Feedback and Suggestions Regards to Physiotherapy Council

Physiotherapist

This document contains the feedback and suggestions supported by relevant references on

ALLIED AND HEALTHCARE PROFESSIONAL CENTRAL COUNCIL BILL 2015 uploaded by ministry of

health & family welfare for Comments/Feedback from stakeholders on the bill.

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Date 22/10/2015

To,

The Secretary

Ministry of Health and Family Welfare Nirman Bhawan, New Delhi

Sub: - Resentment with respect to proposal for the formation of Physiotherapy Council in present

form and Seeking Comments/Feedback from stakeholders on the same, October 25th, 2015)

Respected sir/madam,

With regard to the aforesaid subject, I would like to place before you certain enlightening facts

pertaining to Physiotherapy Profession in our country for your kind perusal and just action in the favor

of Independent Physiotherapy Council. As informed, I do citizen do offer suggestions for the rest of

the professionals, annexed as Annexure -1

Historical facts and background of Physiotherapy profession suffering in Union of

India.

I would like to bring to your kind notice that the Government of India had already decided to have an

independent Council for Physiotherapists under the Ministry of Health and Family Welfare with separate

cells for Occupational T h e r a p i s t a n d Physiotherapists way back in the year 1988 and budgetary

allocation of 5 lakhs rupees was also sanctioned between the years 1989-90 for the same.

Physiotherapy has been defined and categorized more than half dozen by MoHFW in

years 1994(independent council), 1995(paramedical along with lab technician),

1998(rehabilitation professional), 1999(paramedical along with lab technician),

2002(physiotherapy & paramedical), 2012(allied health), 2014(allied health) and

2015(along with physician assistant & dietician) in a very contradictory manner to

implicate physiotherapists with paramedical /allied health/physician assistant &

dietician (non-direct form of health discipline) profession in influence of physician

especially PMR.

Some important dates and incidents are mentioned below: (1998-2007)1

1988 The Government of India decided to have an independent Council under the Ministry of Health

and Family Welfare with separate cells for Occupational Therapist and Physiotherapists

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1989 Budgetary allocation of 5 lakhs rupees for Physiotherapy and occupational therapy council bill.

1994 The MoHFW defined the term Physiotherapy as independent professional and prepared the

bill.

1995 The MoHFW on the recommendation of Law ministry conducted the state health secretary

meeting which decided the paramedical bill to be legislated

1997 Files pertaining to Paramedical and Physiotherapy, reported to be misplaced by them and

later on the noting portion was received from the office of DGHS.

1998 MoHFW itself recorded the need of dominance between PMR and Physiotherapy

1998 Government notified Physiotherapy in rehabilitation council of India (RCI) and categorized as

rehab professional.

1999 The Government de - notified Physiotherapy from RCI.

2001 Despite the aforesaid need of dominance observations, MoHFW constituted an expert

committee consisting of a PMR doctor, pathologists and Radiologists, without any expert

from the Physiotherapy profession to define the term “Physiotherapy”. The committee inserted

the term “Medically directed” in defining Physiotherapy in above said meeting.

2002 The paramedical bill was sent to the Ministry of Law for vetting. The Ministry of law pointed out

that” they are not paramedical and don’t come under the purview of paramedical” and the same

was accepted by MoHFW.

2002-7 The term ‘medically directed’ was strongly opposed by physios; it was rejected by MoHFW in

view of expert opinion, where PMR professionals were members.

2007 Department related standing committee on Health and family welfare in its report on

paramedical and physiotherapy bill 2007 pointed out that the word ‘Medically directed’ in

the definition of Physiotherapy has been deliberately used defeating the very basis of defining

a profession in para9.47 and also observed the discrimination of physiotherapy by the

MoHFW .The same committee also observe the rivalry between medical profession and

physiotherapist in 9.452

2008 Bill Lapsed

2012 MOH&Fw released a report ‘Paramedical to allied health’, and presented to the MoHFW. The

role of private body PHFI which has members from MoHFW at the cost of public exchequer

of Rs 64 lakh is dubious. The report has presented the profession in a derogatory manner and the

experts have dissociated from the report3.

2014 Physiotherapy service was defined with restriction under the Clinical Establishment Act Rule

with PMR as chairman of committee, as allied health professional services4.

2015 syllabus hosted in the portal for the Ministry of Health and Family welfare, seeking comments

from stake holders also hosted in the portal for the Ministry of Health and Family welfare,

described physiotherapy scope of practice with limited scope of practice and term diagnosis or

method of treatment/system of treatment is missing from the definition.

