Ref: TN IPS/HGS/26-27/65

04.08.2026

From

To

The President,

Indian Psychiatric Society – Tamil Nadu Chapter, Tamil Nadu.

The Honourable Health Minister, Department of Health & Family Welfare, Government of Tamil Nadu,

Fort St. George Secretariat, Chennai – 600009.

Subject: application for Seeking NCAHP stream Psychology Courses [equivalent to RCI clinical psychology as per Mental Health Care Act, section 2(g)] in Government Medical Colleges in the Interest of Public Mental Healthcare Delivery by amending the impugned G.O. which is pending with govt informed – reg.

Ref:

1. G.O.(Ms) No:58, Health and Family welfare (PME) Department, dated 20- 02-2026 about annual intake of 18 seats of MA clinical psychology at IMH for academic year 2026-27

2. G.O.(Ms) No:78, Health and Family welfare (PME) Department, dated 4-03- 2026 about annual intake of 20 seats of BSc(hons) clinical psychology at IMH for academic year 2026-27

3. Letter No: e2828/PME-2/2026-1, health and family welfare department, dated 13.03.2026, from office of deputy secretary to DME

Respected sir,

We would like to bring to your kind attention that state autonomy issues missed out in the impugned G.O. (references-1,2, &3) were currently being discussed with Tamil Nadu Government and the proceedings on the above mentioned G.O. may be carried out after clarifying the state’s role in regulating the psychology professionals with appropriate experts.

Government Orders mentioned in the references have been issued by the Health and Family Welfare Department during the previous government regarding the commencement of RCI stream Clinical Psychology courses at the Institute of Mental Health (IMH), Kilpauk, Chennai, and other Government Medical Colleges across the State.

There were lots of issues not considered in that G.O. which was represented with the previous health minister but the govt tenure got ended before amending the G.O.

The issues brought to the attention of health secretary and health minister were the following:

1. Lack regulatory stake by state government in organising care under Rehabilitation Council of India (RCI) stream psychologist as there is no state council.

2. Health Ministries at state government and union government level do not have any regulatory stake on faculties, thus care level and curriculum which hinders the feedback system for refining the mental health care delivery.

3. Mental Health Care Act 2017, section 2(g) clearly emphasized the quality of training and academic requirements and accepted all psychology streams as CLINICAL PSYCHOLOGY, if two years intense supervised clinical training is provided after UG. However, the term ‘clinical psychology’ is familiar nomenclature with RCI stream and many are believing mental health care can be supported by RCI regulated psychologists alone.

4. RCI stream psychology courses fail to integrate the existing infrastructure and manpower available within UGC regulated colleges. This would lead to limited manpower supply to address the huge mental health care Gap indicated by National Mental health survey.

5. There need to be a gradient in education empowering the budding psychology professionals to do task at different levels of competency.

6. The crux of the problem is lack of alignment of RCI with Medical college (NMC) frame work and this leads to RCI not accepting regulatory oversight by psychiatrists in Health department. Moreover, they ask for starting separate OPD which would cause duplication of services and may lead to chaos.

These views were represented with the Hon’ble Minister for Health and Family Welfare. The Chennai Psychiatric Society (CPS) and the Tamil Nadu State Branch of the Indian Psychiatric Society (TN-IPS) have already brought this matter to the attention to your office on 23-07-2027. TNGDA has also informed the government about the structural anomaly that may be inadvertently created on 4th March 2026.

We are very concerned about the structural issues that would arise.

It is our understanding that there is an attempt to urgently introduce Clinical Psychology courses under the Rehabilitation Council of India (RCI) framework as per the implunged G.O mentioned in the references cited above. While the RCI plays an important role in regulating rehabilitation services for persons with other disabilities and mental illness, its mandate is limited to rehabilitation-related functions. The RCI operates under the Union Government and is not administratively accountable to the State Health Ministry. Consequently, creating separate and autonomous spaces for RCI- regulated professionals within Government Medical Colleges may inadvertently fragment mental healthcare delivery and weaken institutional accountability. Such Psychologists also try to ring-fence themselves and their roles, as the sole providers of mental health services, without any administrative or clinical supervision.

