26/03/2019
As you must be aware that RCI has invited recommendations and suggestions on RCI Act because it's drafting a new bill to amend RCI Act,
its a golden chance for prosthetist and Orthotists to fight for their rights for better salary, and using Dr as prefix, because as per WHO Prosthetics Orthotics is a treatment and P & O is a clinician who treats, further explaining
As per WHO “Prosthetist & Orthotist are healthcare professionals with the overall responsibility of Prosthetics & Orthotics treatment, who can supervise and mentor the practice of other personnel. They are clinicians trained to assess the needs of the user, prescribe treatment, determine the precise technical specifications of prosthesis and Orthosis, take measurements and image of body segments, prepare model of the evaluation, fit devices and evaluate treatment outcome.”
Here I am sending few suggestions to OPAI which should be kept in front of RCI and also I am sending suggestions for RCI ammendment which can be put forward by OPAI.
Recommendations for RCI Act amendment (in Purview of Prosthetics & Orthotics) :-
1. Defining Prosthetics & Orthotics as the science and art of healing people by the use of prosthesis and Orthosis (As per WHO)
2. Defining Prosthetist & Orthotist as the healthcare professional who has completed an approved course of education and training (at least bachelor of Prosthetics & Orthotics ) and is authorized by a national authority to treat people (person with disability ) by the use of prosthesis & Orthosis
As well as using the same definition as per WHO “Prosthetist & Orthotist are healthcare professionals with overall responsibly of Prosthetics & Orthotics treatment, who can supervise and mentor the practice of other personnel. They are clinicians trained to assess the needs of the user, prescribe treatment, determine the precise technical specifications of prosthesis and Orthosis, take measurements and image of body segments, prepare model of the evaluation, fit devices and evaluate treatment outcome.”
3. Defining Prosthetic Orthotic Clinic as per WHO recommendations
4. Not referring Prosthetist & Orthotist as Prosthetic Orthotic Technician because both are different jobs with different educational and training background
5. Immediately looking into the nomenclature of all existing posts and wherever minimum qualification required is Bachelor of Prosthetics & Orthotics the pay scale must be as per clinical services (latest pay scale and global trends) and the nomenclature must be Prosthetist & Orthotist or Prosthetic & Orthotic Specialist/Clinician
6. To give the prefix Dr. to Prosthetist & Orthotist because of being a clinician who is directly treating the patients
7. To make ensure that Prosthetic Orthotic services become an integral part of rehabilitation clinics/centers and of healthcare setups
8. To make sure that Prosthetic Orthotic technicians are always under the supervision of Prosthetist and Orthotist and that technicians are always non-clinical personnel.
9. To make sure that as per CRPD and WHO recommendations each and every private and the public hospital has Prosthetic Orthotic Clinic/Rehab Centre with Prosthetist Orthotist in it.
10. To make sure that Prosthetic Orthotic services come under Ministry of Health and Universal Health Coverage.
11. To make sure that Prosthetic Orthotic clinic/center is not called as shop/workshop/limb fitting centers etc
12. To make sure that Prosthesis & Orthosis are not called Prosthetic Orthotic products or equipment or appliance.
13. To make sure that all 16 assistive and mobility aids under WHO top 50 priority list are available in each district and professionals remain available to prescribe and fir them.
14. To make sure that people during Bachelor higher courses from any recognized university abroad (by ISPO or WHO) are given RCI registration
15. To make sure that course is being upgraded time to time and enough learning skills in terms of both theory and practice are learnt by students , WHO emphasis on preventive and promotive care with focus on community, therefore, subjects like Preventive and Social Medicine must be introduced, also before amputation surgery students must learn basics of general surgery, ethics and law should also be included store management should be changed to rehabilitation setup management .
Apart from this radio diagnosis is very important these days so students must learn about basics of radiology and x-ray MRI findings.
Also, the internship period should be extended from 6 months to 1 year as per BDS course. (If we need Dr in name these subjects are must to be introduced )
16. To make sure that before prescribing any mobility aids and before every amputation and corrective surgery of any deformity a Prosthetist Orthotist is consulted (as per WHO recommendations )
17. To make sure that Prosthetist & Orthotist are being trained from time to time for up gradation of technology
18. To ensure a central and state warehouse for availability of materials used in Prosthetics Orthotics services
19. To make sure that the person with disability is made aware about latest Prosthetic Orthotic technology by means of Information Education Communication.
To make sure that patient is given freedom of choice for service provider and type of prosthesis based on best possible suit as per Prescription by Prosthetist & Orthotist.
20. To make sure that there remain strict vigilance and severe penalty and punishment for unauthorized people handling any case of Prosthetics Orthotics , Mobility Aids
And overalll recomendations for RCI act ammendment can be :-
As per the notification on the site of RCI we have been through the amendments in the act and are sending you the recommendations which can be considered for the act and suggestions which can be later on implemented through the amended act
Here is the complete list
Recommendations for RCI Act amendment :-
DEFINITIONS By WHO must be included
Disability / difficulties in functioning
To ensure consistency in concepts and language across professions, stakeholders, and countries, the
Guidelines will follow the International Classification of Functioning (ICF) approach to disability
(WHO, 2001), which understands functioning, and disability, as a dynamic interaction between
health conditions and contextual factors, both personal and environmental. In the IFC, problems in
functioning are categorized in three interconnected areas: impairments, activity limitations, and
participation restrictions. Disability refers to difficulties encountered in any or all three of these
areas. The ICF emphasizes environmental factors in creating disability.
