of the National Mental Health Programme (NMHP) across all Indian States and UTs with assured linkages.”

In the Union Budget 2025-26, Tele MANAS received ₹79.60 crore. This year, the figure has fallen sharply to ₹51.14 crore, a reduction of 35.75%. More tellingly, of the ₹79.60 crore provided last year, only ₹45 crore has been projected to be actually spent in the Revised Estimates. This has become a recurring feature of mental health schemes: not only do allocations fail to rise, even the amounts set aside are often left unutilised.

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National Mental Health Programme (NMHP)

Tele MANAS was launched apparently as a digital component of the NMHP in the aftermath of the COVID-19 pandemic, on World Mental Health Day in 2022. Since then, the government has announced a separate annual budget for Tele MANAS. However, allocations for the NMHP are no longer known, as the programme has been subsumed under the line item Tertiary Care Programme (TCP).

The TCP also includes the Tobacco Control and Drug De-addiction Control Programme, Assistance for Capacity Building for Trauma Centres, the National Programme for Prevention and Control of Cancer, Diabetes, Cardiovascular Diseases and Stroke, Health Care for the Elderly, the National Programme for Blindness, and Telemedicine. All TCP schemes together received ₹483.54 crore in the Union Budget 2025–26, which has increased marginally to ₹490 crore this year. However, the original ₹483.54 crore figure itself has been revised downward to ₹295 crore in FY26.

It is now known to everyone that the NMHP and the District Mental Health Programme have failed to deliver for decades. Yet, no serious corrective steps have been taken to address structural weaknesses or to expand mental health services in villages and small towns. Without transparent budgeting and focused implementation, the treatment gap is only widening.

Other Allocations

As in previous years, the allocations for NIMHANS and Lokpriya Gopinath Bordoloi Regional Institute of Mental Health, Tezpur have been increased.

But the allocation for The National Trust for the Welfare of Persons with Autism, Cerebral Palsy, Mental Retardation [again, why do we still have this phrase in this law?] and Multiple Disabilities has stayed the same at ₹35 crore. In the Union Budget 2020-21, the proposed outlay for the National Trust was ₹39.50 crore. It is disappointing that even after six years, allocations have not crossed that level.

The outlay for the Scheme for Implementation of the Persons with Disabilities Act has risen marginally from ₹115 crore to ₹125 crore. This, however, represents a sharp decline from the Revised Estimates of ₹200 crore.

Similarly, the allocation for the National Action Plan for Drug Demand Reduction has remained flat at ₹333 crore, again significantly lower than the Revised Estimates of ₹420 crore.

So what has increased substantially?

Bureaucracy.

Salary and pension expenditures under the Department of Health and Family Welfare have risen by around 15%, even as the department’s overall budget has grown by only about 9.5%.

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Economic Survey

In the Economic Survey 2025-26, the term ‘mental health’ appears twenty-seven times across Chapters 11 and 14, but most mentions are perfunctory. The subject is largely framed around lifestyle and preventive care, missing both the urgency of the crisis and the deep gaps in public mental healthcare delivery.

The Survey name drops NIMHANS, Tele MANAS and National Mental Health Survey without any insightful linkages with structural drivers, thus watering the canopy and missing the roots. There is limited discussion on key drivers of mental health outcomes in India such as unemployment, educational pressure, socioeconomic inequalities, gender disparities, and stigma. The issue of suicide is mentioned only in terms of its relation with social connectedness as the only determinant. It is mere minimisation of the problem suicide in India missing the realistic picture.

The discussion on the mental health impact of the misuse and abuse of digital technology and AI primarily serves as a foundation for the Promotion and Regulation of Online Gaming Act, 2025, . While the legislation aligns with global regulatory trends, it lacks India-centric data, patterns, and inferences. It concludes with the following:

“A major challenge in addressing digital addiction in India is the lack of comprehensive national data on its prevalence and mental health effects. This hinders targeted intervention, resource allocation, and integration of digital wellness into national mental health strategies. The upcoming Second National Mental Health Survey (NMHS), led by NIMHANS and commissioned by MoHFW, is expected to generate empirical and actionable insights into the prevalence of mental health issues in the Indian context.”

Here’s the core issue: the first NMHS was conducted more than a decade ago. What concrete actions did the government take on that survey’s “empirical and actionable insights”? None. The situation on the ground remains unchanged.

But let us give credit where it is due.

The government has finally applied to mental health the first principle of policy PR: an announcement is enough to generate positive headlines; actual action be damned.

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As you already know, last Thursday, Finance Minister Nirmala Sitharaman presented interim budget.  There is a tradition of not presenting a full budget before the General Elections to the Lok Sabha.

I took this opportunity to analyse the fund allocations and expenditure for the mental healthcare sector in India in the last five years. If you have not read the analysis yet, I urge you to go through the article linked below.

You can also read this Twitter thread analysing the same.

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Read the article and Twitter thread? Let us return to the title of this post.

The General Elections to the Lok Sabha are going to be announced soon. Many of the political parties, large and small, will come up with their manifestos making various promises to get our votes. Although health issues do find space in the manifestos, mentions of mental health are rare.

We need to change this. As a mental health student/professional/advocate, what are your expectations from an election manifesto? What do you want? Please offer your suggestions in the comment section, or you can email to gulzar [at] duck [dot] com. If you have already written about it anywhere, including on social media, please feel free to share the link.

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It is a cliché that the governments do not make major announcements in an interim budget presentation. The interim budgets usually represent the continuity of the government’s ongoing schemes and priorities. As such, the common wisdom dictates that not much should be expected from an interim budget nor should it be analysed with as much scrutiny as the general budgets.

However, if the budgets are vision documents of a government, then the interim budgets, as they come before the general elections, provide us with an opportunity to investigate how that vision was implemented during its term. So in this article, I will briefly analyse the budget allocations and expenditure under Indian government’s programmes related to mental health since 2019.

A not-much-discussed data point of the budget is the actual expenditure. The news providers often focus on the funds allocated for the next year, but skip the discussion about how much of the funds allocated in earlier budgets for the same schemes were actually spent by the government.

One reason for this phenomenon may be that the actual expenditure figures come two years later. For instance, the data for the budget allocations made in 2022 has been published in 2024. The expenditure details of announcements made in the 2024 budget will be provided in 2026, and on that day, as expected, the news providers will focus on the announcements made in the new budget.

But for better policymaking and implementation of programmes, it is important to scrutinise the actual expenditure data, along with the latest announcements.

For this analysis, I have taken data from the Financial Year (FY) 2019-20 through the current FY.

The Union government does not have a single, dedicated programme for mental healthcare. Rather, the allocations are made under different departments in different ministries. Hence, it can be difficult, sometimes impossible, to identify and track the funds allocated and spent on mental healthcare.

The major identifiable line items are the National Institute of Mental Health and Neuro-Sciences, Bengaluru (NIMHANS), Lokopriya Gopinath Bordoloi Regional Institute of Mental Health, Tezpur (LGBRIMH), Deendayal Disabled Rehabilitation Scheme (DDRS), Scheme for Implementation of Persons with Disability Act 2016 (SIPDA), National Action Plan for Drug Demand Reduction (NAPDDR), the National Trust for Welfare of Persons with Autism, Cerebral Palsy, Mental Retardation [why do we still have this phrase?] and Multiple Disabilities, and National Tele Mental Health Program.

Before we dive in, let us define a few terms:

Budget Estimates (BE): the funds allocated to a department/ministry/scheme at the time of budget presentation (on February 1 every year)

Revised Estimates (RE): the allocation amount arrived after mid-year review, after taking into account the trend of expenditure, new requirements, etc

Actual Expenditure (AE): the funds actually spent by the government (figures usually available two years after the BE announcement)

Let us analyse these now:

Ministry of Health and Family Welfare

The following allocations have been made under the Ministry of Health and Family Welfare.

National Institute of Mental Health and Neuro-Sciences, Bengaluru (NIMHANS)

Leading mental healthcare institution of the country, NIMHANS has been allocated Rs 850 crores in the interim budget, up 17.87% from last year’s Rs 721.15 crores. Since 2019, the BE for NIMHANS has gone from Rs 450 crores to Rs 850 crores, showing an enhancement of 88.89%.

NIMHANS has consistently utilised all the funds allocated in the budget and even received more money from the government during all the last five years. Its RE and AE have always been higher than the BE during this period. During FY 2021-22, the actual expenditure of NIMHANS surpassed even the revised estimates.

In case you did not know, NIMHANS is currently undertaking the second National Mental Health Survey in all the states and UTs of the country. Check out the Survey website here.

Lokopriya Gopinath Bordoloi Regional Institute of Mental Health, Tezpur (LGBRIMH)

One of the oldest mental healthcare institutions in India, LGBRIMH is located in Tezpur town of Assam.

In the interim budget, it has been allotted Rs 60 crores, down 5.75% from last year’s Rs 63.66 crores. Despite increasing BE, RE and AE in between, its FY 2024-25 allocation of Rs 60 crores is still equal to that of FY 2019-20. It does not bode well for an institution to have the same amount of budget allocation even after five years.

On utilisation front too, LGBRIMH’s record does not inspire confidence. It actual expenditure has always been less than the budget estimates except for FY 2021-22.

Given the LGBRIMH’s standing as a premier institution of mental healthcare in India’s North East, the government should not only enhance its budget, but also encourage the institution authorities to fully utilise the allocated funds.

National Tele Mental Health Program (T-MANAS)

Announced in the Union Budget 2022-23, the T-MANAS was launched on 10 October, 2022 (World Mental Health Day). A toll-free, 24/7 helpline number 14416 has been set up under this scheme. NIMHANS is the nodal centre with T-MANAS cells set up in various states of the country.

The budget allocation for this programme for the FY 2024-25 is Rs 100 crores, down 25.22% from last year’s BE of Rs 133.73 crores.

Compared to budget allocations, the utilisation of funds under T-MANAS is quite little. In FY 2022-23, the utilisation percentage stood at mere 54.12%. The last year’s allocation of Rs 133.73 crores has also been revised down to Rs 65 crores, a decrease of 51.39%.

The government needs to look into the reasons for such high underutilisation of funds in T-MANAS and should take steps to ensure 100% actual expenditure.

Earlier, the government used to provide separate figures for the National Mental Health Programme (NMHP), but now it has been subsumed under the Tertiary Care Programme. It should be noted that the track record of fund utilisation under the NMHP and District Mental Health Programme has been extremely poor, which might be one of the reasons for removing the NMHP as a separate line item from the budget documents.

Moreover, the government does not provide allocations and expenditure data for the Central Institute of Psychiatry, Ranchi separately. These are part of the Establishment Expenditure of the Centre under line item Other Hospitals/Institutions.

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Ministry of Social Justice and Empowerment

The following mental healthcare related allocations have been made under the Ministry of Social Justice and Empowerment.

Deendayal Disabled Rehabilitation Scheme (DDRS)

The Government of India runs a National Program for the Welfare of Persons with Disabilities including several schemes. Some of these are Deendayal Disabled Rehabilitation Scheme (DDRS), Scheme for Implementation of Persons with Disability Act 2016 (SIPDA), and the National Trust for Welfare of Persons with Autism, Cerebral Palsy, Mental Retardation and Multiple Disabilities. Although funds are spent on mental healthcare through these schemes, their exact amounts cannot be determined from the available data.

The Department of Empowerment of Persons with Disabilities runs the Deendayal Disabled Rehabilitation Scheme for, inter alia, the rehabilitation of the persons of persons with mental illness. It includes establishing half way homes, providing vocational training, reskilling, and counselling beneficiaries and families to facilitate integration into families and society/community.

For FY 2024-25, Rs 165 crores has been allocated for the DDRS, up 26.92% from Rs 130 crores last year.

The utilisation of funds under the DDRS has ranged from 63.98% to 91.75%, except for the FY 2019-20, when it peaked at 135.48%.

Scheme for Implementation of Persons with Disability Act 2016 (SIPDA)

Under this scheme, the Union government provides financial assistance to various bodies to, inter alia, provide barrier free environment for the persons with disabilities (PwDs), make government websites accessible to PwDs, establish skill development centres, run awareness campaigns, organise camps for issuance of disability certificates, provide pre-school training for children with disabilities, promote research and development activities in disability rehabilitation, organise sports events, and establish early diagnostic and intervention centres.

In the interim budget, the government has allocated Rs 135.33 crores for the Scheme for Implementation of Persons with Disability Act 2016, down 9.78% from the FY 2023-24 BE of Rs 150 crores.

The budget allocations for this scheme have consistently declined since 2019. The FY 2019-20 BE for SIPDA stood at Rs 315 crores, which has now come down to Rs 135.33 crores, amounting to a decrease of 57.04%.

SIPDA is also plagued by acute underutilisation of funds. The actual expenditure, as compared to the budget estimates, has ranged from a mere 27.28% in FY 2022-23 to 68.99% in FY 2019-20. Forget budget estimates, the actual expenditure under this scheme has never matched even the revised estimates.

The National Trust for Welfare of Persons with Autism, Cerebral Palsy, Mental Retardation and Multiple Disabilities

The National Trust “works towards providing opportunities for capacity development of Persons with Disability and their families, fulfilling their rights, facilitating and promoting the creation of an enabling environment and an inclusive society.”

For FY 2024-25, the BE for the National Trust is Rs 25 crores, down 28.57% from the last year’s BE of Rs 35 crores. Over the last five years, the allocations have declined twice, increased twice and stayed the same once.

The utilisation of funds has ranged from 75.44% to 100%.

National Action Plan for Drug Demand Reduction (NAPDDR)

The NAPDDR has been started from the FY 2020-21 by subsuming two schemes National Policy for Prevention of Alcoholism and Substance (Drugs) Abuse, and Scheme for Prevention of Alcoholism and Substance (Drugs) Abuse. For comparison purpose, I have combined the data for both the earlier schemes for FYs before 2020.

The NAPDDR has the following objectives:

a) Drug demand reduction in the country by focusing on preventive education, awareness generation, identification, counseling, treatment and rehabilitation of drug dependent persons, training and capacity building of the service providers through collaborative efforts of the Central and State Governments and non-governmental organisations; and

b) Create awareness and educate people about the ill-effects of drugs abuse on the individual, family, workplace and the society at large and reduce stigmatisation of and discrimination against, groups and individuals dependent on drugs in order to integrate them back into the society.

In the interim budget, the government has allocated Rs 314 crores for the NAPDDR, almost same as the year’s BE of Rs 311.

However, this scheme is also marred by consistent underutilisation of resources. It’s AE, as compared to the BE, has ranged from just 34.97% in FY 2021-22 to 48.76% in FY 2022-23 to 56.08% in FY 2019-20.

Probably due to such low use of funds, the budget allocations for the NAPDDR (or the earlier equivalent schemes) declined between FY 2019-20 and FY 2022-23.

Other allocations related to mental healthcare also exist such as those to the Ministry of AYUSH, Rehabilitation Council of India, National Institute of Public Cooperation and Child Development (NIPCCD), and various health institutions with psychiatry and psychology departments. However, the data for the mental healthcare component is not available in such allocations and expenditures.

Conclusion

1. As much as the focus of the government should be on enhancing budget allocations for various schemes, emphasis should also be placed on the complete utilisation of the funds. Even new schemes like T-MANAS started with much fanfare are not fully utilising their allocations. A country with a treatment gap as high as 92% cannot afford underutilisation of even one percent.

2. The government should prioritise the implementation of the National Mental Health Policy 2014, the Mental Healthcare Act 2017 and the National Suicide Prevention Strategy 2022 by allocating adequate dedicated funds for them. Even after a decade, the goals of the 2014 Policy are at the starting point. Last year, the Parliamentary Standing Committee on Health and Family Welfare pointed out that most of the issues highlighted by the NMHS 2015-16 remained almost the same even in 2023.

3. The government does not provide sufficient data for many schemes related to mental healthcare. Mental healthcare sector has to deal with the hellish trinity of low budget allocations, gross underutilisation of funds and non-availability of required data. For ensuring the proper implementation and effectiveness of the schemes, the government should collect adequate data and make it available to the public for scrutiny and analysis.

4. A few institutions such as the National Trust for Welfare of Persons with Autism, Cerebral Palsy, Mental Retardation and Multiple Disabilities, and the Rehabilitation Council of India are in need of urgent reforms. Even the legislations founding them need to be examined and revised.

5. As I have written elsewhere, a Minister of State in the Ministry of Health and Family Welfare should be made in charge of mental healthcare sector for the effective implementation of the schemes and programmes.

   

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This article is the third and last part of my review of the Report. You can read the Part I here and Part II here.

For easier reading and to save your time, I have provided a summary of the recommendations and criticism of the Report below. You may scroll down to read it.