It is very sad to point out that office of physician especially of PMR Rather engaged in using derogatory,

unconstitutional and medically vested term like “medically directed therapy” and “have to render the

duty under prescription of PMR /Physician” its rule ,circular, order and reports in direct violation of

fundamental right “right to practice”.5

The uploaded draft right away speaks to subsume the Delhi council of physiotherapy, which define

the physiotherapy as method of treatment and provides professional freedom to serve the patients as

autonomous profession. On the other hand, the draft defines the health and allied as …………

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“Prescribed as under rule of government of India “. I am afraid the above mentioned rules and

reports, which are direct violation of fundament; do not fall in the description of ………… “Prescribed

as under rule of government of India “. If it so, in that case, I wonder, rule will precede the act and

subsume more ethical act of Physiotherapy?

Deteriorating condition of Physiotherapists in India in comparison of developed Nations:

It is humbly informed that the Government of India does not know the number of Physiotherapists6 due

to lack of Physiotherapy council and Due to the same, there is rampant irregularities in recruitment of

physiotherapist e.g.; at Safadarjung Hospital alone since 2008, in 5 different recruitment have been done

with five different recruitment age criteria, Despite complain and resentment no action has been taken.

year 2008- prescribed age for the recruitment -27

year 2011-prescribed age for the recruitment -25

year 2012-prescribed age for the recruitment 27

Year 2013- prescribed age for the recruitment 25 and age of the candidate will be counted

from closing date of previous advertisement.

Year 2015- prescribed age was 35.

Despite complaint and resentment by Indian Association of Physiotherapists that rules have been

violated in year 2010 and 2013.

It has been claimed that “there is acute shortage of allied health professionals” which is contrary to the

truth in the case of Physiotherapy profession. Rather Physiotherapy professionals are available in

abundance and there are approximately 240 unregulated colleges of Physiotherapy which have already

mushroomed in our country. They are offering Graduate, Post Graduate, and also Doctoral courses due

the absence of a National Council for Physiotherapy.

The condition of Physiotherapists has worsened over period of time due to Absence of independent

regulatory mechanism as described in a study conducted in Tamil Nadu in fig. 27 , in dark contrast to

perception in developed Nation e.g. Australia, a study conducted by turner, describes the perception of

Physiotherapist(fig.1) in Australia8

It is humbly informed that the Physiotherapist’s pathetic condition is more or less the same in each state

of Union of India. In Delhi state, in year 2008, at Safdarjung Hospital, to recruit one Physiotherapist,

51 Physiotherapists have been examined. In same hospital at sports injury center, in years 2015, more

than 200 post graduate in sports injury have interviewed for recruitment of 8 physiotherapists. It is

important point out that the examination lasted for three days and most of Physiotherapists who had

already been working on contractual basis in Sports Injury center, were selected. As a matter of fact

rather than selecting Physiotherapists on the basis of merit, Physician experts at the examination

must have enjoyed the derogatory condition of Physiotherapists for all along three day. Not to mention,

the age criteria as usual has been changed to prefix the candidate. The kind of abuse, derogation,

unemployment and irregularities in recruitment are unprecedented and are the true status of

Physiotherapy in India, for all these poor status of Physiotherapy in Union of India, MOH&FW is fully

responsible at the behest of physician especially of PMR.

Even underdeveloped neighbor countries has better human resource standards9 and perception10 among

Physiotherapy profession.

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Figure: 1

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Figure 2: Physiotherapy Profession in India (Tamilnadu)

1. Poor understanding of PT role 2. Unaccepted nature of therapy 3. Poor awareness 4. Orthopedicians fear of losing

patients 5. Rural absence of physiotherapists 6. Poor affordability

Low Demand of Physiotherapy Service

1. Insufficient educational syllabuses 2. Poor acquired knowledge & low self- confidence 3. Un-prioritized continuing education 4. Unskilled and immoral teachers 5. Lack of evidence based practice