Rehabilitation
Rehabilitation, defined as "a set of measures that assist individuals, who experience or are likely to
experience disability, to achieve and maintain optimum functioning in interaction with their
environments" (WHO, 2011), is instrumental in enabling people with limitations in functioning to
remain in or return to their home or community, live independently, and participate in education,
the labor market and civic life.
Rehabilitation measures are aimed at achieving the following broad outcomes:
• prevention of the loss of function
• slowing the rate of loss of function
• improvement or restoration of function
• compensation for lost function
• maintenance of current function.
Recommendation for addition/substitution
1. Changing the name RCI ACT of 1992 to RCI ACT 2017
2. Including the line “wellbeing of persons with disability” which defines that the act will be working for it.
3. Separating the list of Rehabilitation Professionals/ Medical Professionals & Rehabilitation Personnel
4. Keeping a minimum requirement for registration under each profession
5. Allowing registration of professionals passed out from recognized courses from recognized foreign universities
6. Defining each profession as per WHO guidelines, for example, Prosthetist & Orthotist as per WHO is a healthcare professional who treats a person by means of Prosthetics & Orthotics and at least should have a bachelor degree in Prosthetics & Orthotics
7. Keeping Prosthetist & Orthotist in the list of Medical Professionals working in Rehabilitation sector (as per latest guidelines of WHO)
8. Keeping a Prosthetic Orthotic Technician in the list of Rehabilitation Personnel and defining their responsibilities as per WHO guidelines.
9. Adding Rehabilitation Councillors and Social Worker in disability as separate entity of personnel in CRR
10. Adding Physiotherapist, Occupational Therapist & Rehabilitation Manager to the list
11. Giving the prefix of Dr to Prosthetist Orthotist, Physiotherapist & Occupational Therapist
12. Defining a minimum pay scale for all the professionals based on 7th pay commission and International payment structure
13. Defining a maximum working hour of professionals
14. Until unless a person is registered in CRR the person must not perform the work specified in CRR and even if the person is registered in CRR the person must not do any other work of any other professional registered in any other slot in CRR
15. Strictly restricting non-rehabilitation/medical professionals from treating/selling any patient/product in the name of rehabilitation of disability.
There must be 5 years of Jail and/or 2 Lakhs penalty for those who are working on any person with disability without being registered in CRR/ trying to do some other professional’s job registered in another slot of CRR
16. Ensuring that RCI act is reviewed every 5 years and time to time amendment is done as per international laws and requirements
17. Ensuring that Human resources in Rehabilitation sector is sufficient, sufficiently trained and upgraded time to time.
18. Defining rehabilitation team and rehabilitation clinic/department in purview of healthcare setup
19. Ensuring that a rehabilitation clinic must become the part of primary secondary and tertiary care units at public health as well as private health level
20. Ensuring that a database of disability and its cause is made and made available online with annual updates
21. Integrating disability surveillance with Integrated disease Surveillance Programme
22. Making State Units of RCI to keep proper surveillance and track of works going on in field of disability and rehabilitation
23. Making the provision grants for CRE and tax rebates on aids and appliances as per WHO directives
24. Defining all 21disabilites (as per PWD ACT 2017 ) and categorizing them
25. Making sure that all professionals working on the 21 disability are given space in list of Rehabilitation Professionals
26. Making a Rehabilitation Cadre under Public Health Cadre
27. Defining Inclusion for person with disability
28. Defining barrier-free environment for Person with disability
29. Making an unemployment register for qualified Person with disability
30. Making Information Education Communication necessary for making people aware of disability
31. Ensuring that education and work opportunity is not denied to any person and there should be a minimum wages law for PWDs
32. Making a national helpline for Persons with disabilities
33. Making a team of WHO, UNICEF, UNDP, Ministry of Health, Ministry of Social Justice & Empowerment, Ministry of Human Resource
Development, Ministry of Law, Ministry of Labour and other NGOs working in the sector and at least having 2 annual meetings with whole team to evaluate the programmes and policies.
34. Availability of Mobile clinics to cater rural and remote area populations
35. Making More National Institutes/ adding more courses of specialization, super specialization and PHD programmes in all national institutes on all 21 disabilities
36. Linking all National Institutes together and making the job transferable so as to keep the staffs and numbers updated
37. Upgrading all the courses running as per WHO recommendations and/or international best practices.
38. Universal Health Care for persons with disability and inclusion of all types of disability in insurance
39. Making sure that there remains a national and state warehouse to keep and manage all types of equipment, drugs, physical medicines for persons with disabilities
40. Making national research and trial institute for disability care services
41. Ensuring Disability certificate is issued from any rehabilitation clinic at any secondary or tertiary care government hospital, just that registration is done in a central portal where the person can be registered using Health card
42. Despite giving physical certificates of disability (hard copies ) the person should be issued a smart health card to track all his/her records as well as online access just by biometric signature or unique id number
43. Making it mandatory to have all public transport accessible to all PWDs and reserved seats and spaces both for different types of PWDs.
44. Making a register of barrier-free structures (with the percentage of the barrier-free environment) and transportation too.
Hope you people can strongly reperesent these points on behalf of every Prosthetist & Orthotist and Rehab professional.
With Best regards