Chapter III: National Mental Health Programme and Mental Healthcare Infrastructure

On 25^th January 2023, the National Human Rights Commission said its officials had visited all 46 government run mental healthcare institutions across the country. It said all of the institutions “are in deplorable conditions and depict a very pathetic handling by the different stakeholders. The inhuman and deplorable conditions of the mental health institutes recorded by it across the country, present sorry states of affairs amounting to infringement of the human rights of mentally ill patients. The cured patients are being kept illegally in the hospitals. There is acute shortage of doctors and staff.”

Taking a note of this report, the Parliamentary Standing Committee on Health and Family Welfare asked the Union government to “put concerted efforts to strengthen the infrastructure, capacity, and facilities and upgrade these institutions to generate more human resources” and make them “centres of academic research”.

National Mental Health Programme

The National Mental Health Programme (NMHP) was established in 1982 to provide mental health services at the primary level. The District Mental Health Programme (DMHP) was included in the NMHP in 1996. In 2009, the government added the Manpower Development Scheme under which it has established/approved 25 Centres of Excellence and 47 postgraduate departments in mental health specialities of psychiatry, clinical psychology, psychiatric social work, and psychiatric nursing.

District Mental Health Programme

As per the Report, the DMHP is being run in 704 districts across all 36 states/UTs of the country. In every DMHP team, there should be one psychiatrist, one clinical psychologist, one psychiatric social worker, one psychiatric nurse, one community nurse, one monitoring and evaluation officer, one case registry assistant and one ward assistant. The Report does not tell us if all the covered districts have the required staff.

Further, the government reported that as of 11th October 2022, out of the operational 1,21,649 Ayushman Bharat Health and Wellness Centres (AB-HWCs) in the country, 23,505 AB-HWCs (19%) were providing mental, neurological and substance use (MNS care services.

The Committee however said the funds allocated for the primary and secondary mental health facilities were far lower than required, adding that the expenditure (public and out-of-pocket) for treating mental illnesses was comparatively lower if mental issues could be screened early at the primary health centre and community health centre levels.

It asked the government to allocate more funds to mental healthcare schemes and “develop improved monitoring systems to oversee the functioning of the DMHP and to generate reliable data on the functioning of the DMHP.”

One question the Committee did not raise (and is not often considered in mental healthcare funding discussions) is that none of the states/UTs fully spent funds allocated to them under the DMHP in at least last ten years. Between 2014 and 2020, only five states had spent over 50% of the allocated funds. Delhi government’s performance was the worst and its expenditure stood at 0.000079% of the budget.

Human Resource in Mental Health

The Director, NIMHANS told the Committee that there were about 9,000 psychiatrists in the country. The Rehabilitation Council of India reported the number of clinical psychologists to be 2,840. The Government said it did not maintain data of mental health professionals.

Citing an Indian Journal of Psychiatry paper, the Committee said the nation needed 27,000 more psychiatrists to achieve the desirable number of 3 psychiatrists per 1,00,000 population. It, therefore, asked the government to continue the Manpower Development Scheme beyond 2024 (when it is scheduled to end).

Commenting on the issue of discontinuation of MPhil programmes as per the New Education Policy and its impact on MPhil Clinical Psychology courses, the Committee made the following recommendation:

“The Committee further recommends the Ministry to expedite the solution of the problem which has emanated due to the discontinuation of the M. Phil courses as per the New Education Policy. The Committee believes that Clinical Psychologist is an essential mental health resource and thus suggests that the Ministry may explore re-naming the course or any other alternative and thus relieve the candidates who have already joined for the course.”

Awareness Generation Programmes regarding Mental Health

Under the DMHP, the Union Government provides up to Rs. 4 lakh per year to each district for mental health awareness generation activities. The Committee recommended to “rope in popular personalities who have battled mental issues to spread awareness amongst the masses and encourage people to come out and seek help and treatment.” It also asked the Government to run campaigns on social media to reach adolescents and youth.

But it did not ask how those Rs 4 lakh per year were spent by the districts so far, or if they were spent at all.

Budgetary Allocation for Mental Health

Needless to say, the funding for mental healthcare in India is far from adequate. Neither the Union government nor state governments have ever prioritised budget allocations for mental health. As per the Committee, the scarcity of funds has perpetuated a stark disparity between the magnitude of the problem and the available support systems. Further, it wrote:

“The Committee, after analysing the budget numbers, is of the consensus that the budgetary allocation falls woefully short of meeting the escalating demand for mental health care, and it hinders the improvement of the existing infrastructure. Therefore, the Committee strongly recommends the Ministry of Health and Family Welfare to conduct an in-depth assessment of the current mental health infrastructure, identifying the gaps and deficiencies that need urgent attention. The Committee recommends the Government to allocate funds to establish and enhance regional mental health centres, ensuring accessibility and adequate services in remote areas.”

The Committee has also compared the budget of NIMHANS, Bengaluru with the United States’ National Institute of Mental Health (NIMH). The budget of NIMH for financial year 2023 was about 2.3 billion dollars, while that of NIMHANS was about 85 million dollars only! The NIMH’s budget is about 27 times of NIMHANS’s! The Committee asked the government to increase NIMHANS’s funding substantially so that it can “reach a broader population and invest in advanced research endeavours.”

For National Tele Mental Health Programme (T-MANAS), the budget allocation for current fiscal year is Rs 134 crore. The Committee appreciated the scheme as a “valuable initiative”, but asked the government to take “adequate measures to address the concerns regarding the security, privacy, and management of personal and sensitive data, considering the absence of robust data privacy regulatory frameworks in the country.”

It also cautioned that the scheme “cannot be viewed as a comprehensive solution for long-term mental health improvement, nor should it be the sole focus of the Government's efforts.”

Finally, the Committee asked the Government to include mental health parameters in the Sustainable Development Goals India Index to “track [India’s] progress in this area and identify areas where more work needs to be done.”

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Summary of the Review

In this part, I first summarise the findings and recommendations of the Committee and then my critical analysis of its omissions and commissions.

The aim of the Committee, in its own words, was to “examine the landscape of mental healthcare in India, regulatory structure, the status of mental health infrastructure, causes behind the high prevalence of mental health issues and the rising cases of suicides in the country.” As far as I know, it was for the first time that a Parliamentary Committee, outside of demand for grants and bills, took up the topic of mental health for examination.

Findings and Recommendations of the Committee

1. Relying on the National Mental Health Survey 2015-16 (NMHS 2015-16), the Committee noted that “about 150 million Indians are affected by some type of mental illness” and the lifetime prevalence was 13.7%. It highlighted the huge treatment gap that ranged between 70 to 92% for different disorders.

   It pointed out that most of the issues highlighted by the NMHS 2015-16 remained almost the same even in 2023. It flagged the “lack of mental health professionals, weak mental healthcare infrastructure, inadequate and inequitable access to mental health services, stigma and discrimination” as the reasons for huge treatment gap.

2. The Committee underlined the impact of the COVID-19 pandemic on the people’s psychosocial well-being due to “fear and uncertainty surrounding the virus”, isolation and limited social interactions because of the lockdowns, economics hardships such as loss of employment and financial instability, and lifestyle changes such as blurring of boundaries between personal and professional life resulting from work from home policy.

   To assess the impact of the COVID-19 pandemic on mental health, the Committee expressed the need of a new survey and recommended that the National Mental Health Survey - 2, scheduled to be completed in 2025, should be expedited. [NHMS-2 is being conducted in two phases: Phase 1 during October 2022 - Mar 2024 in 18 States/UTs and Phase 2 during April 2024 - March 2025 covering the remaining 18 states.]

3. As per the NMHS 2015-16, 7.3% of children aged 13-17 years lived with a mental disorder, but the prevalence almost doubled to 13.5% in the cities. The Committee recommended the government to

• work with employers and schools to implement workplace wellness programs and mental health education for students, respectively;

• add provisions in the second National Mental Health Survey (NMHS 2) to collect data on “mental health and psycho-social well-being of children, adolescents, youth and caregivers”;

• train mental health professionals specifically to address mental health concerns of children and youth; and

• develop “a dedicated cadre of school counsellors in all schools under the "Manodarpan" initiative”.

4. Suicides: To reduce the number of suicide attempts by the students, the Committee recommended the establishment of a 24x7 helpline to counsel students who could not qualify for competitive examinations. It asked the government “to strengthen surveillance mechanisms to track factors causing suicides and trends and thus devise mitigation strategies.”

   It also underlined that despite Section 115 of the Mental Healthcare Act, 2017 (the MHCA 2017) decriminalising the suicide attempt, the police personnel were largely unaware of this provision and continued to file cases under section 309 of the Indian Penal Code.

5. National Mental Health Policy 2014: The Committee said that “despite almost a decade since its introduction, the policy's progress has been limited” and “only a few states have embraced and implemented” its recommendations. For the proper implementation of the NMHP 2014 recommendations, the Committee recommended “formulating national and state-level action plan (s)”.

6. Central Mental Health Authority (CMHA): The Committee noted the CMHA was largely absent from public arena even after five years of existence and did not even have a website. Along with recommending the Government to develop its dedicated website, it asked the “the authority to release its annual report comprising of its vision, objectives, programmes implemented, achievements etc.”

7. State Mental Health Authorities (SMHA): Their public presence and performance are also similar to those of the CMHA. Although many states have established these bodies, the Committee noted, “efforts related to the appointment of ex-officio and non-official, appointment of CEOs, officers and other staff, development of mechanisms for complaints redressal and establishment of SMHA funds need further push in most of the States.”

   The Committee recommended the development of a tracker “to track the implementation status of the establishment of SMHAs, MHRBs [Mental Health Review Boards] and other determinants governing the development of mental health infrastructure and human resources.”

8. Prisoners with Mental Illness: The Committee noted that as per the NCRB, 1.7% of total prisoners were living with mental illnesses as on December 31, 2021.

   It recommended the Government to

   (a)   provide adequate training to the prison staff regarding mental healthcare;

   (b)  ensure that adequate mental healthcare staff is stationed in the prisons to address the needs of the inmates; and

   (c) conduct periodic training programs for police, judiciary and general health practitioners to sensitise them about their responsibilities and provisions of the MHCA 2017.

9. Mental Health Insurance: The Committee asked the Government to

   (a)   “develop a mechanism for monitoring the insurance delivery for mental health issues”;

   (b)  collect “data on policies covering mental health issues, total claims received for mental issues, total claims cleared, rejection of policies and reasons for rejection.”; and

   (c)   discourage the insurance companies from excluding outpatient services (such as counselling sessions) and treatment for suicide attempt from their policies.

10. Rights of Persons with Mental Illness (PMIs): The Committee recommended the government to

    (a) expedite the establishment of half way homes and to ensure that the treated patients who “don’t require to stay in mental health establishments are not redesignated to old age or beggar homes”;

    (b) establish vocational training centres in all districts and special employment exchange for PMIs; and

    (c) develop “a portal for real-time display of half-way homes established in all states and UTs, their capacity and occupancy, the facilities provided and the mental healthcare professionals available.”

11. Infrastructure: The Committee noted the statement of the National Human Rights Commission that all 46 government run mental healthcare institutions across the country “are in deplorable conditions and depict a very pathetic handling by the different stakeholders.”

    It asked the Union government to “put concerted efforts to strengthen the infrastructure, capacity, and facilities and upgrade these institutions to generate more human resources” and make them “centres of academic research”.

12. National Mental Health Programme (NMHP): The Committee said the funds allocated for the primary and secondary mental health facilities under the NMHP and the District Mental Health Programme (DMHP) were far lower than required. It stated that the expenditure (public and out-of-pocket) for treating mental illnesses was comparatively lower if mental issues could be screened early at the primary health centre and community health centre levels.

    It asked the government to allocate more funds to mental healthcare schemes and “develop improved monitoring systems to oversee the functioning of the DMHP and to generate reliable data on the functioning of the DMHP.” It also recommended focusing on  community-based care along with bio-medical approach.

13. To increase the number of mental health professionals in the country, the Committee asked the government to continue the Manpower Development Scheme beyond 2024 (when it is scheduled to end). It also recommended to solve the problem of MPhil Clinical Psychology that arose due to the discontinuation of the M. Phil courses as per the New Education Policy.

14. To generate awareness regarding mental health issues among the masses, the Committee recommended to “rope in popular personalities who have battled mental issues to spread awareness amongst the masses and encourage people to come out and seek help and treatment.” It also asked the Government to run campaigns on social media to reach adolescents and youth.

15. The Committee recommended to increase the budget allocations for mental healthcare substantially and asked to “allocate funds to establish and enhance regional mental health centres, ensuring accessibility and adequate services in remote areas.”

16. The Committee appreciated the National Tele Mental Health Programme (T-MANAS) scheme as a “valuable initiative”, but asked the government to take “adequate measures to address the concerns regarding the security, privacy, and management of personal and sensitive data, considering the absence of robust data privacy regulatory frameworks in the country.” It also cautioned that the scheme “cannot be viewed as a comprehensive solution for long-term mental health improvement, nor should it be the sole focus of the Government's efforts.”

17. The Committee asked the Government to include mental health parameters in the Sustainable Development Goals India Index to “track [India’s] progress in this area and identify areas where more work needs to be done.”

Criticism of the Report

1. Perhaps the most significant criticism of this Report is that it adds nothing new to our understanding of mental healthcare frameworks, infrastructure, and funding in the country.

   The Committee appears to have seen only what the government showed. It reported only those omissions and commissions which the government acknowledged. From the Report, it appears that the members did not ask relevant and difficult questions to hold the government accountable. In some cases, even basic information was not provided to the Committee. By not pressing for data, the Members of Parliament let the Government escape its responsibility easily.

2. Citing the NMHS 2015-16, the Committee wrote that “despite years of research and a continued focus on improving health systems, changes seen in the mental health field are few and limited.” My question: where are the “years of research and a continued focus on improving health systems”? Forget continued focus, other than spilling ink on paper in the form of a few laws and policies, I have not seen a single attempt on ground by the Union Government to improve mental health systems.

3. On government response to mental health issues during the COVID-19 pandemic, the Committee simply accepted its submissions without asking if the reported initiatives — a helpline and a few guidelines — were sufficient. The Committee did not demand data about, for instance, the number of people who called the helpline, their issues, and if they were solved. It did not ask if the guidelines were effective. Most importantly, it did not ask that during a once-in-a-century pandemic, was issuing guidelines and launching a telephone helpline the most a government could do for the mental health of 140 crore Indians?

4. On the National Mental Health Survey - 2, the Committee wrote: “[it] is of the firm opinion that the findings from the Survey will serve as crucial evidence for policymakers to take informed decisions related to mental health funding, infrastructure development, and evidence-based interventions.”

   My question: did the first Survey compelled the policymakers to take informed decisions related to mental health funding, infrastructure development, and evidence-based interventions? If the past is the best predictor of the government’s performance, then who can deny that the second Survey will also not be worth the paper it will be printed on?

5. Some of the mistakes in the Report seem to show that none of the Committee members read the draft before signing it. For instance, the Committee stated that the “The [the MHCA Act 2017] does not explicitly address the issue of periodic review and updating of advance directives.” But the Section 8(1) of the Act provides for it:

   “An advance directive made under section 6 may be revoked, amended or cancelled by the person who made it at any time.”

   On page 16 of the Report, there are mistakes in even copying and pasting sentences from the note supplied by the Ministry of Health and Family Welfare.

   The figures 9 and 10 on page 34 seek to compare the budgets of the NIMHANS, Bengaluru and the National Institute of Mental Health, USA. But the both figures are identical and provide incorrect information.

6. In several cases, the Committee did not ask the government sufficient questions about the steps taken for the implementation of legal provisions and schemes it mentioned. For example, the mental health of children and youth after the NMHS 2015-16, the National Mental Health Policy, the rights of the prisoners with mental illness, implementation of mental health insurance, the National Mental Health Programme, the District Mental Health Programme, the National Suicide Prevention Strategy etc. Consequently, it let the government get away without even need to say ‘No Data Available’.

7. The Committee did not raise the fact that none of the states/UTs fully spent funds allocated to them under the DMHP in at least last ten years. Between 2014 and 2020, only five states had spent over 50% of the allocated funds. Delhi government’s performance was the worst and its expenditure stood at 0.000079% of the budget. The MPs did ask why even the minuscule allocations were not used by the governments.

8. The Committee did not ask why even after repeated recommendations in its previous reports (especially those pertaining to the demand for grants), the government had not enhanced budget allocations for mental healthcare. It was perhaps the most important question, but the Report neither raises it nor answers it.

9. The Committee held meetings with NGOs like Manas Foundation, New Delhi and Ashadeep, Guwahati. It claims to have received written submissions from various organisations and associations. Either the inputs provided by these stakeholders were not used or they were not of adequate quality, but their views are not a part of the Report.

