“Increasing mental health institutes and specialists workforce,” said the notice, “though has met the needs of those with acute and severe mental illness (4.5% of the total mental morbidity), the available trained professionals are insufficient to meet the high demands of mental health care of minor illnesses which account for 83 per cent of the total mental morbidity…” 

Guftagu and Leher’s drum circle for queer people in Vashi. The most compelling argument against a BSc Psych is that a therapist needs to place a patient in their socio-economic-cultural realities of community, gender, sexuality and political climate.

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To mental health professionals, so much of this move, the thought process behind it, and the fact that a body set up to solely regulate programmes for rehabilitative measures is gatekeeping the doorways to the field and deciding who is a therapist and who isn’t, is 
deeply problematic.

The RCI is an apex body under the Ministry of Social Justice and Empowerment and the Department of Empowerment of Persons with Disabilities. While there is an overlap between mental health and rehabilitation, because a patient of schizophrenia may need institutional care, it should be the role of the Ministry of Education to take a call on shifting a discipline from Science to Arts, and to detail the curriculum within it for the whole field of psychology.

The first layer to unwrap is that all over the world, psychology is part of Humanities or Arts, an interdisciplinary study. While treating a patient authentically, the therapist will have to place them in a context of their socio-economic background, age, physiology, community, gender construct, sexuality, current political or cultural climate, while detangling personality disorders, past traumas, and attachment issues. A broader education in anthropology or sociology would support the therapist more than Physics or Chemistry.

Sadaf Vidha, Divija Bhasin and Rupa Chaubal. Pic/Shadab Khan

And of course, there is the matter of empathy and stress on emotional intelligence. Which is not to say a student of science will lack these; but to offer the course solely to these students narrows the entry pathway, and excludes those with an aptitude and preference for Arts/Humanities. And thus lowers the number of therapists who will eventually help; and the quality of education and hands-on expertise they have to support them.

“The RCI is a national body for registration,” says Dr Lata Das, “and on paper, it’s a good vocational course, but rigid boundaries of only 30 seats for those with a Plus Two in Science will not help.” Das is a faculty at the Centre for Lifelong Learning, School of Social work at Tata Institute of Social Sciences (TISS), and her view comes from 20 years of experience. For vocational courses, she says, several reputed institutes such as TISS have various diplomas in psychology that can supplement the skills of an existing profession in a field like teaching, or facilitate a mid-career change. And such programmes will help tackle mental health at systemic level. 

“Nowhere in the world is there a mandatory expectation to be a science student to study psychology,” says New Delhi-based, who was among the first to flag off the RCI move on social media. 

When we speak to the founder of the mental health organisation The Friendly Couch, she requests that we be careful in calling her a psychologist, counselling psychologist or psychotherapist; and not a coach or clinical psychologist. She has a BA in Psychology from Delhi’s Ambedkar University, an MSc in Applied Clinical Psychology from the University of Bath, UK, and an MA in Clinical Psychology from Amity University, Noida.

There is a crucial difference pertinent to the debate at hand, and why RCI’s move is welcome to regulate the very chaotic field. “RCI governs all of psychology and decides who is a therapist and who isn’t,” says Sadaf Vidha, founder, Guftagu Therapy in Vashi. “You can call yourself a clinical psychologist only if you do an RCI-registered MPhil; just a Masters is not enough. Most ethical practitioners have a Masters in either Clinical or Counselling Psychology.”

However, the government has not neatly categorised these: As per the Mental Healthcare Act of 2017, one needs to be an MPhil registered clinical psychologist to work with patients. However, the National Commission for Allied and Healthcare Professions Act, 2021 recognises the Masters in Counselling or clinical degree, and other people like Arts-based therapists or psychologists and coaches.

But all the players in this ecosystem need not be at odds with each other. In fact, categorising the severity of cases can fill the treatment gap, says Vidha. A clinical  psychologist deals with mental illnesses, while a counselling psychologist concerns herself with a more holistic worldview such as a relationship crisis, that may also include a mental illness.

We live in enlightened times. Never before has there been so much talk about mental health and openness to therapy to improve interpersonal relationships, deal with day-to-day stress, heal from trauma, address attachment issues and become whole, as well as for personal growth and achieving one’s potential. In this landscape, help cannot come from professionals who only know the names of disorders, or of the Five Signs That You Are a Narcissist.

“India needs preventive and promotive work in Mental Health Sciences,” says Das, speaking as an educationist and not representing her institute. “RCI’s circular says the students will receive ‘adequate’ skills, but that’s not an adequate explanation. Each specific skill and the outcomes for students at each level need to be spelt out since the  RCI circular mentions that the programme is based on National Education Policy and  National Higher Education Qualifications Framework (NHEQF) Level 6  as per UGC guidelines. The fundamental premise underlying the NHEQF  is that higher education qualifications such as certificate, diploma, and degree are awarded based on the demonstrated achievement of learning outcomes and academic standards expected from  graduates.” These could mean competitive skillsets to map out a case and its programme. 

“Say 100 people need therapy, only 10 get it,” says Vidha, a therapist and researcher who specialises in relational psychoanalysis for childhood and attachment trauma. “The solution doesn’t lie in diluting the current study expectation. We need a layered approach to address various groups of people based on severity—counsellers with diplomas and certificates can be first responders or helpline counsellors, then come those with a Masters degree, and then the ones with M-Phils, Doctor of Psychology (PsyD) or PhDs.” A PsyD degree focuses more on hands-on clinical training along with research, preparing students for field careers.