Mental healthcare is best delivered through an integrated, multidisciplinary approach involving psychiatrists, psychologists, psychiatric social workers, psychiatric nurses, and Psychiatric Support Workers. If RCI-regulated Clinical Psychology services are institutionally segregated, accountability to patients, mental healthcare teams, the Directorate of Medical Education (DME), the District Mental Health Programme (DMHP), and ultimately the State

Government may become diluted. In sensitive administrative and service- related matters, professionals may understandably be compelled to adhere primarily to RCI regulations, potentially limiting the State’s ability to effectively deploy and regulate services in accordance with public health needs.

Importantly, there exists a viable and more appropriate alternative through Applied Psychology programmes such as B.Psy., and M.Psy aligned with the National Commission for Allied and Healthcare Professions framework (NCAHP), master degree is recognised by MHCA 2017 and these can be registered in State Mental Health Authority. Graduates of these programmes can be trained, regulated, and deployed directly under the State Health system. The NCAHP framework is better aligned with the administrative and service requirements of Government Medical Colleges and enables professionals to function seamlessly within the existing public healthcare infrastructure.

Hence, we request you to consult with appropriate experts of Tamil Nadu before proceeding on the above-mentioned impugned G.O.s;

Yours sincerely,

President

Dr J Babu Balasingh

IPS TN Chapter

Gen. Secretary Dr N Arunkumar

IPS TN Chapter

Clarifying table on various psychology streams and governing laws and suggestions to align them with medical college framework is attached.

Legal Basis

RCI Act 1992

NCAHP Act 2021

UGC Act 1956

Comparison: Existing RCI vs NCAHP vs UGC in UG Psychology Course Norms

Aspect

RCI (Rehabilitation Council of India)

NCAHP (National Commission for Allied & Health care Professions)

UGC

(University Grants Commission)

Primary Mandate

Rehabilitation & disability services

Regulation of Allied Healthcare Professions

Regulation of General Higher Education

Core Focus Area

Persons with disabilities (RPwD Act)

Allied Healthcare Professionals including Psychology

Curriculum & Academic Standards across Disciplines in Arts & Science

Role in Psychology

Traditionally regulates clinical psychologists (via rehab framework) when separate council for clinical psychology was NOT there

Regulates Psychology as allied healthcare profession (except clinical psychologist under RCI)

Regulates Academic Psychology degrees

New Curriculum Introduced

B.Sc. Clinical Psychology (Hons.)

B. Psy (Bachelor of Psychology)

No Single Curriculum;

Sets Standards for BA & BA (Hons) in Psychology

Proposed UG Title

Clinical Assistant (Clinical Psychology)

Behavioural Health Counsellor

No professional title

Legal Recognition of Title

Not clearly recognised in MHCA/NCAHP

Recognised under NCAHP framework

Not applicable

Scope of Practice

Unclear; may not qualify as “mental health professional” under MHCA 2017

Unclear; Intended for healthcare roles; may not qualify as “mental health professional” under MHCA 2017

Academic only (no clinical scope)

Entry Qualification

Science stream in 10+2 (restrictive) + Entrance Test

Science or Humanities at 10+2 / Entrance Test (Restrictive)

Science or Humanities No Entrance Test

Approach to Training

Rehabilitation- oriented

Competency- based, Healthcare- oriented

Academic / theoretical focus

Overlap Issues

Exceeds mandate into General Psychology & Mental Health

Overlaps with RCI in Clinical Domain

Conflicts with both in curriculum regulation

Major Concern

Overreach; Unclear Legal Standing; Lack of state oversight

Implementation gaps; Ambiguity of Course purpose; Lack of approved nomenclature

Lack of intervention /clarity

Strength

Established licensing pathway (clinical psychology)

Structured competency-Based framework; Scope to be placed within existing health care institutions