10. Finally, the Parliamentary Standing Committee on Health and Family Welfare had a historic opportunity as, like I stated before, it was for the first time that a Parliamentary Committee, outside of demand for grants and bills, took up the topic of mental health for review. This Report could have resulted in a definitive document assessing the developments and deficiencies in mental healthcare sector in the last decade. Unfortunately, by not attempting to hold the government accountable, the Parliament has squandered away this historic opportunity.

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This article is the second part of my review of the Report. You can read the Part I here.

5. Mental Health Issues in Children and Youth

In its Report entitled ‘Mental Health Care and Its Management in Contemporary Times’, the Parliamentary Standing Committee on Health and Family Welfare has noted that according to the World Health Organisation, “around 8% of the world's young children (aged 5–9 years) and 14% of the world's adolescents (aged 10–19 years) live with a mental disorder.”

As per the National Mental Health Survey 2015-16 (NMHS 2015-16), 7.3% of children aged 13-17 years lived with a mental disorder, but the prevalence almost doubled to 13.5% in the cities.

The Committee did not ask the Government if it took any steps for the mental health of children and youth after the NMHS 2015-16, but recommended it to

• run awareness campaigns to “educate citizens about the importance of mental health and the role of behavioural aspects” and “promote healthy habits, coping skills, and ways to seek help when needed”;

• work with employers and schools to implement workplace wellness programs and mental health education for students, respectively;

• “invest in research to better understand the behavioural aspects that impact mental health and the effectiveness of different interventions”;

• add provisions in the second National Mental Health Survey (NMHS 2) to collect data on “mental health and psycho-social well-being of children, adolescents, youth and caregivers”;

• train mental health professionals specifically to address mental health concerns of children and youth; and

• develop “a dedicated cadre of school counsellors in all schools under the "Manodarpan" initiative”.

6. Rising Trends of Suicides in India

When the NMHS 2015-16 was published, the annual national suicide rate, as per the National Crime Records Bureau (NCRB), was 10.6 per one lakh population. In 2022, it reached 12.4, the highest since the Independence.

The Parliamentary Committee highlighted the leading categories of suicide victims such as men, students, farmers and agricultural labourers, daily wage earners, self-employed persons, and the employed, but did not mention the housewives, whose numbers are second only to the daily wage earners and who form the majority of female suicide victims.

This omission becomes even more glaring when you read the Committee’s this lament:

“The Committee notes that while more students committed suicide than farmers, the latter's suicides were termed a national crisis. However, suicides by students hardly caught anyone's attention and were dealt with on a case-to-case basis.”

The Committee recommended the establishment of a 24/7 helpline to counsel students who cannot qualify for competitive examinations.

Also, yes, the Report used the outdated language everywhere when referring to deaths by suicide.

Although the Committee took note of the National Suicide Prevention Strategy, it did not ask a single question about its implementation. Just another instance of it abdicating its duty to hold the government accountable and giving the latter a free pass.

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Let us now turn to the Report’s Chapter II entitled Mental Health Policy and Legislation. In this chapter, the Committee analysed the National Mental Health Policy 2014 (NMHP 2014) and the Mental Healthcare Act 2017 (MHCA 2017).

National Mental Health Policy 2014

Launched in 2014, the National Mental Health Policy (NMHP 2014) is a landmark document focusing on values like equity, justice, integrated and evidence based care, participatory and rights based approach, and holistic approach to mental health. It lays special emphasis on stigma, poverty, homelessness, persons inside custodial institutions, orphaned persons with mental illness, children of persons with mental illness, care givers, internally displaced persons, persons affected by disasters and emergencies, adequate funding, support for families, inter-sectoral collaboration, and continued monitoring and evaluation of mental health of people.

As the 10^th anniversary of the NMHP’s launch approached, the Parliamentary Standing Committee on Health and Family Welfare got a great opportunity in the form of this Report to evaluate its implementation by the Government of India and various state governments.   

As the Committee noted, the following are seven strategic action areas of the NMHP 2014:

(i)             effective governance and delivery mechanism for mental health;

(ii)           promotion of mental health;

(iii)         prevention of mental illness, reduction of suicide and suicide;

(iv)          universal access to mental health services;

(v)           improved availability of adequately trained mental health human resources to address the mental health needs of the community;

(vi)          community participation for mental health and development; and

(vii)        research.

The Committee begins its analysis of implementation of these strategic directions by declaring that “despite almost a decade since its introduction, the policy's progress has been limited” and “only a few states have embraced and implemented the outlined recommendations of the National Mental Health Policy”. It records that the execution of the Mental Healthcare Act, 2017 (MHCA 2017) and the National Suicide Prevention Strategy 2022 — brought on the recommendations of the NMHP 2014 — has been thwarted by the lack of budget allocations, and most of their provisions are still awaiting implementation.

On suicide, the Committee underlines that despite Section 115 of the MHCA 2017 decriminalising the suicide attempt, the police personnel were largely unaware of this provision and continued to file cases under section 309 of the Indian Penal Code. However, again, the Committee did not ask the Government why it had not implemented the Section 115 strictly.

For the proper implementation of the NMHP 2014 recommendations, the Committee recommended “formulating national and state-level action plan (s)”. Moreover, it said:

“The Committee further believes that the policy should be evaluated and reviewed periodically due to the constantly evolving landscape of mental health issues and the subsequent difficulty in implementing an all-encompassing policy like the NMHP.”

Guess who just dropped the ball when presented with an opportunity to evaluate and review its implementation?

Yes, the Parliamentary Standing Committee on Health and Family Welfare.

The Mental Healthcare Act, 2017 (MHCA 2017)

In 2017, the Parliament passed the Mental Healthcare Act, 2017 and it was implemented in 2018. The Act focuses on ensuring the protection of rights of persons with mental illness (PMIs) and mandates the governments to develop mental healthcare infrastructure for the realisation of these rights. The Committee evaluates several aspects of the MHCA 2017, beginning with the “critical examination” of advance directives.

Advance Directives

The Committee “believes” that for proper implementation of advance directives, both the public and professionals need to be made aware.

A great point, but then it says:

Did the Committee not read the Act before beginning its analysis?

Because its Section 8(1) says:

“An advance directive made under section 6 may be revoked, amended or cancelled by the person who made it at any time.”

Central Mental Health Authority (CMHA)

According to Section 43 of the MHCA 2017, the CMHA, inter alia, is responsible for

(a)   maintaining registers of all mental health establishments, clinical psychologists, mental health nurses and psychiatric social workers in the country;

(b)  developing quality and service provision norms for mental health establishments;

(c)   training law enforcement officials, mental health professionals and other health professionals about the provisions and implementation of the MHCA 2017; and

(d)  advise the Central Government on all matters relating to mental healthcare and services.

The CMHA was constituted in November 2018.

As expected, the Parliamentary Committee noted it was largely absent from public arena even after five years of existence and does not even have a website. From the Report, it appears that the Union Government told nothing about the CMHA, including its budget, to the Committee. That makes the CMHA as mysterious and mystical as the Research and Analysis Wing (R&AW) and the Intelligence Bureau (IB).

State Mental Health Authority (SMHA)

Under the MHCA 2017, the SMHAs are state level bodies with powers and functions similar to the CMHA. Unfortunately, their public presence and performance are also similar to those of the CMHA.

Although many states have established these bodies, the Committee noted, “efforts related to the appointment of ex-officio and non-official, appointment of CEOs, officers and other staff, development of mechanisms for complaints redressal and establishment of SMHA funds need further push in most of the States.”

The Committee recommended the development of a tracker “to track the implementation status of the establishment of SMHAs, MHRBs [Mental Health Review Boards] and other determinants governing the development of mental health infrastructure and human resources.”

Prisoners with Mental Illness

Section 31(2) of the MHCA 2017 mandates the governments to “train… all medical officers in the prisons or jails to provide basic and emergency mental healthcare” and section 103 provides for the procedure of treatment of prisoners with mental illness.

The Committee noted that as per the NCRB, 1.7% of total prisoners were living with mental illnesses as on December 31, 2021.

It recommended the Government to

(a)   provide adequate training to the prison staff regarding mental healthcare;

(b)  ensure that adequate mental healthcare staff is stationed in the prisons to address the needs of the inmates; and

(c)   conduct periodic training programs for police, judiciary and general health practitioners to sensitise them about their responsibilities and provisions of the MHCA 2017.

Again, no questions about what the Government had already done or not done.

Mental Health Insurance

As you know, the Section 21(4) of the MHCA 2017 states:

To implement this provision, the Insurance Regulatory and Development Authority of India (IRDAI) has issued notifications from time to time.

The Report does not provide data on the insurance companies which have implemented this provision in their policies. It appears the Government gave the NDA (No Data Available) response to the Committee.

The Committee asked the Government to

(a)   “develop a mechanism for monitoring the insurance delivery for mental health issues”;

(b)  collect “data on policies covering mental health issues, total claims received for mental issues, total claims cleared, rejection of policies and reasons for rejection.”; and

(c)   discourage the insurance companies from excluding outpatient services (such as counselling sessions) and treatment for suicide attempt from their policies.

Rights of Persons with Mental Illness (PMIs)

The Chapter V of the MHCA 2017 focuses on the Rights of Persons with Mental Illness, but the Committee has mistakenly titled the chapter as the Rights of Persons with Disabilities.

This Chapter, inter alia, establishes the rights of the PMIs to access mental healthcare and live with dignity in the society, right to protection from cruel and degrading treatment, mandates availability of mental health services in each district, and in case of the PMIs abandoned by their families, asks the government to establish “less restrictive community based establishments including half-way homes, group homes and the like for persons who no longer require treatment in more restrictive mental health establishments such as long stay mental hospitals.”

The Department of Empowerment of Persons with Disabilities told the Committee that it was running the scheme Deendayal Disabled Rehabilitation Scheme (DDRS) for establishing half way homes for rehabilitation of the PMIs. The Department was also working on rehabilitation of the PMIs “through vocational training, reskilling, and counselling beneficiaries and families to facilitate integration into families and society/community.”

The Committee recommended the government to

(a)   expedite the establishment of half way homes and to ensure that the treated patients who “don’t require to stay in mental health establishments are not redesignated to old age or beggar homes”;

(b)  establish vocational training centres in all districts and special employment exchange for PMIs; and

(c)   develop “a portal for real-time display of half-way homes established in all states and UTs, their capacity and occupancy, the facilities provided and the mental healthcare professionals available.”

As with other provisions, the Committee did not ask the government important questions about the violation of rights of the PMIs as well.

Throughout the Report so far, the Committee has expressed only empty laments on the state of mental healthcare in India, but did nothing to hold the government accountable.

Further, surprisingly, or may be not surprisingly, the Committee did not even mention the National Commission for Allied and Healthcare Professions Act 2021 in the Report, despite the fact that a large majority of mental health professionals are mandated to be registered under this law.

Finally, perhaps the most alarming aspect of this Report is that the Members of Parliament saw only what the government showed. They questioned only those omissions and commissions which the government acknowledged. I can assert with reasonable certainty that none of the Committee members did any preparation before the meetings to question the government representatives. I can assert with even more certainty that no member read the Report before signing it.

If you don’t trust me, I leave you with this screenshot from the Report.

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Next Tuesday, I will review the Chapter III entitled National Mental Health Programme and Mental Healthcare Infrastructure.

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psytizenship is back. Thank you for your subscription. Special thanks to all the subscribers and strangers who asked why I had stopped writing here. It gave me motivation to start again. From now on, the articles will be published every Tuesday.

As we begin again, I want to state this, in case you did not know: psytizenship is pronounced same as citizenship, not ‘saitizenship’. The idea is simply that the psychologists should be citizens aware of policy and legal developments, particularly those relevant to their profession. psytizenship is a small effort in that direction.

Let us dive into the article now.

Last year, on August 4, the Department-Related Parliamentary Standing Committee on Health and Family Welfare presented a report on the subject ‘Mental Health Care and Its Management in Contemporary Times’.

[For the uninitiated, the Parliamentary Standing Committees comprise Members of Parliament belonging to Lok Sabha and Rajya Sabha. These Committees examine various matters, including budget and bills, related to the departments and ministries of the Union Government and are supposed to play a vital role in holding the government accountable.]

This article is the first in a mini-series of my articles highlighting and evaluating the analysis and recommendations of the ‘Mental Health Care and Its Management in Contemporary Times’ report. The Parts II and III will be published over the next weeks. [As much as possible, I want to limit every article to 1000-1500 words so that it is easy to read for the subscribers.]

The aim of the Committee for taking up this subject, in its own words, was to “examine the landscape of mental healthcare in India, regulatory structure, the status of mental health infrastructure, causes behind the high prevalence of mental health issues and the rising cases of suicides in the country.”

To examine the subject, the Committee held multiple meetings between October 2022 and March 2023. It heard the officials of Ministry of Health and Family Welfare, Ministry of AYUSH (Ayurveda, Yoga and Naturopathy, Unani, Siddha and Homeopathy), Department of School Education and Literacy, Department of Biotechnology, Department of Empowerment of Persons with Disabilities, NITI Aayog, Institute of Human Behaviour and Allied Sciences (IHBAS), New Delhi, and Central Institute of Psychiatry (CIP), Ranchi. It also held meetings with the two NGOs - Manas Foundation, New Delhi and Ashadeep, Guwahati.

The Committee, "to understand the ground realities", visited the National Institute of Mental Health and Neuro Sciences (NIMHANS), Bengaluru and Lokopriya Gopinath Bordoloi Regional Institute of Mental Health (LGBRIMH), Tezpur, Assam.

In November, 2022, the Committee also requested views from stakeholders and the public. I am not aware if any psychology association sent a memorandum to the Committee. If you know of any association that did so, please let me know so I can add their name here.

Further, as far as I know, it was for the first time that a Parliamentary Committee, outside of demand for grants and bills, took up the topic of mental health for examination. Especially after the COVID-19 pandemic, the Committee was presented with a historic opportunity to study the mental health landscape in India and hold the government accountable for its omissions and commissions.

Although the Report is of 65 pages, its substance comprises only of 40 pages, excluding the pages before the Introduction and the last 19 pages, which just repeat the observations and recommendations of the Committee. That the Members of the Committee required only 40 pages to examine the entire gamut of mental health care in India and give their recommendations was the first thing I could not digest about the Report. However, hoping it had the saying ‘brevity is the soul of the wit’ on its side, I dived into it.

The Report is divided into three chapters entitled (A) Introduction, (B) Mental Health Policy and Legislation, and (C) National Mental Health Programme and Mental Healthcare Infrastructure. I review the most of the first chapter in this article.

The Chapter I focuses on the present status of the mental health issues in India, the results of the National Mental Health Survey 2015-16 (NMHS), effect of the COVID-19 pandemic on mental health, the mental health issues in children and youth, and suicides. Let us analyse them one by one.

1.     Present status of mental health issues in India: In this section, the Committee has highlighted some common challenges to mental health. Two of them stood out to me: environmental and geopolitical issues, and migration. On migration, the report says: “Migrants often face stressors such as adapting to a new culture, language barriers, discrimination, financial difficulties, and social isolation. These factors can significantly impact an individual's mental well-being and increase the risk of developing mental health problems such as anxiety, depression, and post-traumatic stress disorder.”

I appreciate the fact that the Committee recognised these challenges.

2.     National Mental Health Survey 2015-16 (NMHS 2015-16): As per the Committee, the NMHS 2015-16 "provided valuable insights into the state of mental health in India and offered a comprehensive overview of the challenges and gaps in addressing mental health issues." It noted that “about 150 million Indians are affected by some type of mental illness” and the lifetime prevalence was 13.7%.

The Committee highlighted the huge treatment gap — the difference between the number of people who need care and those who receive care — and observed that it ranged between 70 to 92% for different disorders.

The Committee pointed out that most of the issues highlighted by the NMHS 2015-16 remained almost the same even in 2023. It flagged the “lack of mental health professionals, weak mental healthcare infrastructure, inadequate and inequitable access to mental health services, stigma and discrimination” as the reasons for huge treatment gap.

The Committee also called attention to several “limitations” of the NMHS 2015-16 which it recommended the government to address in the next Survey. These issues include relying on self-reports instead of clinical analysis, collection of data on specific disorders only, exclusion of “specific vulnerable populations, such as homeless individuals, prisoners, and those living in institutions”, limiting the Survey to only 12 states out of 36, and covering “only about 40,000 people which is a tiny sample considering the population of the country.”

