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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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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