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.

Feedback and
Suggestions
Regards to Physiotherapy Council

Physiotherapist

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.

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

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 | Page

1989
bill.
1994

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

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 dont 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
2 | Page

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 Physiotherapists 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 | Page

Even underdeveloped neighbor countries has better human resource standards 9 and perception10 among
Physiotherapy profession.
Figure: 1

4 | Page

Figure 2: Physiotherapy Profession in India (Tamilnadu)

Un-regulated educational
Institutions
1. Profit concerned colleges
2. Fraudulent private colleges
3. Frightening strategies
4. Standard not a concern
5. Mismatch production & job
availability

Low self-esteem of
Powerless Physiotherapy
Physiotherapists
Professionals
1. Unfavorable tradition1. of
Worried about people
consultation
perception
2. Denied independency 2. Unhappy to be known as
3. Doctors envy and upperphysiotherapists
hand
3. Much relied on modalities
4. Nil regulations for authority
5. Forced misconduct

Low Demand of
Physiotherapy Service
1. Poor understanding of PT
role
2. Unaccepted nature of
therapy
3. Poor awareness
4. Orthopedicians fear of losing
patients
5. Rural absence of

Knowledge deficit
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

De-motivating rewards and

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

Worsening Profession
1. Fall in college admission
2. High
discontinuation
of
profession
3. Harmful and less efective services
4. Asymmetry
of
information
and
immoral activities

5 | Page

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, 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.
14

D. CANADA -Physiotherapy Definition

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
physiotherapists 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, womens 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 clients functional capacity. Physiotherapists
encourage clients to assume responsibility for their health and
participate in team approaches to health service delivery.
E. Delhi, Maharashtra & Gujarat council
.
treatment15

describe

Physiotherapy

4. Description of physiotherapy:

as

method/system of

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, neurotherapeutic 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 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 S c h o o 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?

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

Reference;
st
1. Mohfw file NO-20816/1/97-PMS Volume i, volume ii&iii 31
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-\PhysiotherapyServices-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 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-gpappointments
15. http://www.lawsofindia.org/state/21/Delhi.html
16. http://www.physiotherapy.ca/getmedia/e3f53048-d8e0-416b-9c9d38277c0e6643/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/

Annexure -1
Sl.

Existing Clauses

Change requested

Reasons

No
1.

Title:
THE
ALLIED
AND
HEALTHCARE
PROFESSIONALS
CENTRAL COUNCIL BILL 2015

Title:
THE
PROFESSIONS
OF
INDIA

Chapter I Definition- Clause

2 (1) (a)
Allied and Healthcare
Professional
means
such
professionals who are involved
with the delivery of health

Chapter I Definition- Clause

2 (1) (a)

related services, with expertise in

therapeutic, diagnostic, curative,
preventive and rehabilitative
interventions, and as prescribed
under the Rules by the Central
Government;
3

Clause 3(2)(j,l,m,n)
(j) Two representative (ex-

HEALTH
COUNCIL

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

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

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

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
This will ensure that

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.

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.
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.

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.

This clause should be deleted.

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..

Since
majority
in
constitute
comes
from
government
officials
a
dissenting
professional
representative face constant
threat
of
removal and shall not
exercises his free judgment.

Chapter II Clause 8 (2) (vi)

Chapter II Clause 8 (2) (vi)

(1) The Central Council shall, as

soon as may be, constitute from
among its members an Executive
Committee.

It is suggested that this clause

may also be revised to provide
fair representation to all the
profession listed the schedule 1

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 11 (1)
Meetings of the Central
Council -

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.

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

The members are among

those who are eligible to be
registered as professional
under one of the profession
as per schedule 1.

This is done to define the

clause better.

It is suggested that the minimum

one meeting in a year must be
added to this clause.
The clause will read as1) 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.
The subject experts must be
Statement of Objects &
responsible
for
framing
Reasons (Page 12) 2
guidelines for the profession
to be submitted to the
It is suggested that majority of the
overarching committee.
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

9.

10.

Chapter II Clause 11 (1)

Chapter II Clause 11 (1)

Meetings of the Central Council -

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.

It is suggested that the minimum

one meeting in a year must be
addedto this clause.
The clause will read as1) 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.

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

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.

This is done to define the clause

better.

& The subject experts must be

responsible
for
framing
guidelines for the profession to
It is suggested that majority of the be submitted to the overarching
members of this committee must committee.
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

11.
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.

Some more references relevant to physiotherapy professional autonomy

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