Knowledge deficit

1. Poor salary & struggling life 2. Hard work and no fruits 3. Poor employment opportunities

De-motivating rewards and worst career

opportunities

1. Profit concerned colleges 2. Fraudulent private colleges 3. Frightening strategies 4. Standard not a concern 5. Mismatch production & job

availability

Un-regulated educational Institutions

1. Unfavorable tradition of consultation

2. Denied independency 3. Doctors envy and upper hand 4. Nil regulations for authority 5. Forced misconduct

Powerless Physiotherapy Professionals

1. Worried about people perception 2. Unhappy to be known as

physiotherapists 3. Much relied on modalities

Low self-esteem of Physiotherapists

1. Fall in college admission

2. High discontinuation of profession

3. Harmful and less effective services

4. Asymmetry of information and immoral activities

5. Unhappy and frustrated professionals

Worsening Profession

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3. Jurisprudence in developed Nations and Indian states

A. American – Define physiotherapy as method of treatment / system of treatment.

AMERICAN JURISPRUDENCE, 1981 EDITION, HAS BEEN UTILIZED BY MINISTRY OF LAW

TO VET THE TERM OF PHYSIOTHERAPY11

B. Australian & NZ – The PBNZ has published the following description of the general scope of

practice for physiotherapists in Aotearoa New Zealand.12

Physiotherapy provides services to individuals and

populations to develop, maintain, restore and optimize health

and function throughout the lifespan. This includes providing

services to people compromised by ageing, injury, disease or

environmental factors. Physiotherapy identifies and maximizes

quality of life and movement potential by using the principles

of promotion, prevention, treatment/intervention, habilitation

and rehabilitation. This encompasses physical, psychological,

emotional, and social wellbeing.

Physiotherapy involves the interaction between

physiotherapists, patients/clients, other health

professionals, families/whanau, care givers, and

communities. This is a people-centered process where

needs are assessed and goals are agreed using the knowledge

and skills of physiotherapists. Physiotherapists are registered

health practitioners who are educated to practice

autonomously by applying scientific knowledge and clinical

reasoning to assess, diagnose and manage human function.

The practice of physiotherapy is not confined to clinical

practice, and encompasses all roles that a physiotherapist may

assume such as patient/client care, health management,

research, policy making, educating and consulting, wherever

there may be an issue of public health and safety.

The Physio BA has published a definition of “practice”. The following description is based on

that definition:

Physiotherapy practice is any role, whether remunerated or not, in which

the individual uses their skills and knowledge as a physiotherapist ...

practice is not restricted to the provision of direct clinical care. It also

includes using professional knowledge in a direct non-clinical

relationship with patients or clients, working in management,

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administration, education, research, advisory, regulatory or policy

development roles and any other roles that have an impact on safe,

effective delivery of health services in physiotherapy.

C. United Kingdom- Human Medicine Regulation 2012 act, allow Physiotherapist serve as

independent/ supplementary prescriber of medicine. Due to such change only Musculoskeletal

(MSK) physiotherapy practitioners at four primary practices in North West Wales have saved

nearly 700 GP appointments over three months13.

D. CANADA -Physiotherapy Definition14

Physiotherapy is a primary care, autonomous, client-focused health

profession dedicated to improving quality of life by:

Promoting optimal mobility, physical activity and overall health and

wellness;

Preventing disease, injury, and disability; Managing acute and chronic

conditions, activity limitations, and participation restrictions;

Improving and maintaining optimal functional independence and

physical performance; Rehabilitating injury and the effects of disease

or disability with therapeutic exercise programs and other interventions;

and Educating and planning maintenance and support programs to

prevent re-occurrence, re-injury or functional decline.

Physiotherapy is anchored in movement sciences and aims to enhance

or restore function of multiple body systems. The profession is committed

to health, lifestyle and quality of life. This holistic approach incorporates

a broad range of physical and physiological therapeutic interventions

and aids.

Physiotherapy services are those that are performed by physiotherapists

or any other trained individuals working under a physiotherapist’s

direction and supervision.

Primary Functions

Physiotherapists utilize diagnostic and assessment procedures and

tools in order to develop and implement preventive and therapeutic

courses of intervention. They apply a collaborative and reasoned

approach to help clients achieve their health goals, in particular

focusing on the musculoskeletal, neurological, cardiorespiratory and

multi-systems. Within these systems, physiotherapists practice in areas

that include pediatrics, geriatrics, oncology, women’s health, pain,

critical care, wound care, occupational health and sports medicine.

Physiotherapists analyze the impact of injury, disease, disorders, or

lifestyle on movement and function. Their unique contribution to health

care is to promote, restore and prolong physical independence by

enhancing a client’s functional capacity. Physiotherapists encourage

clients to assume responsibility for their health and participate in team

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approaches to health service delivery.