Wide reach with high human resources for teaching and broad academic governance

Key Limitation

Narrow disability focus

Nascent; Regulatory Ambiguity

Academic focus & ot aligned with professional regulation

Suggestions Proposed

Aspect

RCI (Rehabilitation Council of India)

NCAHP (National Commission for Allied & Health care Professions)

UGC

(University Grants Commission)

New Curriculum to be Introduced

MA in Rehabilitation Psychology

MA in Clinical Psychology

BA in Psychology & BA (Hons) in Psychology MA in Psychology (Specialisation)

Entry Qualification

Proposed UG Title

Proposed PG Title

BA (Hons) in Psychology

NA

Rehabilitation Psychologist

BA (Hons) in Psychology

NA

Clinical Psychologist

10+2 in Science or Humanities Stream

No Professional Title Academic Psychologist

Acceptance of Nomenclature and Title

Accepted

Accepted ISCO 2634

Accepted ISCO 2634

Conformity to International Standards

Yes

UG stream placed in general psychology – academic setting & PG in applied setting

Yes

UG training placed in general psychology – academic setting & PG in Clinical setting

Yes

Years of Training

4+2

4+2

3 for BA; 3+1forBA (Hons)

4 + 2 for MA (Specialisation)

Doctoral Training

Available Available Available

Legal Recognition of Title

Recognised in RCI 1992 & MHCA 2017

Recognised under NCAHP framework & MHCA 2017

Not applicable

Scope of Practice

Clear; Will qualify as “rehabilitation professional” under RCI Act 1992

Clear; Will qualify as “mental health professional” under MHCA 2017; Intended for healthcare roles

Academic and Other fields like education, industry etc., (no clinical scope)

Approach to Training

Rehabilitation -oriented

Competency- based, Healthcare- oriented

Academic / Theoretical focus for BA and Additional Clinical focus and exposure for BA(Hons)

Overlap Issues

No Overlap; Restricted to mandate of RCI Act

No Overlap with either RCI or UGC

No Overlap; Common UG training for all fields of Psychology

Major Concern

Lack of state oversight; limited scope for regulation and accountability

Nascent; yet to be rolled out fully

Uniformity of training and access to clinical exposure

Strength

Familiarity; Established licensing Pathway recognised by MHCA

Competency- Based Framework; Scope to be placed within existing health care institutions; Scope for regulation

Wide reach with high human resources for teaching and broad academic governance

Proposal to ensure continuity

RCI to allow registration of individuals with existing Clinical Psychology qualifications for a period of 5 years until functioning of State Allied Health Councils in all States

NCAHP to allow the registration of those individuals with qualification in clinical psychology & who are registered with RCI and permit dual membership in both registers to bring them under the ambit of the NCAHP Act and ensure continuity & accountability

NA

Proposed Schema of academic pathway in psychology course for better alignment of regulatory systems (NCAHP, RCI and UGC).

The strong theoretical aspects on fundamentals are gained in regular academic streams of psychology during first 3 years, then one-year training in the preferred specialization. Those selected to do specialization in health sector can select either in Clinical Psychology or in Rehabilitation Psychology.

What is proposed is, Previously held….

3 years UG in UGC college +2 years PG in UGC +2 years MPhil. in health /rehab institution may be switched to….

3 years UG in UGC college +1 year (internship in an accredited Health institution).

+2 years (specialization the concerned institution – health sector/rehabilitation sector) as per National Education Policy.

BA Psychology in UGC regular stream for 3 years

(As vast manpower & infrastructure is already available)

+2 completed with science or humanity

One-year training as internship in accredited educational Health Institution (or other institution as per specialization preferred)

Allowed to do limited practice under supervision (with registration in NCAHP)

Regular academic stream in MA (education psychology, industrial psychology etc.)

MA (Clinical psychology) – 2 years in Medical College

(registered in NCAHP)

MA (Rehabilitation psychology) – 2 years in Rehabilitation Institution (registered in RCI)