13/10/2025
Date: 13/10/2025
To
The Secretary National Commission for
Allied and Healthcare Professionals (NCAHP)
2nd Floor, Academic Block NIHFW Campus,
Munirka New Delhi – 110067
Subject: Representation Regarding the Draft “Registration of Allied and Healthcare Professionals Regulations – 2025”
Respected Sir/Madam,
I, Appireddy gari Damodhara Reddy, a self-employed Medical Laboratory Technician (DMLT) from Anantapur District, Andhra Pradesh, respectfully submit this representation regarding the draft “Registration of Allied and Healthcare Professionals Regulations – 2025” issued by the National Commission for Allied and Healthcare Professionals (NCAHP) for public feedback. I wish to bring to your attention several critical concerns that directly impact the professional recognition, registration, and livelihood of DMLTs and other allied health professionals.
Concerns Regarding Signing Authority for Basic Category Laboratories
I express my deep disappointment that, despite the 15th Meeting of the National Clinical Establishment Council held on 30.10.2024, attended by Mr. Sween Samuel, Sr. Consultant, NCAHP, which recommended that the signing authority for basic composite laboratories be kept in abeyance until MLT-specific regulations are formulated, this issue has repeatedly remained unaddressed. The prolonged inaction jeopardizes the livelihood of approximately 1 lakh self-employed MLT professionals who have independently conducted 50 routine laboratory tests in basic category laboratories since independence.
The uncertainty around signing authority threatens not only the legal ability to practice but also the financial stability and professional autonomy of these diploma holders. I respectfully request NCAHP to take a timely decision ensuring the livelihood of these professionals and to consider retrospective recognition for existing diploma holders where reservations exist.
Exclusion of DMLT from the Approved Nomenclature
It is concerning that the Diploma in Medical Laboratory Technology (DMLT) is absent from the Approved Nomenclature attached to the Draft Regulations, whereas other diplomas such as OT, Radiography, Optics, and Physiotherapy have been recognized. Nearly 90% of MLT categories are excluded, despite being essential for delivering laboratory services across India.
Exclusion of DMLT could prevent professionals holding this qualification from registering under NCAHP, creating legal ambiguities regarding their practice, and affecting those who have obtained eligibility through lateral entry programs. Inclusion of DMLT is essential to safeguard professional recognition, ensure legal rights, and protect career and livelihood.
Professional Contributions and Importance of Self-Employed DMLTs
The contributions of self-employed DMLTs during health crises, including COVID-19, have been invaluable. These professionals have ensured timely and reliable laboratory services, often in rural and underserved areas. The Hon’ble Prime Minister Shri Narendra Modi has consistently encouraged self-employment and entrepreneurship, yet the current draft appears to favor corporate interests, potentially overlooking the role of self-employed DMLTs. Recognizing DMLTs formally will validate their contributions, protect livelihoods, and reinforce self-employment initiatives.
Stakeholder Engagement and Inclusivity
The process of framing these regulations must ensure broader stakeholder engagement, particularly involving practicing DMLT professionals and representatives of self-employed laboratory technicians. Decisions that affect the profession and livelihoods of these healthcare workers should be inclusive, consultative, and reflective of the realities of frontline practitioners. I urge NCAHP to demonstrate genuine inclusivity in decision-making to maintain the credibility and fairness of the regulatory framework.
Need for Telugu / Regional Language Version
The draft is currently available only in English, creating barriers for many professionals, especially in rural areas, small laboratory owners, and older practitioners. To uphold fair participation and natural justice, it is essential that NCAHP release a Telugu or regional language version of the draft regulations. This will ensure that all allied health professionals can understand, review, and submit meaningful feedback.
Extension of Feedback Submission Deadline
The current deadline of 25.10.2025 may not provide sufficient time for self-employed or rural professionals to thoroughly review the draft and provide feedback. Extending the deadline by at least one month will facilitate inclusive consultation, broad participation, and considered feedback from all stakeholders.
Alignment with National Health Objectives
Inclusion and recognition of DMLT professionals align with national health objectives, strengthen healthcare delivery, promote self-employment, and enhance accessibility. Timely inclusion will ensure that self-employed laboratory professionals continue to contribute effectively to India’s healthcare ecosystem, while protecting their professional dignity and livelihood.
Conclusion and Request
In view of the above, I respectfully request NCAHP to: 1. Provide clear signing authority for diploma holders in basic category laboratories, including retrospective recognition where necessary. 2. Explicitly include Diploma in Medical Laboratory Technology (DMLT) in the list of recognized allied health professions. 3. Release a Telugu / regional language version of the draft regulations to ensure informed participation. 4. Extend the feedback submission deadline by at least one month to allow for comprehensive stakeholder consultation.
Implementing these measures will uphold the legal and administrative principles enshrined in the Allied and Healthcare Professions Act, 2021, and ensure that the professional rights, recognition, and livelihood of DMLTs and allied health professionals are fully protected.
Sincerely,
Appireddy Damodhara Reddy
Medical Laboratory Technician (DMLT)
Mobile: 9291253141
Anantapur District,
Andhra Pradesh
Submission Email: ncahpregulationspublicopinion@gmail.com