E. Delhi, Maharashtra & Gujarat council – describe Physiotherapy as method/system of

treatment15.

4. Description of physiotherapy:

The description i t s e l f justifies the prolong demand of independent Physiotherapy council

a) Assessment/examination method –like any other system of treatment, Physiotherapists use

scientific methods which includes, examination of joint integrity and mobility, gait and balance,

muscle performance, motor function, cardio respiratory function, pain, neuro-motor and sensory

motor development, posture, cardiovascular and work capacity, cognition and mental status,

skin condition, accessibility and environmental review.

b) Diagnosis – like any other method of treatment Physiotherapist do utilize scientific methods/ Lab

/equipment which include a process that arises from examination and evaluation and represents

the outcome of the process of clinical reasoning; may be expressed in terms of movement

dysfunction or may encompass categories of impairments, functional limitations,

abilities/disabilities, or syndromes; diagnosis is both process and a label.

The diagnostic process performed by the Physiotherapist includes integrating and evaluating

data that are obtained during the examination to describe the patient/ client condition in terms

that will guide the prognosis, the plan of care, and intervention strategies. Physiotherapists use

diagnostic labels that identify the impact of a condition on function at the level of the system

(especially the movement system) and at the level of the whole person.

There is ample evidence that the Indian university in 4-1/2 curriculum of Physiotherapy do impart

radio diagnosis orientation16. In India condition the term “diagnosis” means mechanical

examination of human body, which Physiotherapist are used to performing since long time, as

SD curve from electrical stimulation, as in form of E.M.G biofeedback and Isokinetic test in

diagnosis and prognosis. Now a day Physiotherapist in devolved Nation especially in sports

setting use real-time ultrasound to detect muscle injury which is less time consuming, cost

effective and as effective as MRI and without radiation etc.17

c) Physiotherapy Interventions

Physiotherapy interventions include, but are by no means limited to, the following broad

categories:

Education, consultation, health promotion and prevention services.

Personalized therapeutic exercise including testing and conditioning, neuro-therapeutic

approaches to improve strength, range of motion, and function.

Soft tissue and manual therapy techniques; including massage, spinal and peripheral

joint mobilization and manipulation.

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Physical, electrotherapeutic and mechanical agents; and acupuncture.

Cardio respiratory techniques including airway clearance methods.

Skin and wound care.

Management of incontinence including pelvic floor re-education.

Functional activity and tolerance testing and training.

Work and occupational re-training and return to work

planning.

Prescription, fabrication and application of assistive, adaptive, supportive and

protective devices and equipment. Environmental change, focusing on removing barriers

to function.

d) Practice Settings

Physiotherapists work in private and public settings providing client and/or population health

interventions as well as management, educational, research and consultation services.

This broad range of settings may include but is not limited to the following:

Child-development centers Community health centers

Government/ health planning agencies

Health clubs/Fitness centers

Hospices

Hospitals

Individual homes/home care Insurance companies

Nursing Homes

Long term care facilities

Occupational health centers

Outpatient/ambulatory care clinics

Physiotherapy clinics/ practices/private offices

Prisons

Public settings for health promotion Rehabilitation Centers/ Research facilities/

Seniors centers/residences Schoo ls /universities/colleges

Sporting events/field settings Sports medicine clinics Work sites/companies

e) Alternative method:

Often used to describe independent healing approaches and Techniques used in place of

conventional treatments or mainstream medicine. In developed nation Physiotherapy Servesas

alternative method treatment e.g. musculoskeletal (MSK) physiotherapy practitioners at four

primary practices in north west Wales have saved nearly 700 GP appointments over three

months.

Physiotherapist serve as first contact practitioner in Australia, NZ, Canada and United State as

describe above.

Due to absence of regulatory mechanism, the Government of India do not know that how many

Physiotherapists live in India and what type of practice are they engaged complementary

or alternative?

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Above mentioned facts give rise to following startling questions

1. If the state health secretary meeting on the recommendation Law Ministry was that much

important, I wonder why Ministry throws the Physiotherapy profession from Ministry of Health

to Ministry of Social justice. Whether sanctity of that meeting and recommendation of Law

Ministry Remain Secured?

2. If Law Ministry recommendation was that much important that it force the government to conduct

the State Health Secretary meeting in 1995. I wonder, why it was not important in 2002,

when t h e Law Ministry pointed out on the basis 20 year old literature Physiotherapist are not

Paramedical even after its acceptance by MOH&FW?