Last, citing the NMHS 2015-16, the Committee wrote that “despite years of research and a continued focus on improving health systems, changes seen in the mental health field are few and limited.” My question: where are the “years of research and a continued focus on improving health systems”? Forget continued focus, other than spilling ink on paper in the form of a few laws and policies, I have not seen a single attempt on ground by the Union Government to improve mental health systems. This right here is the first step in our journey of seeing the Parliamentary Standing Committee on Health and Family Welfare abdicating its duty to hold the government accountable and giving it a free pass.

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3.     Global Comparison: In this section, the Committee has cited World Health Organization’s World Mental Health Report: Transforming Mental Health for All 2022, and Sapien Labs’ Mental State of the World Report 2022 to highlight “India's unsatisfactory status in terms of mental well-being, life satisfaction and happiness across the globe.” The Committee stated that “for India's sustainable socio-economic growth, it is necessary to give the citizens [a] sense of equality, inclusiveness, justice, social security and participation.”

4.     Effect of COVID-19 on Mental Health: The Committee has underlined the impact of the COVID-19 pandemic on the people’s psychosocial well-being due to “fear and uncertainty surrounding the virus”, isolation and limited social interactions because of the lockdowns, economics hardships such as loss of employment and financial instability, and lifestyle changes such as blurring of boundaries between personal and professional life resulting from work from home policy.

The Ministry of Health and Family Welfare told the Committee that to provide psychosocial support, the government took initiatives such as “setting up of a 24/7 helpline” and issuance of several kinds of guidelines.

Here also, the Committee simply accepted the submissions of the government without asking if the reported initiatives were sufficient. It did not demand data about, for instance, the number of people who called the helpline. It did not ask if the guidelines were effective. Most importantly, it did not ask that during a once-in-a-century pandemic, was issuing guidelines and launching a telephone helpline the most a government could do for the mental health of 140 crore Indians?

The Committee expressed the need of a post-COVID-19 survey to “assess the prevalence and severity of mental health disorders” and recommended that “National Mental Health Survey - 2, which is scheduled to be completed in 2025, should be expedited so that the impact of Covid-19 may be accurately ascertained.” [NHMS-2 is being conducted in two phases: Phase 1 during October 2022 - Mar 2024 in 18 States/UTs and Phase 2 during April 2024 - March 2025 covering the remaining 18 states.]

The Committee said: “[it] is of the firm opinion that the findings from the Survey will serve as crucial evidence for policymakers to take informed decisions related to mental health funding, infrastructure development, and evidence-based interventions.”

My question: did the first Survey compelled the policymakers to take informed decisions related to mental health funding, infrastructure development, and evidence-based interventions? If the past is the best predictor of the government’s performance, then who can deny that the second Survey will also not be worth the paper it will be printed on?

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Next week, I will review the remaining sections of Chapter I, and the Chapter II entitled Mental Health Policy and Legislation.

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NEW DELHI, OCTOBER 27: The Government of India ordered the closure of all psychology and psychiatry departments in the country with immediate effect on Wednesday. 

Informing about the historic decision in a televised address to the nation at eight o’clock in the evening, Prime Minister Narendra Modi said the advent of “trauma-informed therapy” and its practitioners had made the disciplines of psychology and psychiatry useless and therefore, continuing them would only be a massive waste of taxpayers’ money. He also asked the state governments to issue instructions to their institutions to cease operations in these departments.

The Government has directed the heads of all institutes to send compliance reports by midnight today.

In a statement released by his office after the announcement, Vice President M. Venkaiah Naidu termed trauma-informed therapy a glorious treatment for all types of mental disorders, coining the backronym TIT for TAT in the process. 

In some circles, the backronym is being interpreted as a rebuke to critics like Ajay Gulzar, who have spoken against the abuse of the term ‘trauma’ and wanted to stop it, but instead, they got their own disciplines shut down by the Government. 

Addressing a press conference after the sudden announcement, Union Minister of Health and Family Welfare Mansukh Mandaviya revealed that the Prime Minister had taken the decision after listening to a podcast by a Cornell University-trained psychotherapist, who reportedly stated that trauma was the root of all mental health problems. 

“Some experts disagreed and said it was a display of etiological ignorance, semantic inflation, and unnecessary medicalization of unpleasant but normal human experiences. These people do not realize the magical potential of trauma-informed therapy and just want to save their jobs,” he said.

The Health Minister informed that the Government was bringing amendments to several laws in the upcoming Winter Session of Parliament to implement the decision. 

“Earlier, the Government needed to regulate dozens of sub-disciplines in psychiatry and psychology, and therefore, had to make many different laws, but now, since we would only recognize trauma-informed therapists, we need just one law. It would make the process of laying down standards and certifications straightforward and easy to follow. Moreover, in the upcoming Union Budget, the Government would allocate money only for trauma-informed therapy,” he said.

The Insurance Regulatory and Development Authority has notified that the insurance companies need to cover only trauma-informed therapy under their plans.

Immediately after the Prime Minister’s address, thousands of newly unemployed psychology professors were seen rushing to their offices to collect their belongings as their access to institutions would be revoked at midnight. Some of them were also seen registering for trauma-informed therapy courses, whose prices had surged multi-fold. Edtech company Byju’s is reportedly in talks to acquire a start-up that provides such training programs online.

Hailing the ground-breaking announcement by the Indian Government, Yale University psychologist Paul Bloom stated, “since publishing the book Against Empathy in 2016, I have been sceptical of the benefits of traditional psychotherapy. If empathy is evil, then most concepts in psychology are. The trauma-informed therapy is the only magic wand to solve humanity’s mental health problems.”

Harvard cognitive scientist Steven Pinker also welcomed the Indian Government’s decision. 

“Although violence has declined and we are living in the era of Long Peace, the diagnosis of trauma has gone up. In fact, it is the only accurate clinical diagnosis now as far as mental health is concerned. Hence, I would request American Psychiatric Association to rename DSM as the Diagnostic and Statistical Manual of Trauma in the next edition,” Pinker said. 

Several social media therapists have come forth in support of the PM’s decisive stand. “The only shared human experience that is worth exploring is trauma, and to address mental health in an unequal world, we must accept the trauma we hold within ourselves. Unless we heal these traumas, our inner child shall continue to suffer,” said one trauma-informed therapist who runs the popular Instagram page @ProfoundlyTIT.

Disclaimer: In case it was not obvious, it is a piece of satire.

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I write about mental health policy. Follow me on Twitter, LinkedIn and Instagram.

My dream: discussions on mental health policy proposals in psychology classrooms before the authorities make the decisions.

The reality: most psychologists become aware of rules, policies, and laws after they are notified and published.

In the last few years, I have tried to bridge the gap between this dream and reality. We are still at the awareness stage. I cannot say when the mass advocacy stage would come, although we see “mental health advocate” written in social media bios all the time.

Almost all the mental health policy conversations are led and driven by psychiatrists, lawyers, and social workers. The psychologists are rarely part of these conversations. Therefore, we keep seeing laws that are not favourable to the psychology profession. 

The questions I get about mental health laws are primarily related to an immediate, practical concern. How can I register under the National Commission for Allied and Healthcare Professions Act 2021? When will the Commission be formed? I have done this degree from this university; would it be recognised under this law? What would happen to those having distance learning qualifications? And they go on.

I seldom get conceptual questions and concerns that take a long-term perspective. Why are some professionals called ‘behavioural health sciences professionals’ while others are termed ‘mental health professionals?’ What are the criteria for the inclusion of a profession in the NCAHP Act? How are the professional categories defined? Has the law been designed using a rights-based approach? Are the psychologists adequately represented in the various authorities? 

Our focus should not only be on following a law. We should also be asking if it is a good law. We should be able to imagine the consequences before a proposal takes shape.

This is where psychology professionals fail. Generations of psychologists have been brought up with zero public policy imagination. Their awareness and outrages about laws are post facto.

But the sadder fact is that even this post facto ephemeral anger does not turn into organised advocacy. 

For instance, the NCAHP Act recognises educational qualifications obtained through regular mode only. The mental health — sorry, behavioural health — professionals who possess distance learning degrees and years of experience can no longer practice now. Therefore, they are upset. But do they have organized themselves, protested, and asked the government to amend the Act? 

It is time for psychologists to study why they cannot implement what they preach.

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I have started two petitions: one to the Government of India to increase expenditure on mental health in Union Budget 2022-23 and another to political parties to include mental health provisions in their manifestoes for upcoming legislative assembly elections. You can sign them here and here.

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I keep receiving questions about the implementation of the National Commission for Allied and Healthcare Professions Act 2021 (the NCAHP Act 2021). To answer a few of them, I am writing this brief note about its implementation status.

The NCAHP Act 2021, if you do not know about it yet, was passed by Rajya Sabha on March 16, 2021, and by Lok Sabha on March 24, 2021. The Government notified it in the Gazette of India on March 28, 2021, after it received the assent of the President.

The Act, among other things, provides for “regulation and maintenance of standards of education and services by allied and healthcare professionals, assessment of institutions, [and] maintenance of a Central Register and State Register” of professionals. It includes psychologists as “Behavioural Health Sciences Professionals.”

It came into force on May 25, 2021.

On May 27, 2021, the Union Ministry of Health and Family Welfare notified the National Commission for Allied and Healthcare Professions Rules, 2021. Some relevant points in the Rules are:

1.     The President or member of a Professional Council should have a postgraduate degree in the recognised profession. They should have an experience of not less than fifteen years, out of which at least seven years should be as a leader in the allied and healthcare professions. [Every recognised category under the NCAHP Act has a Professional Council to represent the profession in the Commission.]

2.     The Commission will maintain an online Central Allied and Healthcare Professionals Register.

3.     The Rules prescribe an application form for the issuance of the certificate of registration to recognized professionals. The registration fee is Rs 2,000/-.

4.     The qualifying criteria for permission to establish an allied and healthcare institution stipulate that the institution should be “within the vicinity of a functional medical college or University and has an attached hospital for the purposes of practical exposure and internships to the students.” It remains to be seen how it would affect the already existing departments of psychology.

Section 20 of the NCAHP Act provides for the constitution of an Interim Commission within sixty days from the date of assent of the President until the Government constitutes the regular National Commission.

On August 3, 2021, the Ministry of Health & Family Welfare published the National Commission for Allied and Healthcare Professions 1st (Removal of Difficulties) Order, 2021 stating that “due to the second wave of the Covid pandemic in India, the Interim Commission could not be constituted within the stipulated period.” It said that “the Central Government shall, as soon as may be but within six months from the date on which the Act receives the assent of the President, constitute an Interim Commission.” [emphasis supplied]

After that, the Interim Commission was notified by the Government on September 21, 2021. As stipulated by Section 20 of the NCAHP Act, the Interim Commission consists of Additional Secretary, Ministry of Health and Family Welfare as the Chairperson; one Joint Secretary each from the Ministry of Health and Family Welfare, the Ministry of Law and Justice, the Ministry of Education, the Ministry of Social Justice and Empowerment, and the Ministry of Skill Development and Entrepreneurship; Deputy Director General, Directorate General of Health Services; Member, Ethics and Medical Registration Board, National Medical Commission; Member Secretary, Rehabilitation Council of India; and Head, Directorate of Regulatory Affairs and Communication, Atomic Energy Regulatory Board. The Deputy Secretary or Director, Ministry of Health and Family Welfare shall be the Secretary of the Interim Commission.

Other than these eleven members, the positions of two professionals representing each of the recognised categories are vacant. These members shall be selected by the Committee formed under Section 16 of the National Commission for Allied and Healthcare Professions Rules, 2021. Effective implementation of the Act will begin after the appointment of these members.

TL;DR version:

Basic Rules under the NCAHP Act 2021 have been framed. The registration fee for the issuance of the registration certificate to recognised professionals is Rs 2,000/-. The Government has appointed some members (all bureaucrats) of the Interim Commission, while the positions of two professionals representing each of the recognised categories are vacant.

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It was World Mental Health Day a few days ago, which, among other things, served as an opportunity to repeat several truths which have become clichés. One of the clichés is that Indian governments do not fund the mental healthcare sector adequately. Another is that our governments do not even fully spend the minuscule budget allocations. The Union government repeatedly saying ‘there is no data’ to any question has become another truism. There is another platitude that we do not have adequate mental health professionals, infrastructure, and affordable and accessible mental healthcare services in our country. 

World Mental Health Day was introduced in 1992. Two years later, World Federation for Mental Health commemorated it with a specific theme for the first time: ‘Improving the Quality of Mental Health Services throughout the World.’ Twenty-five more themes later, our concern remains the same: how to improve the quality of mental health services? Actually, in India, we have to go one level down: how to provide mental health services of any quality at all? Because more than one hundred crore — a number so large that you won’t even bother reading it correctly: 1000000000 — Indians do not have affordable access to any mental health service. Therefore, along with quality, it is a quantity issue. 

The Union Ministry of Finance has started the process of preparation of the 2022-23 Budget. Moreover, the legislative assembly elections are going to be held in five states — Goa, Manipur, Punjab, Uttar Pradesh, and Uttarakhand — in February/March next year. They present us with two opportunities: lobby with the Government to increase the budget allocations for the mental health sector and ask the political parties to include mental health in their election manifestoes.

I am starting two petitions: one to the Government of India to increase expenditure on mental health and another to political parties to include mental health promises in their manifestoes for upcoming legislative assembly elections. Following is the text of these petitions:

Increase the allocation for mental health in the upcoming Union Budget 2022-23

The Government of India should increase the expenditure on mental health to at least Rupees ten thousand crores in the Union Budget 2022-23. While the Government has brought multiple progressive laws, including the Mental Healthcare Act 2017, the abysmally low public investment in mental health has led to an acute shortage of mental health professionals and an enormous treatment gap of over 90%. The mental health expenditure by the Union Government is less than 1% of its total health budget, which itself is marginally above 1% of India’s Gross Domestic Product.

The Global Burden of Disease Study estimated that about twenty crore Indians suffer from mental disorders, i.e., one in every seven persons. A budget of Rupees ten thousand crores would amount to Rs 500 for every person living with mental illness, or at the population level, it would be Rs 71 for every Indian. Not a huge amount, but it would be a significant improvement from the current budget of about Rs 7 per Indian.

Improving psychological wellness is also an objective of the United Nations Sustainable Development Goals (SDGs). The SDG Target 3.4 seeks to “reduce by one-third premature mortality from non-communicable diseases through prevention and treatment and promote mental health and well-being” by 2030. Target 3.5 aims to “strengthen the prevention and treatment of substance abuse, including narcotic drug abuse and harmful use of alcohol.”

The meagre government spending on mental health in India has led to a shortage of services for people with psychological disorders. There is an immediate necessity of significant public investment for improving mental health services at the level of primary health centres, construction of infrastructure, adequate training of mental health professionals including increasing the number of seats, hiring mental health professionals at every level, enhancing funding for research, creating awareness about mental illnesses, and implementation of the Mental Healthcare Act 2017 and the National Commission for Allied and Healthcare Professions Act 2021. Therefore, the government outlay on mental health must grow multi-fold. Moreover, for better effectiveness and to make the sector a priority of the Government, a Minister of State in the Ministry of Health and Family Welfare should be made in charge of the mental health matters.

In her 2021-22 Budget address, Finance Minister Nirmala Sitharaman spoke about nutrition, water supply, Swachh Bharat, clean air, and even vehicle scrapping policy under ‘health and wellbeing’ but did not mention mental health at all. Let us hope that in 2022, our mental health will become as important as old vehicles.

You can sign this petition here.

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Political parties should include mental health provisions in election manifestoes

While the Parliament has passed several laws related to mental health, the primary responsibility of implementation falls on the state governments. The Global Burden of Disease Study estimated that about twenty crore Indians suffer from mental disorders, i.e., one in every seven persons. Despite good laws, we lack access to affordable, acceptable, and quality mental health care. The rights-based approach enacted on paper has to be followed by evidence-based implementation.  

The proposals which a government executes usually originate in an election manifesto. Five states — Goa, Manipur, Punjab, Uttar Pradesh, and Uttarakhand — are holding legislative assembly elections in February/March next year. Therefore, it is an opportunity for all political parties to include mental health provisions in their manifestoes and convey that our mental health matters. As a beginning, the following points are being suggested for inclusion in the manifestoes:

1.     Allocation of at least ten percent of the state’s health budget to the mental health sector every year

2.     Implementation of the National Mental Health Policy 2014 in letter and spirit

3.     Implementation of the Mental Healthcare Act 2017, including the establishment and operationalisation of State Mental Health Authority and Mental Health Review Boards

4.     Implementation of the Rights of Persons with Disabilities Act 2016, including the simplification of the disability assessment and certification process, adequate disability pension, job reservation & opportunities, and access to specialized work training

5.     Recruitment of registered mental health professionals in Primary Health Centres, Community Health Centres, and Civil Hospitals

6.     Increase seats and provide training programs for mental health professionals in all state medical colleges

7.     Ensure 100% expenditure of allocations under Government of India’s District Mental Health Programme, and

8.     Address social inequalities to reduce the risk of mental health issues

You can sign this petition here.

