The Allied and Healthcare Professions Bill, 2018 is terrible for psychology

Ajay Gulzar
4 min readJan 21, 2019

Psychology as a discipline has always been in an identity crisis, especially in India. Is it a branch of philosophy? The answer now is ‘no’. Is it a branch of social sciences? That is how it is taught in the Indian Institutes of Technology (IITs) and some other institutions. Does it belong in the Arts? The nomenclature of the degrees — BA and MA — granted by many universities might suggest so. Is it a science? Many colleges and universities award science degrees — BSc and MSc — to their psychology graduates. This identity crisis is so deep rooted that some years ago, the University of Delhi decided to award a BTech in Psychological Science! Similar conflicts of identity are at the heart of The Allied and Healthcare Professions Bill, 2018 as far as psychology, or ‘Behavioural Health Sciences’ as the Bill calls it, is concerned. There are several issues with this Bill.

First, the Bill excludes clinical psychologists. At one level, this exclusion seems justified since they are already included in the Rehabilitation Council of India (RCI) Act, 1992. However, RCI is under the Ministry of Social Justice and Empowerment, Government of India. The Allied and Healthcare Council of India (AHCI), envisaged in the Bill, would be under the Ministry of Health and Family Welfare. It makes no sense that one sub-field of psychology — clinical psychology — is regulated by one ministry and other sub-fields would be regulated by another ministry when both of them are part of the same discipline. Moreover, a ministry whose primary mandate is social justice should not be in the business of healthcare regulation.

Second, there is acute under-representation of psychology in the AHCI. As per Clause 3 of the Bill, the Council would consist of various representatives of the Government, NITI Aayog, different professional councils, etc. It would also 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.

Third, the Clause 10(f) 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.” The Bill deals with biotechnologists, environment protection officers, burn care technologists, advance care paramedics, physiotherapists, nutritionists, optometrists, podiatrists, community health promoters, nuclear medicine technologists, radiology and imaging technologists, ECG technologists, forensic science technologists, health information management professionals, urology technologists, surgical technologists, and of course, psychologists and counsellors. It is inconceivable that a psychology aspirant should take the same entrance exam as the one taken by, say, a future nuclear medicine technologist. Same problem arises in case of “a uniform exit or licensing examination” as provided by the Clause 10(g) of the Bill. A psychologist and a podiatrist cannot take the same licensing examination.

Finally, 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. The Allied and Healthcare Professions Bill, 2018 seems to include all kinds of psychologists (except clinical), even the ones who do not deal with health.

Psychology as a modern discipline has existed in India for over a century now. Despite this long existence, it has not grown and its contribution to Indian society is negligible. The most significant reason for this is the absence of an independent, statutory body for the profession. Rehabilitation Council of India (RCI) deals only with, as the name suggests, rehabilitation of persons with disability. For this purpose, it has created various categories of professionals in the field of rehabilitation and special education. 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 ‘Behavioural Health Sciences’.

The psychologists do not need multiple councils, ministries and legislations for their and the profession’s development. In fact, such an arrangement takes the focus away from them and leads to stagnation of the discipline. Mental health is a primary concern in the twenty-first century. For the welfare of both the practitioners and the clients, we need an independent National Psychology Council, which would look after the education, training and practice in the relevant sub-fields of psychology. Therefore, the Behavioural Health Sciences category should be removed from the Allied and Healthcare Professions Bill and the government should introduce a new Bill for the creation of the National Psychology Council.

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Ajay Gulzar

Psychology. Policy. Law. Poetry. LAMP Fellow, 2015–16. Alumnus: JNV, University of Delhi, IIT Bombay.