3. Whether inclusion of Physiotherapy profession curriculum in RIPs &NIPs, does not amount

misplace fund in light of above mentioned facts and condition of physio?

4. Whether our policy can be based on lost files Note and misplace fund?

5. Whether any present decision of the Ministry of Health and Family welfare with respect to the

Physiotherapy Profession and that which is inconsistent with the prior decision, “decided to have

an independent Council under the Ministry of Health and Family Welfare” with long history of

biased and vested on the behest of Physicians especially of PMR who are occupying influential

positions in the Mohfw, is not a violation of the principle of promissory of estoppels?.

6. How long will such derogatory victimization will be continued by Moh&fw at the behest of

Physician especially PMR?

Demand

Therefore, in light of the above mentioned facts, the pathetic condition of physiotherapists and in

view of continued victimization, I humbly seek your urgent intervention and special attention in this

matter and request you:-

1. To immediately formulate measures for implementing the original decision of the Ministry of

Health and Family welfare to have an Independent council for Physiotherapists as decided in

the year 1988, on the similar line of any other method of treatment being regulated in India.

2. To take appropriate action with respect to explained facts, misplaced files & fund o f

Physiotherapy, irregularities in recruitment, conflict of interest and discrimination pointed out

at different paras of this representation.

3. To ban the Physiotherapy education and practice in India, if above request not feasible

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Reference;

1. Mohfw file NO-20816/1/97-PMS Volume i, volume ii&iii 31st

report on Paramedical and

Physiotherapy report ‘Paramedical to allied health’ 2012 clinical establishment CEA, physiotherapy

centre/023

2. http://clinicalestablishments.nic.in/WriteReadData/597.pdf

3. Final report Rationalization/ review of recruitment rules and job description,

AIIMS deloitte march 2012

http://www.aiims.edu/aiims/notices/recruitment_rules/draftcopy.pdf

a. Clinical establishment act,Physiotherapy CEA, 2014,

4. http://clinicalestablishments.nic.in/WriteReadData/597.pdf

a. Report ‘Paramedical to allied health’ 2012

5. http://www.mohfw.nic.in/WriteReadData/l892s/NIAHS%20Report.pdf

a. Duty and responsibility 2007 onward of Safdarjung hospital

b. Duty and responsibilities mention in the ACR, A. Dhargave, Chief Physiotherapist, PMR

department

6. Lok Sabha unstarred question No.4442 ,

a. http://164.100.47.132/LssNew/psearch/QResult16.aspx?qref=3186.

7. http://www.phmed.umu.se/digitalAssets/104/104561_karthikeyan-kandasamy.pdf

8. http://www.sciencedirect.com/science/article/pii/S000495141460266X

9. http://www.health.gov.bt/wp-content/uploads/moh-files/National-Standard-for-\Physiotherapy-

Services-inside-page.pdf

10. http://library.crp-

bangladesh.org:8080/bitstream/handle/123456789/45/620%20Yeamtiaz%20Ali%20Sarkar.pdf?sequ

ence=1

11. American jurisprudence, 1981 edition , article 10 , 2002 and 2012 edition , article 8

12. Physiotherapy practice thresholds in Australia and Aotearoa New Zealand, 1 May 2015

13. http://www.ahpra.gov.au/Search.aspx?query=%27project%20to%20develop%20new%20threshold%

20competency%20standards%27&f.Website%7Cboard=physiotherapy%20board&f.Date%7Cd=d%

3D2015

14. http://www.csp.org.uk/news/2015/08/20/north-wales-physio-service-saves-nearly-700-gp-

appointments

15. http://www.lawsofindia.org/state/21/Delhi.html

16. http://www.physiotherapy.ca/getmedia/e3f53048-d8e0-416b-9c9d-

38277c0e6643/DoPEN(final).pdf.aspx

17. http://www.muhs.ac.in/upload/syllabus/BPTH_Syllabus_050712_17082012_1508.pdf

18. http://www.ncbi.nlm.nih.gov/pmc/articles/PMC3495579/

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Annexure -1

Sl.