Mental health is a profession of a few rays of hope in vast swathes of darkness. Every year, we hope that finally, the Government of India will pay attention to mental health in this budget. Every year, the government disappoints, and the cycle continues. Let us see if our governments and political parties would listen to us this time or old cars would remain more important than our mental health.

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The June edition of psytizenship’s monthly segment — Developments at the Intersections of Psychology, Policy and Law — is being published late for one reason: the last Friday of the month fell on 25th and I wanted to wait for the remaining five days so that no new development was missed. In the May edition, a couple of developments were missed due to this, which I am covering today. From July, I am thinking of doing this segment on the last day of the month.

Let us see what we have in the June edition:

1.     S Sushma v. Commissioner of Police: Justice N Anand Venkatesh of the Madras High Court delivered a landmark judgement on June 7, 2021, in the widely reported S Sushma v. Commissioner of Police case, whose proceedings I covered in the April edition also. Most probably, you have already read about the judgement. Here it is in brief:

The relationship of a lesbian couple belonging to Madurai was being opposed by their respective parents. The couple escaped to Chennai, and their parents filed “girl missing complaints” with the police. To seek protection, the couple approached the Madras High Court.

As Justice N Anand Venkatesh noted in the order, he “consciously refrained from adopting the usual course of disposing” of the case as it “brought to light an important issue requiring de-stigmatisation and acceptance in the eyes of the society.”

The “unusual course” which Justice N Anand Venkatesh took was this: he asked the police to close the girl missing complaints, appointed a psychologist, Ms Vidya Dinakaran, to counsel the parties and submit reports to the Court, decided to take a session himself with the psychologist, and interacted with some members of the LGBTQIA+ community to know about their lived experiences. He wrote in a previous order dated 28.04.2021:

“Ultimately in this case, the words must come from my heart and not from my head, and the same will not be possible if I am not fully “woke” on this aspect. For this purpose, I want to subject myself for psycho-education with Ms. Vidya Dinakaran and I would request the psychologist to fix a convenient appointment for the same. I honestly feel that such a session with a professional will help me understand same-sex relationships better and will pave way for my evolution. If I write an order after undergoing psycho-education, I trust that the words will fall from my heart.”

On May 07, 2021, Justice N Anand Venkatesh underwent “a session of psycho-education” with Ms Vidya Dinakaran. She submitted a report about this session, which spans 14 pages of the judgement.

After this, the judge “felt that a further interaction with person(s) who belong to the LGBTQIA+ community would be greatly instrumental to help myself understand the ground realities, the emotions, social discrimination and exclusion, and several other difficulties faced by the community. Therefore, an interaction was scheduled with Dr. L. Ramakrishnan, Vice President, SAATHII, Ms. Shanmathi, PCVC, Dr. Trinetra Haldar Gummaraju, Digital-Content Creator, Actor, MBBS Intern – Kasturba Medical College and her mother Ms. Haima Haldar.” Dr Trinetra Haldar Gummaraju submitted a report to the Court after the interaction.

Justice N Anand Venkatesh wrote in the judgment:

“I must frankly confess that the Petitioners, Ms. Vidya Dinakaran, and Dr. Trinetra became my gurus who helped me in this process of evolution and pulled me out of darkness (ignorance).”

In the final judgement, after a discussion of provisions of the Constitution of India and relevant court orders from around the world, Justice N Anand Venkatesh issued guidelines/directions “for proper recognition of the rights of the LGBTQIA+ community and to ensure their safety and security to lead a life chosen by them,” which include:

a)     The police should close girl/woman/man missing cases, which involve consenting adults belonging to the LGBTQIA+ community.

b)    The Union Ministry of Social Justice and Empowerment should make a list of NGOs “including community-based groups which have sufficient expertise in handling the issues faced by the LGBTQIA+ community.” Any person belonging to the LGBTQIA+ community can approach these NGOs for the protection of their rights.  [Action asked to be taken within 8 weeks from the date of receipt of a copy of the judgement.]

c)     The Union Ministry of Social Justice and Empowerment should make suitable arrangements “to accommodate any and every member of the LGBTQIA+ community, who require shelters and/or homes.” [Action asked to be taken within 12 weeks from the date of receipt of a copy of the judgement.]

d)    The Court asked various government departments and organizations, inter alia, to conduct awareness and sensitization programmes, make changes in curricula of schools and universities to educate students about the LGBTQIA+ community, ensure availability of gender-neutral restrooms for the gender-nonconforming students, make workplaces LGBTQIA+ community-friendly, and provide physical and mental health assistance. [Interestingly, in the list of organizations made responsible for provision of physical and mental health assistance, the Indian Psychiatric Society is mentioned but not the psychology associations such as the Indian Association of Clinical Psychologists and the National Academy of Psychology. Why is it so? Is the judiciary not aware of these organizations and the role of psychologists in mental health?]

e)     The High Court banned the practice of so-called “conversion therapy.” Justice N Anand Venkatesh directed to:

“Prohibit any attempts to medically “cure” or change the sexual orientation of LGBTIQA+ people to heterosexual or the gender identity of transgender people to cisgender,” and “take action against the concerned professional involving themselves in any form or method of conversion “therapy”, including withdrawal of license to practice.”

The Court kept the petition open for regular monitoring of the implementation of the directions and guidelines, and the next date of hearing is August 31, 2021.

Some observations from my side:

a)     One must read this outstanding judgement. A copy is available here.

b)    The psychology associations need to wake up from their deep slumber and start making contributions to our society and policy making processes. In the instant case, they should be part of the programmes seeking to implement the guidelines. More importantly, they should ensure that the governments implement these guidelines in letter and spirit.

c)     This judgement has many good sentences and paragraphs. I’m ending this long section with this line from the order: “Ignorance is no justification for normalizing any form of discrimination.”

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2.     Enforcement of the NCAHP Act, 2021: The National Commission for Allied and Healthcare Professions Act, 2021 came into force on May 25th, 2021. The gazette notification is available here. One immediate impact of this Act coming into force is that the qualifications obtained through distance learning mode are not recognized as allied and healthcare qualifications. Now, only those with regular learning mode degrees/diplomas can practice as allied and healthcare professionals, including psychologists, in India.

If you are not well versed with the NCAHP Act, 2021, you can read this FAQs guide.

3.     Rules under section 65 of the NCAHP Act: The Government of India notified the Rules under section 65 of the NCAHP Act on May 27th, 2021. The National Commission for Allied and Healthcare Professions Rules, 2021 encompass the following provisions:

a)     Qualifications, experience and manner of selection of Part-time Members of the Commission

b)    Salaries, allowances and conditions of service of Chairperson, Vice-Chairperson, Members and officers of the Commission

c)     Rules regarding the transaction of business of the Commission

d)    Rules regarding application for a certificate of registration (the registration fee is Rs 2,000.)

e)     Qualifications, experiences and manner of appointment of members of Interim Commission

f)     Rules regarding establishment of new allied and healthcare institutions [An important qualifying criteria: “The institution is within the vicinity of a functional medical college or University and has an attached hospital for the purposes of practical exposure and internships to the students.”]

g)    Financial provisions

The rules regarding other matters such as basic standards of education, courses, curricula, infrastructural facilities, faculty, examinations (including entrance and exit exams), training, research, continuing professional education, fee,  distribution of seats, and recognition of degrees/diplomas granted outside India would be made by the Commission under section 66 of the NCAHP Act.

4.     Human Rights Advisory on Right to Mental Health in view of the second wave of COVlD-19 pandemic by National Human Rights Commission (NHRC): In the last edition of Developments at the Intersections of Psychology, Policy and Law, I had covered the Rehabilitation Council of India’s Model Recruitment Rules and stated that I “saw several posts on social media full of happiness as the psychologists hoped that they would get better pay and perks now.” I was puzzled as it was not the first time that the RCI had come up with such Rules. They had notified the Model Recruitment Rules in 2016 also, but, as it turned out, most psychology professionals and students were not even aware of the old Rules. Hence, as I stated then, the misplaced optimism.

Something similar happened again. India’s National Human Rights Commission issued a Human Rights Advisory on Right to Mental Health in view of the second wave of COVlD-19 pandemic to Central and state/UT governments on May 31, 2021, and the social media saw similar optimistic posts again. What they ignored was that earlier, on October 8, 2020, the NHRC had issued another Human Rights Advisory on Right to Mental Health in Context of Covid-19 Pandemic with the instruction that “all the concerned authorities are requested to implement the recommendations made in the advisory and to submit the action taken report for information of the Commission.”

A contentious issue is this: the new advisory does not tell us if these Action Taken Reports were submitted by the Central and state governments or not. If the reports were submitted, then where are they? If they were not submitted, then what were the actions taken by the NHRC against the Central and state governments? In the new advisory, the NHRC wrote that “all the concerned authorities of the Union/State Government{s)/UTs are advised to implement the recommendations made in the said Advisory 2.0 and need to submit the action taken report (ATR) within four weeks for information of the Commission.” The four weeks ended on June 28, 2021. Were the recommendations implemented? To find out, I am filing a Right to Information request and will post an update whenever I receive the reply.

If you wish to support such endeavours, then please pick up a paid subscription, or you can make a one-time payment of any amount here.

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PS. Arjun Kapoor and Sayali Mahashur of Centre for Mental Health Law and Policy, Pune wrote a must-read article on mental health insurance. Despite the enabling provision in the Mental Healthcare Act 2017, the insurance companies keep denying the claims submitted by people and the Insurance Regulatory & Development Authority of India is not doing enough to enforce the law.

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Your content is so good [that] it should be taught in Psychology class as a subject.

— Jasbir Kaur Thadhani, Head, Counseling and Psychometrics, Mehrizm Foundation, and Visiting Faculty, Rashtriya Raksha University

I had announced a week ago that I was going to launch paid subscriptions to psytizenship, which will help me cover —

a)     operational costs of psytizenship (such as domain name, etc.),

b)    subscription charges of periodicals and costs of purchasing articles, books and any other material required for research,

c)     the fees of filing RTIs and accessing government documents,

d)    a good stipend to research interns (that I plan to hire in coming months),

e)     execution of multiple projects I am conceiving at this moment, and most importantly,

f)     coffee and green tea for myself.

The paid subscriptions are live now. You can purchase one here.

If you are a student or an early career professional, a 40% discount is available on this link (you don’t need to show any proof to use the discount. It is an honour system.)

If you cannot afford a recurring subscription but still want to support psytizenship financially, you can make one time payment of any amount here.

Thank you so much for reading and supporting my work.

Hi!

Thank you so much for being a part of the psytizenship community. With your support, I have published nine articles so far, including a 3,400-word critique of the National Commission for Allied and Healthcare Professions Act, 2021 (the NCAHP Act), as well as a 1,700-word FAQs guide on it.

The psytizenship has received appreciation from professors, practising psychologists, PhD candidates, students, and other readers. I am immensely grateful for your appreciation, love, and kindness. Thanks to psytizenship, several colleges, psychology associations and NGOs have invited me to speak on issues at the intersections of psychology, policy, and law. Furthermore, the professors and practitioners from various universities and organizations have sought my advice on matters related to the implementation of the NCAHP Act and other laws.

Earlier, hundreds of professionals, professors, associations, and students used my analysis to demand changes in the Allied and Healthcare Professions Bill 2018 when it was being examined by the Parliamentary Standing Committee on Health and Family Welfare. Member of Parliament Bhartruhari Mahtab cited one of my articles in his speech during the discussion on this legislation in Lok Sabha.

The USP of psytizenship is that it produces rich and deeply researched articles on topics that are virtually never discussed in psychology classrooms. Leave alone university professors, for instance, even the top think tanks of India, including those working on mental health laws and policies, did not produce a single report on the NCAHP Act as far as mental health is concerned.

The mental health policy field requires both an ability to conduct quality research and a drive to inform public discussions. This work requires a significant investment of time and resources. Hence, without your financial support, psytizenship is not sustainable.

Therefore, on July 1, 2021, I am launching paid subscriptions. The paid subscription will help me cover —

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c)     the fees of filing RTIs and accessing government documents,

d)    a good stipend to research interns (that I plan to hire in coming months),

e)     execution of multiple projects I am conceiving at this moment, and most importantly,

f)     coffee and green tea for myself.

The subscription plans are a) Rs 300 per month, and b) Rs 3,000 per year. If you are feeling particularly generous, you can subscribe to the Founding Member plan at Rs 10,000 per year (or any amount more than Rs 3,000.)

I am aware that many psytizenship community members are students and early career professionals. Therefore, a 40% discount is available for such subscribers (you don’t need to show any proof to use the discount code. It’s an honour system.)

Along with the need to make psytizenship financially sustainable, it is also necessary that our work reaches all the psychology students, professionals and people of India. Therefore, for now, most of the articles will be freely available. By picking up a paid subscription, you are not only providing sustenance to psytizenship, but also keeping it accessible for those who cannot afford to pay.

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It is a cliché to state that the mental healthcare sector is acutely underfunded in India. Many articles and social media posts point out this reality every year, especially around the presentation of the Union Budget in Parliament. These articles and posts, some of them written by me, painstakingly inform readers about the negligible funds allocated to mental health. But no one tells us how much of those meagre allocations are spent by the authorities. The purpose of this article is to address this gap as far as the National Mental Health Programme (NMHP) is concerned. 

The NMHP has two components: the District Mental Health Programme (DMHP) and the Tertiary Care Programme. The allocation figure usually reported in the media after the presentation of the Union Budget is actually of the Tertiary Care Programme component. Table 1 below presents the utilization rates of this component of the NMHP from the Financial Year 2015-16.

As you can see in the Table 1, in the last three Financial Years, the budget allocated for the Tertiary Care Programme has never been fully used. In fact, the expenditure did not touch double digits in 2018-19 and 2019-20. Even during the year of the COVID-19 pandemic, when the reports of mental health issues rose astronomically, the allocation was reduced from Rs 40 crore to Rs 27.36 crore. Hence, the utilization (data not publicly available yet) cannot be more than 68.4%. (As per the Demand for Grants 2021-22 report submitted by Standing Committee on Health & Family Welfare to the Parliament on March 8, 2021, the Government had spent only Rs. 9.07 crore. Therefore, the expenditure possibly did not touch double digits during the COVID-19 pandemic also.)

Let us come to the rarely reported District Mental Health Programme (DMHP) now. The DMHP component was added to the NMHP in 1996 (if you did not know: the government launched the NMHP in 1982). The objectives of the DMHP are:

1. To provide mental health services including prevention, promotion and long-term continuing care at different levels of district healthcare delivery system,

2. To augment institutional capacity in terms of infrastructure, equipment and human resource for mental healthcare,

3. To promote community awareness and participation in the delivery of mental health services, and

4. To broad-base mental health into other related programs.

Under the DMHP, the Government of India provides financial assistance up to Rs. 83.20 lakh to each supported district for “early detection, management and treatment of mental disorders/illnesses.” Currently, 692 districts of the country receive this financial assistance.

Chart 1 below illustrates the expenditure under the DMHP. It shows (a) the funds allocated by the Government of India to the states, (b) the funds utilized by the states and (c) the percentage of utilization. 

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Let us go over some of the salient features of expenditure under the DMHP:

1. No state government of India has spent 100% of the funds allocated to it under the District Mental Health Programme in the last six years. In fact, no state has spent even 80% of the budget. (Whenever I use the term ‘state/states,’ it includes the UTs also unless otherwise specified.)

2. There were 222 instances of budget allocation to 37 states in the last six years (37x6 = 222). Only 15 times, the utilization has been 100% or more. That means, in 93.24% of the cases, the state governments did not spend the entire budget allocated to mental health.

3. West Bengal has the highest utilization percentage of funds under the DMHP at 79.29%.

4. Only five states of the country have had expenditure rate over 50% — West Bengal (79.29%), Andhra Pradesh (77.87%), Chhattisgarh (63.61%), Karnataka (62.1%) and Sikkim (52.99%).

5. Only ten state governments have reported expenditure over 40% — the five listed above and Gujarat (48.12%), Tamil Nadu (47.58%), Dadra and Nagar Haveli (44.01%), Meghalaya (42.88%) and Uttar Pradesh (40.9%). It means that 27 states of India did not spend even 40% of the budget allocated under the District Mental Health Programme between 2015-16 and 2020-21.

6. The National Capital Territory — Delhi — has had the lowest expenditure under the DMHP. Out of Rs 761.83 lakhs allocated in the last six years, Delhi government spent only Rs 0.06 lakh, with the utilization rate standing at 0.000079%. (Since Chart 1 reports figures only up to two decimal points, it shows Delhi’s utilization as 0%.)

