Remove psychology from AHP Bill, 2018 & create an independent National Psychology Council

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One out of every four of us is likely to deal with some kind of psychological issue in the course of our lives. Mental health undoubtedly forms a key issue of our times and every time an individual faces a psychological problem, an oft-given advice is: seek professional help.

But when there is an absence of legal standards for education, training and licensing for the professionals, both the practitioners and clients face problems and are left with many confusions and doubts. The future psychologists don’t know about the qualifications to become eligible for practice and the clients can’t decide whom to trust with their life. To fill this gap, we need a legal framework for education, training and licensing.

The Allied and Healthcare Professions Bill, 2018 seeks to provide such a framework.

However, instead of providing benefits, it does harm to the profession and the public. Here is how:

1. The Bill seeks to govern different sub-fields of Psychology except Clinical Psychology since that is already covered by the Rehabilitation Council of India under Ministry of Social Justice and Empowerment. But it makes no sense that one sub-field of psychology — Clinical Psychology — is regulated by one ministry and other sub-fields are regulated by another ministry when both of them are part of the same discipline. This arrangement would adversely affect the teaching, research and practice in psychology. Moreover, a ministry whose primary mandate is social justice should not be in the business of healthcare regulation.

2. There is an acute under-representation of psychology in the proposed Allied and Healthcare Council of India. Other than bureaucrats, the Council would have Directors/Superintendents of four medical institutions, but no one from a mental health/psychology institute. There is only one representative from the ‘Behavioural Health Sciences’ category, while some other categories like Medical Laboratory Sciences, Medical Radiology, Imaging and Therapeutic Technology, Ophthalmic Sciences and Physiotherapy would have two representatives each. This inadequate representation would adversely affect the quality of policy making in the area of psychology leading to further neglect of the discipline.

3. The Bill provides for a “uniform entry examination with common counselling for admission into the allied and healthcare institutions at the diploma, undergraduate, postgraduate and doctoral level” and a "uniform exit or licensing examination.” The Bill covers professionals like bio-technologists, environment protection officers, burn care technologists, physiotherapists, nutritionists, optometrists, podiatrists, nuclear medicine technologists, radiology and imaging technologists, ECG technologists, forensic science technologists, and psychologists. It is absolutely unrealistic that a Psychology aspirant should take the same entrance exam as the one taken by, say, a future Nuclear Medicine Technologist. Similarly, a psychologist and a podiatrist cannot take the same licensing examination.

4. The Allied and Healthcare Professions Bill is primarily for the medical community. The inclusion of psychologists is inappropriate. Many psychologists, of course, work in healthcare settings but not all of them. Psychology is not limited to healthcare only and it is not a medical profession. Also, within the medical community, the psychologists are often treated as the support staff, which has led to degeneration of their autonomy, erosion of authority and lower remuneration for them.

In India, Psychology as a profession has not fully developed yet. The most significant reason for this is the absence of an independent, statutory body for the profession. The Rehabilitation Council of India (RCI) deals only with, as the name suggests, rehabilitation. The narrow mandate and focus of the RCI has led to the neglect of clinical psychologists. Similarly, the Allied and Healthcare Council of India would focus on medical and related specialties resulting in negligence of students and practitioners from psychology. Therefore, merely standardizing and regulating the discipline would help neither the psychologists nor the public. We need a body which would work towards (a) developing the profession and (b) regulating it.

Given these issues and concerns, we request the Parliamentary Standing Committee on Health and Family Welfare and the Government of India that:

1. The ‘Behavioural Health Sciences’ category should be removed from The Allied and Healthcare Professions Bill, 2018.
2. For the development, standardization and regulation of psychology, an independent, statutory National Psychology Council should be established.
3. The Clinical Psychologists should be removed from the Rehabilitation Council of India (RCI) Act, 1992 and included in the National Psychology Council.

As a client, if you want better psychologists and as a psychologist, if you want a better future, please sign this petition.