No

Existing Clauses Change requested Reasons

1. Title: THE ALLIED AND

HEALTHCARE

PROFESSIONAL’S

CENTRAL COUNCIL BILL 2015

Title: “THE HEALTH

PROFESSIONS COUNCIL

OF

INDIA”

The title should reflect the

professions and not

professionals and also the word

‘India’ needs to reflect in the

title as it does in already

existing

Professional councils. Allied

should deleted , as it is

derogatory in nature,

government must need to

have bigger heart

while dealing weaker

section of cadre and

service, who have

hardly use to have any say in

government. Such terms are

obscure and not use any part of

world now a day

2 Chapter I – Definition- Clause

2 (1) (a)

Allied and Healthcare

Professional” means such

professionals who are involved

with the delivery of health

related services, with expertise in

therapeutic, diagnostic, curative,

preventive and rehabilitative

interventions, and as prescribed

under the Rules by the Central

Government;

Chapter I – Definition- Clause

2 (1) (a)

This clause gives reference to rules

prescribed by Central Government.

It is

It is suggested that the mentioned

rules by the Central Government

in this regard (if any) needs to give

as annexure

All the terms and

prescribed rule must

be define afresh in words

– allied (if at all ),

health , therapeutic,

diagnostic, curative,

preventive, rehabilitative

interventions ,

profession mention in the

schedule and any rule already

adopted for them

by government

3 Clause 3(2)(j,l,m,n)

(j) Two representative (ex-

Clause 3(2)(j,l,m,n) This will ensure that

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officio) from existing

Statutory State Allied and

healthcare (or paramedical) council

to be nominated by the Central

Government on a two year rotation

basis. Provided that an appointment

under this clause shall be made on

the recommendation of the

Government of the State, or as the

case may be, the Union Territory

concerned.

(l) One third members from total

categories as prescribed under the

rules by the Central Government at

any given point on biennial rotation

to be elected from amongst

themselves in such a manner that

they represent such organizations

which can represent the interest of

allied and health care professional

cadres, as the case may be.

Provided that each of the categories

to be represented at least once (for

period of two years) in the duration

of six years and that in case of

constitution of the Council for the

first time after the commencement

of this Act, the members of this

category shall be nominated by the

State Government till the

assumption of office by the elected

members.

(m) One representative to be

appointed by Central Government

from any one of the private

sector/charitable institutes of the

excellence on allied and healthcare

on

It is suggested to ensure

That the nominated members,

under various categories listed

above in Clause 3(2) (j,l,m,n) , are

among those who are eligible to be

registered in the registry as

professional under one of the

profession as per schedule 1.

the eligible

Professionals under each

category are in the

overarching committee.

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annual rotation.

Provided that the nomination under

this clause shall be made on

recommendation of the Central

Council.

(n) Two members to be nominated

by the Central Government from

amongst the eminent practitioners in

allied and healthcare streams on

rotation every two years.

4 Chapter II – ‘Constitution of

the Central Council’-Clause 3

(2) (l)

One third members from total

categories as prescribed under the

rules by the Central Government at

any given point on biennial rotation

to be elected from amongst

themselves in such a manner that

they represent such organizations

which can represent the interest of

allied and health care professional

cadres, as the case may be.

Provided that each of the categories

to be represented atleast once (for

period of two years) in the duration

of six years and that in case of

constitution of the Council for the

first time after the commencement

of this Act, the members of this

category shall be nominated by the

State Government till the

assumption of office by the elected

members.

It is suggested that this clause may

be revised to provide fair

representation (based on the

existing professional practitioners

of the each of the profession) to all

the profession listed in schedule 1.

The member on the committee

should have a complete tenure of

three years instead of rotation of

two years.

The number of practicing

professionals represent the

community that of

professionals in active practice.

Hence the deciding factor for

numbers should be based on the

available in the registry.

For better implementation of

provisions and carryover of

decisions taken..

5 Chapter II – Clause 7 (1) states

‘The Central Council

may, without prejudice to the

provisions of sub-section (2), by a

majority of its total membership

and a majority of not less than two-

thirds of

its members present and

voting, at any time recommend

removal of a member of the Council

to the Central Government.’

This clause should be deleted.

Since majority in

constitute comes from

government officials a

dissenting professional

representative face constant

threat of

removal and shall not

exercises his free judgment.

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6 Chapter II – Clause 8 (2) (vi)

(1) The Central Council shall, as soon

as may be, constitute from among its

members an Executive Committee.

vi. Five members to be nominated

by Central Council from amongst

itself, such that two members

represent medical professional from

hospitals specified in sub section 2

(k) of section 3 and three members

represent the allied and healthcare

professionals from categories

specified in sub section 2(l) of

section 3 at any given time.