7. In the last six years, 14 state governments did not spend even one-fourth of the total budget allocated under DMHP. These states are Haryana (24.88%), Goa (22.75%), Jammu & Kashmir (20.93%), Himachal Pradesh (20.85%), Daman & Diu (20.51%), Bihar (20.09%), Arunachal Pradesh (15.31%), Punjab (13.69%), Tripura (12.74%), Jharkhand (12.05%), Uttarakhand (11.85%), Andaman & Nicobar Islands (5.49%), Telangana (4.68%) and, already mentioned in the last point, Delhi (0.000079%.)

8. In January this year, Kerala government was in the news for allocating Rs 64 crore for mental health care. But under the DMHP, Kerala’s utilization rate has been paltry 37.42% in the last six years. Only once has the state come close to spending 100% of the allocation, when, during 2017-18, it spent Rs 99.07 lakhs out of budgeted Rs 100.00 lakhs.

9. Between 2015-16 and 2020-21, the Government of India allocated Rs 52,101.77 lakhs to states under the District Mental Health Programme. During this period (till 31.12.2020), the states spent only Rs 19,856.56 lakhs. The national utilization rate comes out to a disappointing 38.11%. 

10. The national expenditure rate has never touched 50% in any of the last six years. It was 39.33% in 2015-16, 31.16% in 2016-17, 42.43% in 2017-18, 45.18% in 2018-19, the highest 47.84% in 2019-20 and 21.81% in 2020-21 (till 31.12.2020).

As you can see, the expenditure under the Tertiary Care Programme and the District Mental Health Programme is in an extremely poor state, to say the least. But the mental health advocates and civil society have rarely paid attention to it. 

As for lawmakers, the Parliamentary Standing Committee on Health & Family Welfare has taken note of this situation. The Committee, while talking about the Tertiary Care Programme component, said in its Demand for Grants 2021-22 report that: 

“The Committee observes that Rs. 50.00 crore was allotted at BE [Budget Estimates] 2018-19 under the NMHP and the same was reduced to Rs. 40 crore in BE 2019-20 and BE 2020-21. However to make things worse, the actual expenditure was Rs. 2.01 crore, Rs. 2.51 crore and Rs. 9.07 crore in 2018-19, 2019-20, 2020-21 respectively. The Committee expresses its deep concerns over the gross underutilisation of funds under National Mental Health Programme followed by dwindling trend of allocation of funds. The Committee is of the view that a constant underutilization over the years under this head clearly points towards the Ministry's inability to comprehend the magnitude of mental health burden in the country. Various studies have highlighted the high prevalence of mental illness in the country but no substantial progress has been achieved to facilitate a robust mechanism for delivery of mental healthcare services. (sic)”

It further wrote:

“The Committee points out that Ministry did not launch any specific programs pertaining to mental health during Covid-19. According to WHO about 7.5 per cent Indians suffer from some mental disorder and WHO predicted that by 2020, roughly 20 per cent of India will suffer from mental illnesses. The Committee is of the view that unprecedented condition during the pandemic would have considerably increased the prevalence of depressive disorders and mental illness in the country. The Committee desires the Ministry to conduct a study to assess the prevalence of mental illness, depressive disorders and suicide death rate in the country including the impact of the pandemic on the mental health of the population. (sic)”

Concerning the District Mental Health Programme, the Committee said that “the system is not well established and gaps exist in the delivery of care on the ground level. The irony is that many states have not framed the State Mental Health Rules and Regulations and thus this programme has not been operationalised throughout the country at the seamless pace. (sic)” 

The sad fact is that often, the government does not take seriously such observations made by a Parliamentary Standing Committee. Hence, it does not act to improve the situation.

The mental health sector in India faces a double whammy. On the one hand, the budget allocations for our mental health are minuscule. And on the other, the governments do not care to spend those amounts either. Unless we speak up, this deplorable situation not is going to change.

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Last month, I started experimenting with a new segment of psytizenship entitled ‘Developments at the Intersections of Psychology, Policy and Law’, which covers the latest updates in this field (with a particular, but not exclusive, focus on India). I share news, articles, court judgements, government orders, laws and research papers related to mental health policies and laws in this segment. The last Friday of a month is reserved for it.

Let’s see what we have in this edition:

1.     Rehabilitation Council of India’s Model Recruitment Rules: On May 12, the RCI came up with new Model Recruitment Rules for the Rehabilitation Professionals and Personnel, including clinical and rehabilitation psychologists. For an entry level Assistant Professor in Clinical Psychology or Rehabilitation Psychology (Teaching), the prescribed pay band (as per 7th Central Pay Commission) is Level‐11 Rs. 67700 ‐ 208700. For a practising Clinical Psychologist or Rehabilitation Psychologist (Non-Teaching), the pay band is Level‐10 Rs. 56100 ‐ 177500, and for an Associate Clinical Psychologist or Associate Rehabilitation Psychologist (Non-Teaching), it is Level‐8 Rs. 47600 – 151100.

When the notification came out, I saw several posts on social media full of happiness as the psychologists hoped that they would get better pay and perks now. I was puzzled by this sentiment as my immediate thought was that these Rules were just advisory in nature and not going to be enforced. The old Model Recruitment Rules, notified in 2016, were not implemented either, but, as it turned out, the psychology professionals and students were not even aware of the old Rules. Hence, the misplaced optimism.

Can the Indian Association of Clinical Psychologists ensure the implementation of new Rules? I am not even hopeful enough to say ‘time will tell’.

2.     Wales Government to Launch Universal Basic Income (UBI) Pilot: The social and structural determinants such as income and job security influence health heavily and account for between 30%-55% of health outcomes. Therefore, they are a major focus of health policy around the world. As income and wealth inequality rises, unconditional cash support has gained more and more popularity in various countries. The Welsh government is the latest to announce a Universal Basic Income pilot. The first minister Mark Drakeford said:

“A basic income pilot is one of the specific responsibilities of our new social justice minister. It will have to be carefully designed, it will draw on the experience of attempted pilots in Scotland, but I have a very longstanding interest in basic income. I hope we will be able to mount an experiment here that will test whether the claims that are made for a basic income approach are actually delivered… I want to do it on that broad basis and design the best possible pilot.”

Question: there have been so many successful pilot studies of UBI around the world. The last edition of ‘Developments at the Intersections of Psychology, Policy and Law’ covered the effects of Bolsa Familia, the world’s largest conditional cash transfer programme, on suicide rates in a cohort of half the Brazilian population. Despite so much success, why has no country launched a full-fledged UBI program yet?

3.     Under distress due to debt and pending payments for their harvest, many farmers of Uttar Pradesh have destroyed their crops. A farmer said, jab pareshani mein lambe time tak koi sadasya reh jaave, wo maansik tanaav ka shikar jrur banega (When a person remains burdened under such problems for a long time, they are bound to face psychological issues.) We are back to the social and structural determinants of mental health. Watch the video (11 minutes):

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4.     Climate Change and Mental Health: Dr Emma Lawrence, Rhiannon Thompson, Gianluca Fontana and Dr Neil Jennings of Imperial College London have published a briefing paper entitled 'the impact of climate change on mental health and emotional wellbeing: current evidence and implications for policy and practice'. They have stated that

• There is a clear relationship between increased temperatures and the number of suicides;

• There is clear evidence for severe distress following extreme weather events;

• People who meet the criteria for mental illness are more vulnerable to the effects of climate change on physical as well as mental health;

• The climate crisis threatens to disrupt the provision of care for people with a mental illness diagnosis; and

• Climate change exacerbates mental distress, particularly among young people, even for individuals who are not directly affected (e.g. ‘eco-anxiety’).

The paper contains excellent recommendations for stakeholders (e.g., government, healthcare systems, community groups, academics, emergency responders) to fully understand, manage and reduce mental health impacts of climate change. Read it here.

5.     The popular imagination and public conversations on mental health usually focus on depression, stress and anxiety disorders. Mental disorders such as schizophrenia and bipolar disorder are still shrouded in public silence. Hence, during the COVID-19 pandemic, I actively looked for papers and articles focusing on the latter and directed private conversations towards this topic. A recently published article by Riddhi Dastidar on IndiaSpend focuses on workplace support for women with schizophrenia. They write:

For women living with schizophrenia to pursue meaningful employment and live independently, locally available and accessible community care for symptom management (as opposed to institutionalisation), and supported employment initiatives are required, say disability rights activists, mental health professionals and persons living with mental illness. GBD 2019 [Global Burden of Disease Study 2019] recommended using community-based programmes and non-psychiatric, community health workers to reduce the treatment gap for mental illness in India, based on existing models such as the Atmiyata programme in rural Maharashtra. Health activists on the ground supported this approach. Yet India continues to place emphasis on institutionalised care, we found.

"If [employers] can avoid recruiting a person with mental illness, most will," said Thara Rangaswamy, co-founder of SCARF and the principal researcher behind the Madras Longitudinal Study. "Persons with disabilities like visual impairment or locomotor disability are often more activist--they will fight for their rights. But people living with schizophrenia often don't do it at all, either because their functioning is impaired by symptomatology, or the cost of disclosure is so high because this is one disability where stigma clouds everything."

This must-read deep dive is available here.

Finally, another article worth reading: Covid-19: Pandemic triggers mental disorders but insurance eludes many.

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PS. Today is the martyrdom anniversary of my favourite freedom fighter Shaheed Bhagwati Charan Vohra. I had written a short Twitter thread about him last year on the 90th anniversary. Read on by clicking on the tweet below.

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I have often expressed frustration over the fact that very few psychologists in India take active interest in mental health policies and laws. For instance, the participation of practising psychologists in the drafting and consultation process of documents such as the National Mental Health Policy 2014, the Mental Healthcare Act 2017 and the National Commission for Allied and Healthcare Professions Act 2021 was virtually non-existent.

Although the trepidation of finding a decent employment in an underpaid and undervalued profession like psychology doesn’t leave much time for engaging with the strange world of policy making, the complete neglect by psychologists is inexcusable. A common refrain I hear is: ‘I want to do something but don’t know how to go about it’. The purpose of this article is to answer the “how” from my limited experience.

Let us begin:

• Build Knowledge: The first step is, of course, building a strong foundation of existing knowledge in the field. To that end, start with reading the National Mental Health Policy 2014, the Mental Healthcare Act 2017, the National Commission for Allied and Healthcare Professions Act 2021, the National Policy for Persons with Disabilities 2006, the Rights of Persons with Disabilities Act 2016, the Rehabilitation Council of India Act 1992 (along with proposed amendments), the National Health Policy 2017 and the National Education Policy 2020. Read relevant United Nations documents such as the Universal Declaration of Human Rights, the International Covenant on Civil and Political Rights, the International Covenant on Economic, Social and Cultural Rights, the Convention on the Rights of the Child and the Convention on the Rights of Persons with Disabilities. Do a deep dive into the WHO Mental Health Policy and Service Guidance Package. Read every other relevant document you can find. Read the Constitution of India. Just read, read and read.

• Spread Knowledge: If you have read everything listed above, you know more than 99.9999% of psychologists in India do. Tell others what you know. Write articles. Post on social media. Start a Substack publication. Author research papers. Tell people good things about a policy. Educate us on the limitations of a law. Inform government officials where the rules are not implemented. Become a beacon of awareness in the darkness of ignorance. It is possible that your writing may be read by a policymaker or someone who has the authority to take an action and may lead to change. For example, one of my articles on Allied and Healthcare Professions Bill was cited by Member of Parliament Bhartruhari Mahtab during a discussion on the Bill in Lok Sabha.

• Make Psychology Associations Accountable: Advocacy and lobbying are among the primary goals of any professional association. But the score of psychology associations in India on these counts is virtually zero. Other than organizing an annual conference, most psychology associations do nothing of value. Go to the website of any Indian psychology association and compare it with that of the American Psychological Association. You would see the immense difference. (National Academy of Psychology doesn’t even have a website for many months now. www.naopindia.org is inactive and their leadership is sleeping.) Let us ask the leaderships of Indian psychology associations to speak, write and advocate about mental health policies and laws. Let us ask them to move beyond university auditoriums and step into government offices, Parliament and courts.

• Attend Annual General Meetings of Psychology Associations: This point could have been included in the last one also, but I want to place a special emphasis on it. Many students and professionals attend annual conference of one or the other psychology association. Some of them also happen to be members of those associations. However, they are hardly involved in decision making processes of their organizations.

  A psychology association usually holds its Annual General Meeting (AGM) at the venue of the conference. But despite hundreds of its members being present at the venue, only a few dozens of them turn up at the AGM. The participants are usually the people who either are/were part of the leadership or aspire to join it. As a result, the associations become cliques and the “outsiders” have little information about their workings.

  An AGM is a place where the work of an association is reviewed, and questions are asked by the members. So, to actually know your association and influence its decisions, it is important that you take part in the AGM. (Even if you are not a member, you can participate in the AGM. Just ask the organizers. I have done this multiple times.)

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• Mental Health in Union and State Budgets: We know that the government expenditure on mental health in India is negligible. Not just expenditure, the attention to this field is also abysmal. For instance, in her 2021 Budget Speech, Union Finance Minister Nirmala Sitharaman mentioned vehicle scrapping policy under 'health and wellbeing' category but not mental health. Read that again: vehicle scrapping policy was part of 'health and wellbeing' in her speech but not mental health!

  Question the governments — both state and central — over allocation of funds to the mental health sector in annual budgets. Before the presentation of budgets, ask them to allocate adequate amount of money. Let us not just say ‘increase the budget’; we need to find out how much expenditure on mental health is necessary. Is it 1%–2% of GDP? Or 40%–50% of total health budget? We need to figure this out.

• Participate in Public Consultation on Laws and Policies: As I said in the beginning, the participation of practising psychologists in the drafting and consultation process of laws and policies is virtually non-existent. We need to change this scenario. Whenever governments and Parliamentary committees invite public comments on bills and drafts of policies and rules, make sure to submit your comments and ask others to do so too. For instance, the Government of India is currently in the process of amending the Rehabilitation Council of India Act 1992. The date of public comments passed months ago, but you can still write to the Government and Members of Parliament on the final version of the bill, which brings me to my next point.

• Write to MPs, MLAs, Ministers and Bureaucrats: Whenever there is an issue which requires the attention of an MP, MLA, minister or a bureaucrat, write to them. Do not hesitate. You may not get a reply, but when hundreds and thousands of professionals write to a policy maker on an issue, they are bound to pay attention. There are many MPs, MLAs and bureaucrats who are interested in mental health, but do not have an in-depth knowledge. Make your expertise available to them. Send them policy and legislative briefs. Help them seek accountability on mental health issues from the government. Submit questions to MPs and MLAs which they can raise in the Parliament and legislative assemblies, respectively.

• Make Mental Health an Election Issue: For any issue to become a part of a government’s agenda, it has to first become a part of a party’s election manifesto. In recent years, there have been campaigns to make mental health part of the election manifestos. These campaigns have been successful to an extent. For instance, in the recent legislative assembly elections in West Bengal, the mental health found space in at least two manifestos — those of Bharatiya Janata Party and Left Front.

  We need to continue this campaign with more ferocity. Mere mentions of mental health are not enough. We need parties to pledge in their manifestos that their government would allocate a stated minimum percentage of health budget to mental health and that they would hire psychologists for every village, block and district in the state.

• If you are a professor/head of psychology department, teach a paper on Psychology, Policy and Law: Isn’t it a shameful scene for our education system that students with bachelor’s and master’s in psychology in India have no in-depth knowledge of mental health laws and policies? Forget in depth, most of the psychologists don’t even have passing knowledge. How can we, then, expect them to comply with regulations in their counseling and psychotherapy practice? How can they participate in the policy making process and help the profession evolve? And how can a profession flourish whose practitioners don’t interact with bureaucrats and lawmakers?

  We cannot allow this ignorance to be continued. If you are someone who decides the curricula of psychology degrees, please include a paper on Psychology, Policy and Law in the course.

• Make Policy Communication Fun: All of us know this: the legal documents are technical, dry and boring. The professionals may read and understand them, but we need to educate the general public also. Therefore, the policies and laws are required to be communicated in an engaging and fun manner. If you can convey them in an engaging way, please do it. Frankly, I don’t have this skill. The most “fun” thing I could attempt in this article was linking a statement with a favourite Faiz Ahmed Faiz couplet (see second paragraph, if you missed it).

I hope these points will help you start your journey in the policy making process. It is not a one time activity, but a years long endeavour. Many times, there are failures and whatever policy changes we can achieve are only incremental. But over the years, these changes add up and the final outcome is immensely rewarding.

