Competency-based registration, not time-based registration, is key to professionalising allied healthcare. Discuss with reference to recent NCAHP draft regulations.

Time-based registration, or "grandfathering," gives credit for years spent on the job. Competency-based registration gives credit only for skill that has been shown. The NCAHP Act, 2021 set up a statutory national regulator for allied professions, with Central and State Registers [1]. NCAHP's draft Provisional Registration Regulations, 2026 say that moving from provisional to regular registration depends on demonstrated competence, not tenure [2].

Why time served is not enough

• Patient safety: in jobs like lab testing or radiography, one wrong reading can change a diagnosis. Years of practice do not prove a worker's current skill.
• Uneven training: the 2018 Bill aimed to regulate 53 professions [3]. Many of these workers trained in informal settings, and seniority cannot make their skills equal.
• Trust in the register: a Central or State Register [1] is the State's promise of quality. Automatic entry by seniority weakens that promise.

How the draft builds in competency

• Bridge courses, supervised clinical training and minimum qualifying exams close the gaps "wherever applicable" [2].
• Inclusion without dilution: existing workers get provisional registration after their credentials are checked. Each gets a PR UID (a unique ID number), with rules on validity, extension, termination and appeals [2]. This brings them under oversight instead of excluding them.
• Uniformity: a single online registration system covers all States and UTs [2], and the Act sets up a Professional Council for each recognised category [4].

Concerns

• Endless provisional status: if extensions are open-ended, "provisional" could become a permanent second tier [2].
• Vague wording: "wherever applicable" is not defined, so some categories may never face a test.
• State capacity: regular registration goes into State Registers [2]. Weak State Councils could hold back workers who have already qualified.
• Cost: course fees and time off work weigh heavily on low-paid technicians.
• Ethics gap: registration decides who may practise, not how misconduct is handled. The 117th Standing Committee report asked for autonomous boards to regulate professional ethics [5].

Competency-based registration turns an informal workforce into an accountable profession without pushing existing workers out. The final rules should cap extensions, publish which test applies to each profession, strengthen State Councils and set up the ethics boards. This would protect the right to health under Article 21 and advance SDG 3.c on building the health workforce.