Chapter II – Clause 8 (2) (vi)

It is suggested that this clause

may also be revised to provide

fair representation to all the

profession listed the schedule 1

The members are among those

who are eligible to be

registered as professional

under one of the profession

as per schedule 1.

7 Chapter II – Clause 11 (1)

Meetings of the Central

Council -

(1) The Central Council shall meet

at such time and place, and shall

observe such Rules of procedure in

regard to the transaction of business

at its meetings, including the

quorum at such meetings, as may be

determined by the prescribed Rules.

Chapter II – Clause 11 (1)

Meetings of the Central Council

It is suggested that the minimum

one meeting in a year must be

added to this clause.

The clause will read as-

1) The Central Council shall meet at

least once a year at such time and

place, and shall observe such Rules of

procedure in regard to the transaction

of business at its meetings, including

the quorum at such meetings, as may

be determined by the prescribed

Rules.

This is done to define the

clause better.

8 Statement of Objects &

Reasons (Page 12) 2. Maintenance

of proper standards in the training

and education of allied and

healthcare professionals is

considered essential as these

personnel play a crucial role in

healthcare delivery. With a view to

regulating these professions, it is

considered necessary to set up

Council on the lines already existing

for pharmacy, nursing, etc. To begin

with, it is proposed to set up an

overarching Council for all the

categories prescribed under the

Rules by the Central Government

with individual committees for each

professional. The Council will be

responsible, inter alia, for

maintenance of uniform standards

of education in the respective

disciplines and registration as well

licensing of qualified personnel for

practicing the professions.

Statement of Objects &

Reasons (Page 12) 2

It is suggested that majority of the

members of this committee must be

among those who are eligible to be

registered as professional under

their respective registry.

The roles & responsibility of this

committee needs to be defined. The

committee must be responsible for

framing the standards of education,

practice and other related guidelines

The subject experts must be

responsible for framing

guidelines for the profession to

be submitted to the

overarching committee.

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9. Chapter II – Clause 11 (1)

Meetings of the Central Council -

(1) The Central Council shall meet

at such time and place, and shall

observe such Rules of procedure in

regard to the transaction of

business at its meetings, including

the quorum at such meetings, as

may be determined by the

prescribed Rules.

Chapter II – Clause 11 (1)

Meetings of the Central Council -

It is suggested that the minimum

one meeting in a year must be

addedto this clause.

The clause will read as-

1) The Central Council shall

meet at least once a year at such

time and place, and shall observe

such Rules of procedure in regard

to the transaction of business at its

meetings, including the quorum at

such meetings, as may be

determined by the prescribed

Rules.

This is done to define the clause

better.

10. Statement of Objects &

Reasons (Page 12) 2. Maintenance

of proper standards in the training

and education of allied and

healthcare professionals is

considered essential as these

personnel play a crucial role in

healthcare delivery. With a view to

regulating these professions, it is

considered necessary to set up

Council on the lines already

existing for pharmacy, nursing,

etc.To begin with, it is proposed to

set up an overarching Council for

all the categories prescribed under

the Rules by the Central

Government with individual

committees for each

professional. The Council will be

responsible, inter alia, for

maintenance of uniform standards

of education in the respective

disciplines and registration as well

licensing of qualified personnel for

practicing the professions.

Statement of Objects &

Reasons(Page 12) 2

It is suggested that majority of the

members of this committee must be

among those who are eligible to be

registered as professional under

their respective registry.

The roles & responsibility of this

committee needs to be defined.The

committee must be responsible for

framing the standards of education,

practice and other related

guidelines

The subject experts must be

responsible for framing

guidelines for the profession to

be submitted to the overarching

committee.

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11.

Schedule 1- There are five

professions listed in this schedule

under Healthcare Professions

(Group A).

It is suggested to create a sub

category in Healthcare Professions.

A (i)

Physiotherapy and Occupational

therapy.

A (ii)

Optometry, Nutrition Science and

Physician Associate and assistant.

The five have different durations

as courses with different level of

responsibility and these needs to

be reflected within this group. It

is suggested to create a sub

category in Healthcare

Professions.

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Some more references relevant to physiotherapy professional autonomy

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Finally, we would like to request to consider the

recommendations made in 31st Departmental Related

Parliamentary Standing Committee on Physiotherapy &

Paramedical Council Bill 2007, submitted in October 2008.

This committee made recommendations after a great

exercise at the national level; therefore we must consider

their recommendations for better growth.

End of Document

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