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Here, I wanted to provide a link to at least one online course on mental health policy, but I could not find any on platforms like Coursera, Udemy, edX, etc. If you find one, please let me know. I will update the space.

The Centre for Mental Health Law and Policy, Pune runs an International Diploma in Mental Health, Human Rights & Law. The applications are open now.

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Let’s begin with a couple of announcements:

First, since the beginning of psytizenship, I have wanted to write at least one article every week. The primary attractions are consistency and timeliness, but due to various reasons (mainly procrastination and COVID-19 issues), that has not happened, yet. Beginning today, you will get to read a new article on psytizenship every Friday. I am not very active on social media and don’t like posting article links there, so to stay updated, it would be better if you subscribe and get the latest pieces in your email inbox. That would also be a cool way to show your support to psytizenship.

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Second, I am experimenting with a new segment entitled ‘Developments at the Intersections of Psychology, Policy and Law’ containing latest updates from the field (with a particular focus on India). I will be sharing news, articles, court judgements, government orders, laws and research papers in this segment. The planned frequency is once a month and the last Friday of a month is reserved for it. If you come across anything which can be posted in this space, please write to me at ajay@ajaygulzar.com.

Following is the first edition of Developments at the Intersections of Psychology, Policy and Law.

1.     The higher courts of India rarely consult psychologists on relevant matters. For that matter, even the policy and law makers extremely rarely speak with psychologists. So, it came as a pleasant surprise when Justice N Anand Venkatesh of Madras High Court decided to consult a psychologist in a matter involving two woman petitioners whose relationship was “not to their [parents’] liking” and therefore, they were forced to leave their city.

Justice Venkatesh wrote in the order that he “thought it fit to refer the Petitioners and their respective parents to a counsellor who specialises in working with LGBTQI+ individuals. This move becomes very vital since this Court is moving into uncharted waters, and a report from a specialist will provide support to this Court to move forward in this case.”

He further wrote, “I am also trying to break my own preconceived notions about this issue and I am in the process of evolving, and sincerely attempting to understand the feelings of the Petitioners and their parents.”

In this regard, Justice Venkatesh also sought an appointment with the psychologist to understand same-sex relationships better. He wrote:

“Insofar as the request made by the learned counsel for the petitioners for setting out guidelines in cases of this nature is concerned, I want to give myself some more time to churn. Ultimately in this case, the words must come from my heart and not from my head, and the same will not be possible if I am not fully “woke” on this aspect. For this purpose, I want to subject myself for psycho-education with (psychologist) and I would request the psychologist to fix a convenient appointment for the same. I honestly feel that such a session with a professional will help me understand same-sex relationships better and will pave way for my evolution. If I write an order after undergoing psycho-education, I trust that the words will fall from my heart."

2.     In an order, the Delhi High Court asked the National Insurance Company Ltd, which rejected a woman’s claim for reimbursement of costs for treatment of schizophrenia, to comply with the provisions of Mental Healthcare Act 2017 and “held that her claim for ₹6.67 lakh was reimbursable as she was entitled to it. The court also imposed a cost of ₹25,000 on the insurance company to be paid to the woman for forcing her to opt for litigation to claim reimbursement.”

Moreover, “the High Court remarked that it was “clearly getting the feeling” that the insurance regulator [IRDA] was not taking action against the companies and was only taking steps when judicial orders were passed.”

3.     Can money prevent suicides? A study, led by global health and social medicine expert Daiane Borges Machado, investigated the effect of Bolsa Familia, the world’s largest conditional cash transfer programme, on suicide rates in a cohort of half the Brazilian population. The results:

“We evaluated the impact of the Brazilian Cash Transfer Program on suicide outcomes over a 12 year follow-up [2004-15] and observed that those receiving Bolsa Familia had a 61% lower risk of being a suicide victim than non-beneficiaries. The results were more pronounced among women and young individuals. These results demonstrate that economic interventions, such as Conditional Cash Transfers, contribute to the reduction of suicide, presumably by reducing poverty-driven hardship.”

Universal basic income, anyone?

Do read this article by Tanmoy Goswami on the study.

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After years of discussions, the legislation for allied and healthcare professions was recently passed by the Parliament of India. It received the assent of the President on March 28, 2021 and became the National Commission for Allied and Healthcare Professions Act, 2021 (NCAHP Act 2021). As many psychologists are unaware of the contents of this Act, there are questions and confusions. Therefore, in collaboration with COSAS Community, I have developed a Frequently Asked Questions (FAQs) guide. Please note that this piece is only for general information and is not a professional legal opinion. For many questions, there are no answers under the NCAHP Act 2021. Those questions may be answered by the rules and regulations to be framed later.

Frequently Asked Questions

• What are the objectives of the NCAHP Act 2021?

  As stated in the long title of the Act, its objectives are “regulation and maintenance of standards of education and services by allied and healthcare professionals, assessment of institutions, maintenance of a Central Register and State Register and creation of a system to improve access, research and development and adoption of latest scientific advancement.”

• Who are allied and healthcare professionals?

  The term “allied and healthcare professionals” includes two kinds of professionals who have obtained a recognized diploma or degree through regular learning mode under the NCAHP Act 2021: allied health professionals and healthcare professionals.

• Who are allied health professionals?

  As per this Act, an allied health professional is “an associate, technician or technologist who is trained to perform any technical and practical task to support diagnosis and treatment of illness, disease, injury or impairment, and to support implementation of any healthcare treatment and referral plan recommended by a medical, nursing or any other healthcare professional.” They should have obtained a qualification of degree or diploma with a coursework of minimum 2,000 hours spread over a period of two years to four years.

• Who are healthcare professionals?

  A healthcare professional “includes a scientist, therapist or other professional who studies, advises, researches, supervises or provides preventive, curative, rehabilitative, therapeutic or promotional health services.” They should have a qualification of degree with a coursework of minimum 3,600 hours spread over a period of three to six years.  

• Which mental health professions are included under this law?

  First, the NCAHP Act 2021 uses the term ‘behavioural health’, not ‘mental health’. The professions included under Behavioural Health Sciences category are:

a)     Psychologist (Except Clinical Psychologist covered under RCI for PWD)

b)    Behavioural Analyst

c)     Integrated Behaviour Health Counsellor

d)    Health Educator and Counsellors including Disease Counsellors, Diabetes Educators, Lactation Consultants

e)     Social workers including Clinical Social Worker, Psychiatric Social Worker, Medical Social Worker

f)     Human Immunodeficiency Virus (HIV) Counsellors or Family Planning Counsellors, and

g)    Mental Health Support Workers.

The Act also includes Movement Therapist (including Art, Dance and Movement Therapist or Recreational Therapist) under the Other Care Professionals category.

• Why does this law use the term ‘behavioural health’ and not ‘mental health’?

  It does not state the reason for using the term ‘behavioural health’. Instead, it simply claims that “‘Behavioural health’ is the preferred term to ‘mental health’.”

• What are the definitions of professional titles?

  The Act does not provide the definitions of professions. The Government of India has used International Labour Organization’s International Standard Classification of Occupations - 08 (ISCO - 08) to identify and map the professions, and hence, it argued that “the ISCO document already includes the definition of each profession.”

• Why are clinical psychologists excluded from this Act?

  The education and practice of clinical psychologists is regulated by an already existing statutory body, the Rehabilitation Council of India (RCI), and therefore, they are excluded from this Act.

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• How can a professional register themselves under this Act and who would be the licensing authorities?

  A person with recognized allied and healthcare qualification can register themselves with the respective State Allied and Healthcare Council or the National Commission, which would serve as licensing authorities. They will maintain the State Register and the Central Register, respectively. After registering with the State Council, the registered professionals' names will automatically be entered in the Central Register, enabling them to practice all over the country. Moreover, as per Section 38 of the Act, those professionals who are already offering their services can apply for provisional registration as per the regulations to be specified.

• What is the difference between state license and national license?

  The State Council is the primary registration body. After the professionals are registered with the State Council, their names will be entered in the National Register as well.

• For how long a certificate of registration is valid?

  As per the Section 33(4), the certificate of registration of an allied and healthcare professional shall be valid for a period of five years and will require to be renewed thereafter.

• Can professionals with distance learning degrees also register under the NCAHP Act 2021?

  This law recognizes qualifications obtained through regular learning mode only. Therefore, those who possess distance learning qualifications would not be able to register.

• If someone has obtained one degree through distance mode and another one in a regular manner — for instance, a master’s in psychology via distance mode and an MPhil in Counseling Psychology via regular mode — would they be able to register?

  The Act does not have a stated answer to this question. Most likely, the answer is no, but we should wait for the rules and regulations for clarity.

• If someone has obtained a bachelor’s in another field and a master’s in psychology, would they be able to register?

  Again, the Act does not have a stated answer to this question.

• Are minimum 3,600 hours supposed to be covered in one degree or multiple degrees?

  From the language of the Act, it appears that they would need to be covered in one degree spanning 3 to 6 years at undergraduate level. However, since psychologists usually obtain bachelor’s and master’s degrees, the calculation of 3,600 hours over multiple degrees would most likely be allowed.

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• How many hours are mandated for supervision and practical training?

  The Act does not specify minimum hours of supervision and practical training required.

• Can I call myself a psychologist after master’s degree?

  Yes, if a master’s degree becomes the recognized qualification under the rules to be framed, you can use Psychologist as your title after obtaining master’s degree in psychology and registering with a State Council.

• Would there be uniform entrance and exit/licensing examinations?

  Yes, the Act provides for uniform entrance and exit/licensing examinations, which would standardize the process of admissions and licensing across India.

• Would the degrees obtained abroad be recognized?

  Yes, as per Section 39(1), “any corresponding qualification granted by the institutions outside India shall be the recognised allied and healthcare qualifications as may be specified by regulations.”

• Would the Rehabilitation Council of India (RCI) have any role to play in the licensing of professionals under this Act?

  No, the National Commission for Allied and Healthcare Professions is separate from the RCI. A person representing RCI would be a member of the Commission, but the RCI itself would not be the licensing body for psychologists except clinical ones.

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• How will the Act impact higher education in psychology?

  One of the functions of the National Commission is providing “basic standards of education, courses, curricula, physical and instructional facilities, staff pattern, staff qualifications, quality instructions, assessment, examination, training, research, continuing professional education, maximum tuition fee payable in respect of various categories, proportionate distribution of seats and promote innovations.” It is expected that teaching and research would receive major boost, with particular emphasis on learning practical skills. The lack of availability of supervision is a major issue in psychology right now, which is expected to be solved as after the implementation of this law, it would be mandatory for the institutions to create facilities for providing supervision.

• Will this Act open up new job opportunities?

  For a proper implementation of the NCAHP Act, 2021, thousands of psychologists would be needed to be employed. However, that would require a large amount of budget for the mental health sector also. If the government actually increases the expenditure on mental health, then thousands of new job opportunities would be created. Moreover, the registration and standardization would increase career prospects in private sector also.

• Will the universities need extra accreditation?

  Yes, the Act contains provisions for recognition of allied and healthcare institutions. These provisions include basic standards of education and necessary facilities in respect of staff, equipment, accommodation, training, and hospital. If an institution fails to maintain the minimum essential standards specified by the Commission, the State Council may issue warning, impose fine, reduce intake or stop admissions and recommend to the Commission the withdrawal of recognition.

• Does the Act contain any ethical standards to be maintained by psychologists?

  The regulation of the professional conduct, code of ethics and etiquette to be observed by the allied and healthcare professionals is one of the functions of the National Commission. The Allied and Healthcare Profession Ethics and Registration Board, under the State Council, shall be primarily responsible for regulation of the professional conduct and promotion of ethics.

• What will happen if someone practices without a license?

  If someone uses the title or description of a profession mentioned in the NCAHP Act, 2021 without registration in the Central Register or a State Register, a fine of up to Rs 1 lakh may be imposed on first conviction. On subsequent conviction, there is provision of imprisonment up to 1 year and fine up to Rs 2 lakhs.

• What are the drawbacks of the NCAHP Act 2021?

  Well, as far as psychology is concerned, the problems with the NCAHP Act start from the name of the profession itself: Behavioural Health Sciences. The major drawbacks include the inadequate and incomplete definition of the professional category, absence of patient centric provisions like informed consent and advance directive, division of psychologists between multiple legislations and ministries, clubbing of other professions with behavioural health sciences category, lack of clarity on definitions and scope of individual professions, creation of an unnecessary and imaginary hierarchy between behavioural health sciences professionals and mental health professionals, no provision for degrees already obtained under distance learning mode, and acute under-representation of psychologists. You may read a detailed analysis of drawbacks here.

If you have any questions, which have not been answered in this FAQs guide, please leave a comment.

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Acknowledgements: I am grateful to all the organizations which invited me to speak on various versions of this legislation. I am immensely thankful to COSAS for inviting me to speak and collaborating on this article. Special thanks are due to Kantadorshi Parashar, Rashi Trehan and Kadambari for reviewing the drafts of the articles on this legislation and providing outstanding feedback. My deep gratitude to Rashi for creating embodied photographs, which accompany all of my articles.

About COSAS: COSAS is a community-oriented mental health organization working towards creating a mental health inclusive society. It offers services in psychology internships, training and courses to anyone aiming to be a mental health advocate and ally. To know more about them and what they do, please log on to www.cosas.org.in or follow them on Instagram (@cosascommunity).

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Rarely does it happen that a Bill goes to a Parliamentary Committee for improvement and comes back in a worse form. As far as psychology is concerned, this is exactly what happened in the case of National Commission for Allied & Healthcare Professions Bill 2021.

Let’s recap! On December 31, 2018, a Bill entitled the Allied and Healthcare Professions Bill, 2018 (AHPB 2018) was introduced in the Rajya Sabha by the then Union Minister of Health and Family Welfare Mr Jagat Prakash Nadda. Its objective was “regulation and maintenance of standards of education and services by allied and healthcare professionals and the maintenance of a Central Register of Allied and Healthcare Professionals.”  

Understandably, the AHPB, 2018 was sent to the Parliamentary Standing Committee on Health and Family Welfare for examination and report on January 02, 2019. After more than a year (during which the general elections to the Lok Sabha were also held), the Standing Committee presented its report to the Parliament on January 31, 2020. In light of the Committee’s recommendations, the Government revised the Bill and the Union Minister of Health & Family Welfare Dr Harsh Vardhan introduced the new version as the National Commission for Allied & Healthcare Professions Bill (NCAHP Bill) 2020 in the Rajya Sabha on September 15, 2020.

The NCAHP Bill is a landmark legislation and defines two kinds of professionals: allied health professionals and healthcare professionals. The allied health professional is “an associate, technician or technologist who is trained to perform any technical and practical task to support diagnosis and treatment of illness, disease, injury or impairment, and to support implementation of any healthcare treatment and referral plan recommended by a medical, nursing or any other healthcare professional.” They should have obtained a qualification of degree or diploma with a coursework of minimum 2,000 hours spread over a period of two years to four years.

The healthcare professional “includes a scientist, therapist or other professional who studies, advises, researches, supervises or provides preventive, curative, rehabilitative, therapeutic or promotional health services.” They should have a qualification of degree with a coursework of minimum 3,600 hours spread over a period of three to six years.   

The NCAHP Bill covers ten categories of professions such as medical laboratory and life sciences; trauma, burn care and surgical/anesthesia related technology; physiotherapy; nutrition science; ophthalmic sciences; occupational therapy; community care, behavioural health sciences and other professionals; medical radiology, imaging and therapeutic technology; medical technologists and physician associates; and health information management and health informatic professionals.  

The scope of this article is limited to category number seven: community care, behavioural health sciences and other professionals. Two years ago, in an article on AHPB 2018, I had written that in India, psychology as a discipline had always been in an identity crisis and those conflicts of identity were at the heart of that Bill. The new NCAHP Bill shows us that even worse is possible. Let’s unpack the issues with this Bill one by one as far as the ‘community care, behavioural health sciences and other professionals’ category is concerned:

1.     The first problem is the name of the professional category itself. Instead of the usual term “mental health,” the Bill uses “behavioural health.” In fact, it is stated in its Schedule that “‘Behavioural health’ is the preferred term to ‘mental health’.” It does not tell us why, but I will not go into the conceptual debate. The problem I want to highlight is of more immediate and practical significance: the conflict of this nomenclature with the already existing terminology in law.

In India, we have the National Mental Health Policy 2014 and the Mental Healthcare Act 2017. As it is clear from the names of these documents, they use the term ‘mental health’. Similarly, the National Health Policy 2017 also uses this term. Under the Mental Healthcare Act 2017, the clinical psychologists are ‘mental health professionals’, but under the NCAHP Bill, other psychologists and counsellors are ‘behavioural health sciences professionals.’ Why has the government used different terms for the same discipline? Are the sub-fields drastically different in reality? If yes, what are those differences? Would this not create a conceptual, legal and administrative conflict among professionals belonging to the same discipline? And would it not also confuse the people who avail their services?

