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.

Date 22/10/2015

To,The SecretaryMinistry 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

1 | P a g e

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 legislated1997 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 Physiotherapy1998 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 Lapsed2012 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

2 | P a g e

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

3 | P a g e

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

Figure: 1

4 | P a g e

Figure 2: Physiotherapy Profession in India (Tamilnadu)

5 | P a g e

1. Poor understanding of PT role2. Unaccepted nature of therapy3. Poor awareness4. Orthopedicians fear of losing

patients 5. Rural absence of physiotherapists6. Poor affordability

Low Demand of Physiotherapy

1. Insufficient educational syllabuses2. Poor acquired knowledge & low self- confidence3. Un-prioritized continuing education4. Unskilled and immoral teachers5. Lack of evidence based practice

Knowledge deficit

1. Poor salary & struggling life2. Hard work and no fruits3. Poor employment opportunities

De-motivating rewards and worst career opportunities

1. Profit concerned colleges2. Fraudulent private colleges3. Frightening strategies4. Standard not a concern5. Mismatch production & job

availability

Un-regulated educational Institutions

1. Unfavorable tradition of consultation

2. Denied independency3. Doctors envy and upper hand4. Nil regulations for authority5. Forced misconduct

Powerless Physiotherapy Professionals

1. Worried about people perce2. Unhappy to be known as

physiotherapists3. Much relied on modalities

Low self-esteem of Physiothera

1. Fall in college admission

2. High discontinuation of profession3. Harmful and less effective services4. Asymmetry of information and immoral activities

Worsening Profession

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

6 | P a g e

management, 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 FunctionsPhysiotherapists 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

7 | P a g e

encourage clients to assume responsibility for their health and participate in team 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 councila) 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 InterventionsPhysiotherapy interventions include, but are by no means limited to, the following broad categories:

Education, consultation, health promotion and prevention services.

8 | P a g e

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.

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 SettingsPhysiotherapists 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 Schools /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.

9 | P a g e

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?

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

10 | P a g e

out at different paras of this representation.

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

11 | P a g e

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’ 20125. 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. b t/ w p-co n ten t /upload s / m o h- f ile s / N ati o nal- St andar d - f or- \Physiotherapy-Services-inside-page.pdf

10. http://library.crp-bangladesh.org:8080/bitstream/handle/123456789/45/620%20Yeamtiaz%20Ali%20Sarkar.pdf?sequence=1

11. American jurisprudence, 1981 edition , article 10 , 2002 and 2012 edition , article 812. Physiotherapy practice thresholds in Australia and Aotearoa New Zealand, 1 May 201513. 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/

12 | P a g e

Annexure -1

Sl.

No

Existing Clauses Change requested Reasons

1. Title: THE ALLIED AND HEALTHCARE PROFESSIONAL’SCENTRAL COUNCIL BILL 2015

Title: “THE HEALTH PROFESSIONS COUNCIL OFINDIA”

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 existingProfessional 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 HealthcareProfessional” 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 mustbe 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

13 | P a g e

officio) from existingStatutory 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 ensureThat 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 eligibleProfessionals under each category are in the overarching committee.

14 | P a g e

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 ofthe 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 Councilmay, 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 ofits members present andvoting, at any time recommend removal of a member of the Council to the Central Government.’

This clause should be deleted. Since majority inconstitute comes from government officials a dissenting professional representative face constant threat ofremoval and shall notexercises his free judgment.

15 | P a g e

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

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.

16 | P a g e

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.

17 | P a g e

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.

18 | P a g e

Some more references relevant to physiotherapy professional autonomy

19 | P a g e

20 | P a g e

21 | P a g e

22 | P a g e

23 | P a g e

24 | P a g e

25 | P a g e

26 | P a g e

27 | P a g e

28 | P a g e

29 | P a g e

  

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

30 | P a g e