Bhasin and Vidha also emphasise the need for licensing and an ethics board where malpractice can be reported. “Out there are coaches with a certificate or a counselling diploma taking on serious cases, which is leading to a lot of malpractice,” says Vidha. “They even offer conversion therapy for queer and trans people, which is horrifying.”

There is an effort by the body called the Psychologists Collective to form the Psychology Council of India. They have petitioned the government to remove RCI from governing psychologists and form a body comprising psychologists to regulate degrees, educational experience and work experience in the profession. Rupa Chaubal, its president, says, “The stakeholders were not given a chance to voice their opinion, consent or objections before deciding upon the qualifications for the title of a Clinical Psychologist.”  

One option is a four-year nested programme after BSc/BA Psychology to get a PsyD. It can have exit points that prepare the professional to work at different levels. “If you finish the first year,” suggests Vidha, a participating member of the Psychologists Collective, “you get a professional diploma. Two more years gives you another degree; in four years, you earn a PsyD.” 

This will also accommodate the skills needed for a working professional. Currently, even some Masters degrees do not equip therapists with process skills, supervised on-field sessions, long term therapy plans and an understanding of ethics. Many do not have a supervised internship programme. A student of BSc Psych would be even less supported if her combination subjects are Physics and Botany, as opposed to an Art student’s Sociology and Political Science.

“Internationally,” explains Chaubal, “Clinical Psychology follows a bio-psycho-social model. The suggested curriculum of B.Psy, M.Psy as well as PsyD strongly relies on the medical model. Clinical psychology needs a psycho-social foundation; it cannot be in the stronghold of a bio-medical model. You are not treating only the mind of the person, you need to know where that person is, her realities and be able to tailor the interventions accordingly.”

“People need to learn a lot that education does not prepare them for,” says Vidha. “[And] a BSc in Clinical Psychology will not help the case. It will have little to no practical counselling skills and will not cover micro skills about the therapeutic relationship.”

Currently, it is not mandatory for counselling psychologists to work during their Master’s degree. Only some colleges offer internships with supervised counselling sessions. The same goes for the MPhil degree, even though all the colleges offering it come under the RCI. 

Chaubal points out that Maharashtra did not have an RCI institute until Amity University came up in 2014 and it had eight seats. Even now, there are very few RCI-recognised institutions from where the RCI degree courses can be pursued. 

Chaubal says this little technicality looms over veterans in the field who feel like they are practising illegally. “We may have PhDs, guided them, worked in reputed, government organisations such as Nagpur AIIMs or have over 35 years of experience, but face bullying on social media where someone will say we cannot call ourselves clinical psychologists because we don’t have an RCI registration.” Chaubal, for instance, has an MA in Counselling Pscyhology from Mumbai University, an MA in Clinical Psychology from SNDT and an MPhil from Tiss in Couselling and Clinical Practice, and 22 years of practice experience. Dr Das has a PhD from TISS.

“The essence of the new regulation is helpful because it makes placement mandatory during the degree,” says Bhasin. “This new course will help fill that gap, although it is not ideal as the RCI is not solely for psychologists.” 

Perhaps the RCI has thought this through, but there are no details available. They are yet to respond to a legal notice sent by The Psychologists Collective.
“There is little to no transparency,” says Bhasin. “No information is given about who makes the decisions and they do not answer questions on mail. If any psychologist or psychology student has a question, they are left with no answers.” 

Her vote is also to an independent government level body made up of practising psychologists. “There should be a license system [the RCI system is a registration],” she says, “Which means all psychologists must adhere to a set of rules and ethics. Currently, anyone can work as a psychologist, without consequences, without ever having studied psychology and there are no consequences.” You can coin yourself a therapist with a certificate in a supplementary modality such as inner child healing, past life regression or shadow work.

But trauma cannot be divided so neatly. “Somebody who comes to you for marital problems may have history of child sexual abuse, a personality disorder, attachment problems,” says Vidha. “All of that influences marital problems. So the distinction that if you are working with rehabilitative populations, then you need an MPhil, and if you are doing counselling, you just need a BSc, is ethically incorrect.” 

A concern among practising  educationists and professionals, such as Dr Das and Chaubal, is how the regulation will fit retrospectively. And what are the prospects of those from other pathways to get into international programmes and education institutes, given that RCI is a government limb, jobs and opportunities such as being on decision-making committees may tilt towards RCI-dominant trainers.

Then there’s a Recognition of Prior Learning metric that takes into account formal and informal learning: Credit points, or years of practise that put professionals on par with those churned by a change in education pathway. “What about employability?” asks Dr Das, “Will other candidates be eligible for a job, as much as a BSc Psy student? 

“If the RCI registers BSc Clinical Psychology graduates as Counseling psychologists, how does one license such a candidate? How can the training equip a candidate to work as a counseling psychologist?” are Chaubal’s questions. Underlining this decision is that RCI seems to think that counselling doesn’t need as many skills. The best course may be that it only regulates psychologists in rehabilitative field.

At the time of going to print, the RCI had not responded to mid-day’s questions.