2.     The term ‘behavioural health sciences’ is defined, in the Bill, as the “scientific study of the emotions, behaviours and biology relating to a person's mental well-being, their ability to function in everyday life and their concept of self.” This definition refers only to “study” and not practice, the more important part which the NCAHP Bill seeks to regulate. For example, in the Mental Healthcare Act 2017, the definition of ‘mental healthcare’ is the “analysis and diagnosis of a person's mental condition and treatment as well as care and rehabilitation of such person for his mental illness or suspected mental illness.” Although not ideal, this definition does include the practice part also, which is of immediate significance with respect to the patients and their care.

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3.     The Mental Healthcare Act 2017 includes provisions like informed consent (“consent given for a specific intervention, without any force, undue influence, fraud, threat, mistake or misrepresentation, and obtained after disclosing to a person adequate information including risks and benefits of, and alternatives to, the specific intervention in a language and manner understood by the person”), advance directive (“the way the person wishes to be cared for and treated for a mental illness, and the way the person wishes not to be cared for and treated for a mental illness”) and least restrictive alternative/environment (“offering an option for treatment or a setting for treatment which meets the person’s treatment needs and imposes the least restriction on the person’s rights”).

These provisions put the patients at the centre and recognize their rights. However, the NCAHP Bill does not contain such provisions, depriving the patients of their basic rights in the behavioural health sciences ecosystem. It is possible that the National Commission for Allied & Healthcare Professions would wake up one day and form guidelines about informed consent, advance directive, etc., but the fact is that they would not have the force of an Act made by the Parliament of India. Therefore, these provisions should have been included in the Bill itself.

4.     The NCAHP Bill has excluded clinical psychologists because, the government argues, they are already covered in the Rehabilitation Council of India (RCI) Act, 1992. However, the RCI is under the Ministry of Social Justice and Empowerment, Government of India. The National Commission for Allied and Healthcare Professions is under the Ministry of Health and Family Welfare. It is absurd that one sub-field of psychology — clinical psychology — is regulated by one ministry and other sub-fields would be regulated by another ministry. This makes me wonder if it would be sensible if the psychiatrists were under the Ministry of Social Justice and Empowerment, while all other doctors were under the Ministry of Health and Family Welfare. Moreover, the division of psychologists between two ministries would only create barriers in coordination and collaboration among members of the same profession. In my opinion, it is the government’s laziness and status quoist approach that has led to this bizarre situation.

5.      I hope you have noted that the name of the professional category is ‘community care, behavioural health sciences and other professionals,’ not ‘behavioural health sciences professionals.’ It is primarily for this reason I said in the beginning that the NCAHP Bill went to the Parliamentary Standing Committee for improvement but came back in a worse form.  

In the AHPB 2018, the category was called ‘behavioural health sciences’ and included only psychologists and counsellors. Since many professions were asking for their own independent regulatory councils, the Standing Committee recommended that those Councils should be formed under the overarching National Commission for Allied and Healthcare Professions. It suggested that the similar professions could be clubbed together to form such Councils. Hence, one of the Committee’s recommendations was to group together life sciences professionals, nutrition science professionals and behavioural health professionals to form a Council for Life, Nutrition and Behavioural Health Science Professionals. The Government accepted the idea, but decided to group together community care professionals, behavioural health professionals and “other care professionals” instead. Hence, from both the Government and the Parliament, the psychologists and counsellors got bad deals. Leave alone an independent National Psychology Council, they did not even get their own independent professional category.

Additionally, the category number seven is the only category that includes the term “other professionals.” The government could not even find a proper term for these “other professionals,” because what common label one can put on podiatrists, palliative care professionals and movement therapists (who, in the Bill, include art therapists, dance and movement therapists, and recreational therapists).

6.     The Government of India has adopted International Labour Organization’s International Standard Classification of Occupations – 08 (ISCO-08) for identification and mapping of professionals “so as to allow for global recognition and mobility.” In the Bill, only the names of professions and their ISCO – 08 codes are mentioned, and the definitions of professions are not provided because, as per the government’s argument, “the ISCO document already includes the definition of each profession.”

Herein lies the contentious issue. Only the definition of “psychologist” is provided in the ISCO – 08 and not that of “behavioural analyst,” “integrated behaviour health counsellor,” “health educator,” “disease counsellor,” “clinical social worker,” “psychiatric social worker,” “medical social worker,” etc., which are also included in the behavioural health sciences category. In fact, these professions are not even specifically mentioned in ISCO – 08! What is the difference between a behavioural analyst and an integrated behaviour health counsellor in Indian law? Or the difference between a clinical social worker and a medical social worker? We don’t know!  

Coming back to the definition of a psychologist, the ISCO – 08 actually includes all sub-fields of psychology. Since the NCAHP Bill excludes only clinical psychologists, are we supposed to assume that it includes all other kinds of psychologists including, for example, educational psychologists and organizational psychologists? The plain reading of the Bill indeed suggests so.

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7.     The ‘community care, behavioural health sciences and other professionals’ category includes environmental protection officers, ecologists, occupational health and safety officers (inspectors), podiatrists and palliative care professionals also. In the ISCO – 08, the environmental protection officers and the ecologists are categorized as Life Science Professionals. The NCAHP Bill also has a category, in fact the very first, with the same name. Why, then, these professionals are included with mental health, sorry, behavioural health professionals?

Similarly, in the ISCO – 08, the occupational health and safety officers (inspectors) are classified under ‘environmental and occupational health inspectors and associates’ along with food sanitation and safety inspector, pollution inspector and product safety inspector. Going ahead, the podiatrists, art therapists, dance & movement therapists and recreational therapists are categorized as Health Professions Not Elsewhere Classified (2269). The palliative care professionals are mapped under Health Associate Professionals Not Elsewhere Classified (3259). Following ISCO – 08, why did then the government not take all these professions and formed a separate ‘others’ category? Why were these professions forcefully clubbed together with the behavioural sciences? Is it because the government thought that the psychologists won’t notice, or even if they did, then won’t speak against it? If so, I admit that it is a very good reason, but unfortunately not a lawful one.

It is important to mention here that the ISCO – 08 code for occupational therapists is also 2269 (Health Professions Not Elsewhere Classified). Why do then all professions with code 2269 — the podiatrists, art therapists, dance & movement therapists, and recreational therapists — are not grouped together with occupational therapy professionals? Is it because the occupational therapy professionals wanted their own independent category and nobody else to be included with them? Again, an excellent reason, but it destroys the government’s argument that the ISCO – 08 has been strictly followed to recognize and club professions.

8.     The usual higher education structure in psychology consists of a bachelor’s degree of three years, a master’s degree spanning two years, a two-year MPhil, and a PhD (minimum three years). Within the discipline, there is usually no place in the job market for those who hold only a bachelor’s degree. An MA/MSc is necessary. Still, as of today, to be qualified as a registered psychologist and have better career prospects, an MPhil is required. For academia, the PhD is a must (some exceptions can be found here and there though).

As per the NCAHP Bill, the allied health professionals should have a degree or diploma with a coursework of minimum 2,000 hours spread over a period of two years to four years. A BA/BSc would come in this, but from career point of view, it doesn’t have much value in psychology. Hence, the healthcare professionals’ qualification becomes of practical importance who should have a qualification of degree with a coursework of minimum 3,600 hours spread over a period of three to six years. It’s not clear whether the entire coursework has to be covered in one degree or can be covered in more than one degree.

Assuming that it can be covered in two degrees (it would have to be allowed otherwise almost everyone holding bachelor’s and master’s in psychology would be disqualified), the psychologists and counsellors under this Bill would have five years of coursework, whereas the clinical psychologists currently have to undergo seven years of coursework. Does this mean that the behavioral health science professionals would be considered inferior to the mental health professionals? Even if in future, the maximum six years of coursework is made mandatory for other psychologists, it would still not be equal to that of clinical psychologists. It appears that with its poverty of thought, the government has created an unnecessary hierarchy of psychologists. In my view, it has occurred primarily because the government has attempted to impose the realities of medical professions on psychology. [Also, to be noted here is the case of psychiatric social workers: under the Mental Healthcare Act 2017, they need a two-year MPhil (hence seven years of education in total). Under the NCAHP Bill, the maximum course time is six years. So, would there be two kinds of psychiatric social workers?]

9.     There are many psychology professionals in India, who received their education through distance learning mode. The NCAHP Bill states that the allied and healthcare qualification has to be obtained through regular mode only. While I completely support this provision, the care should have been taken to include, in some way, those who already possess distance learning degrees and have accumulated significant work experience. To begin with, these professionals would not be able to provisionally register under Section 38 of this law, which states that “every person who offers his services in any of the recognised categories on or before the commencement of this Act shall be allowed to be provisionally registered under the provisions of this Act.”

Another question is about the continuation of distance learning courses in psychology. Would universities like IGNOU no longer be able to offer degrees in psychology? And if they would be allowed, what would be their degrees’ value in the eyes of National Commission for Allied and Healthcare Professions?

10.  Another major drawback of the NCAHP Bill is the under-representation of psychologists in the Commission and the Professional Council. Every category mentioned in the Schedule of the Bill would have a Professional Council. The President and a member of the Professional Council would be part of the overarching Commission. Now, the President of Physiotherapists’ Professional Council would always be a physiotherapist; that of Nutrition Science Professional Council would always be a dietician or nutritionist; that of Occupational Therapy Professional Council would always be an occupational therapist and so on, but the President of Community Care, Behavioural Health Sciences and Other Professionals’ Council would not always be a psychologist. There would be many times when both the President and the representing member would not be psychologists. (In fact, I am willing to stick my neck out and say that a psychologist would never be appointed as the Chairperson of the Commission.)

Even within the Professional Council, which can have four to twenty-four members, the mental health, sorry again, the behavioural health sciences would never be in focus all the time. The physiotherapists can focus only on physiotherapy and the nutritionists can focus only on nutrition, but the psychologists and counsellors would share time and resources of the Council with podiatrists and ecologists among others. How much impact would it have on behavioural health priorities? It is anybody’s guess.

This under-representation and rejection of psychologists has happened earlier also. For instance, in the Mental Health Policy Group — formed to design the National Mental Health Policy (released in 2014) — there was no practising psychologist. There was hardly any consultation with the psychologists during the drafting of Mental Healthcare Act 2017. Even during the drafting of this Bill, there was virtually no consultation with the psychologists. No psychologist was called by the Parliamentary Standing Committee as expert witness. In short, whenever the government has formed any major law or policy for psychology, the psychologists have never been consulted.

11.  The Clause 11(1)(g) provides for a “uniform entry examination with common counselling for admission into the allied and healthcare institutions.” It is not certain if there would be only one entrance exam for all the professions. I hope not because I do not see why and how a psychology aspirant would take the same entrance exam as the one taken by, say, a future nuclear medicine technologist.

In the earlier version, the AHPB 2018, there was also a provision for “a uniform exit or licensing examination,” which, in NCAHP Bill, has been changed to “exit or licensing examinations.” If we were to read between the lines of this change, then it is likely that there would be only one entrance examination for all categories, but separate exit/licensing examinations. Again, only time will tell how this would pan out.

12.  A point which is applicable to all professions: the NCAHP Bill does not state the minimum period of practical training necessary for qualification as an allied and healthcare professional. The definitions state the total duration requirements only. In my opinion, if it was stated in the law itself, it would have been better.

Also, the functions of the Professional Councils are not defined in the Bill. Hence, their powers and responsibilities have been left at the whims and mercies of the Central Government and the Commission.

To summarise, as far as psychology is concerned, the problems in the NCAHP Bill start from the name of the profession itself. The inadequate and incomplete definition of the professional category, absence of patient centric provisions like informed consent and advance directive, division of psychologists between multiple legislations and ministries, clubbing of other professions with behavioural health sciences category, lack of clarity on definitions and scope of individual professions, creation of an unnecessary and imaginary hierarchy between behavioural health sciences professionals and mental health professionals, no provision for degrees already obtained under distance learning mode, acute under-representation of psychologists, and uniform entry examination are some of the issues which would continue to keep the discipline of psychology stagnant and in a perpetual identity crisis.

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Finally, I am restating what I have stated earlier elsewhere also. This Bill is primarily for the medical community. The inclusion of psychologists seems like an afterthought. Many psychologists, of course, work in healthcare settings but not all of them. However, the Bill seems to include all kinds of psychologists, even the ones who do not deal with health. My fear is that the National Commission on Allied and Healthcare Professions would focus primarily on medical and related specialties thereby resulting in continued negligence of students and practitioners from the behavioural health sciences category.

Here we are talking of a discipline which has always been on the margins. Despite its more than a century long existence, the growth and contribution of psychology to Indian society is negligible. The government’s budget allocations to this discipline are minuscule; its members are treated not more than the medical support staff in hospitals; and its identity crisis is so deep that some years ago, the University of Delhi decided to award a BTech in Psychological Science! The fundamental question is essentially this: for how long can the neglect of psychology in India continue? Or a slightly more important question would be: for how long the psychologists would stay silent and allow their neglect to continue?

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As soon as I downloaded the Budget 2020-21 documents, I looked for allocations under the Ministry of Health and Welfare. When I saw the budgetary support for National Mental Health Programme (NMHP), my instant reaction was laughter as it was no laughing matter. Millions of Indians spent the year 2020 dealing with mental health issues during theCOVID-19 pandemic. But instead of enhancing the funding for NMHP, the government reduced it during financial year 2020-21 from the already measly amount of Rs 40 crore to Rs 27.36 crore. Moreover, for the year 2021-22, the allocation has been kept flat at Rs 40 crore. In an article before the presentation of the Budget, I had stated “If a pandemic — which woke up millions of people each day to realities of mental health crises within their four walls — cannot force a government to pay attention and allocate significant resources to mental health sector, then nothing ever can.” Now, I could only look at the allocation figures and imagine that ‘meri taraf mat dekhiye, main aapki koi sahayta nahi kar paunga’ — please don’t look at me, I can’t help you — meme. 

Even though I had no hope from the government as far as mental health is concerned, I am disappointed. In her budget address, Finance Minister Nirmala Sitharaman spoke about nutrition, water supply, Swachh Bharat, clean air and even vehicle scrapping policy under ‘health and wellbeing’ but did not mention mental health at all. Vehicle scrapping policy but not mental health? In a year of millions of mental health conversations? The neglect is just amazing.

The allocations for other mental health related schemes are down too. The National Trust for the Welfare of Persons with Autism, Cerebral Palsy, Mental Retardation [why do we still have this phrase?] and Multiple Disabilities has seen its proposed expenditure reduced from Rs 39.50 crore (Budget Estimates 2020-21) to Rs 30 crore (Budget Estimates 2021-22). For the Scheme for Implementation of Persons with Disability Act, the budget is down to Rs 209.77 crore from Rs 251.50 crore. For the second consecutive year, the National Institute of Mental Health Rehabilitation has been given no money. Only National Institute of Mental Health and Neurosciences (NIMHANS), Bengaluru and Lokpriya Gopinath Bordoloi Regional Institute of Mental Health, Tezpur have seen some marginal enhancements in their budgets.

Another point I had mentioned in my article was the mental health data. The Finance Minister’s speech made no mention of it, but the real surprise came today. A Rajya Sabha member Elamaram Kareem had asked the government the number of registered mental health professionals including clinical psychologists in the country. He also asked the number of additional seats created in clinical psychology and psychiatry since the implementation of the Mental Healthcare Act, 2017 (MHCA 2017). The Health and Family Welfare State Minister Ashwini Kumar Choubey replied that the requested data is “not maintained centrally.” This is surprising since MHCA 2017 mandates Central Mental Health Authority to maintain and publish a register of all mental health establishments and certain mental health professionals including clinical psychologists. 

It is not that after decades of neglect, one expects the government to transform mental health landscape overnight. It is that the budget did not even take baby steps. Much was made about the fact that it is this decade’s first budget. Well, if we expect great results in the mental health sector by 2030, it would have been better if the Finance Minister had begun yesterday by announcing some initiatives. For instance, I had written that even an allocation of just Rs 10,000 crore (against a necessity of at least Rs 100,000 crore) for mental health would be a good start. In fact, even if the Finance Minister had budgeted only Rs 100 crore for NMHP (instead of keeping it at Rs 40 crore) and mentioned it in the speech (saying, for example, that the allocation had been increased by 150%), it would have been reasonable. 

Sometimes, you just need an intent and the evidence that it is backed by action. But in Budget 2021, our mental health got nothing.

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