The following Expert members of ICMLS were part of the National Taskforce on MLS constituted by the MOHFW in 2015. The approved Model Curriculum Handbook was prepared which is available on following link of MOHFW

1s MODEL CURRICULA HANDBOOK OF MEDICAL LABORATORY SCIENCES-2016

2. REVISED MODEL CURRICULA HANDBOOK OF MEDICAL LABORATORY SCIENCES-2025

The ICMLS has strongly objected on process, approach, content and duration of the MLS course decided in 2nd Curriculum under NCAHP and submitted a detailed submission on this matter 

Objections submitted by the ICMLS were as under-

ICMLS/2025/09                                                                       Date:  17^th August 2025

To

The Chairperson,

National Commission for Allied and Healthcare Professions (NCAHP)

 

Subject: Objections and Comments on the process being adopted by the NCAHP to Review the Curriculum of Medical Laboratory Sciences

 

Respected Madam,

 

On behalf of the Indian Confederation of Medical Laboratory Sciences (ICMLS), we wish to submit the following objections and concerns (in addition to the feedback already submitted in specific proforma through provided link) regarding the draft curriculum uploaded by the NCAHP for seeking comments of stakeholders: -

 

1. Review Process Conducted prior to Framing of Statutory Rules under the NCAHP Act-2021: The review had been undertaken before the Rules and Regulations under the NCAHP Act notified. This undermines the legitimacy of the exercise as it deviated and undermine the statutory compliance. The model Curriculum is to be adopted all over India in all States/UTs. In absence of adequate representation of States/ UT through fully functional NCAHP supported by the Advisory Council, UG/PG Board and in absence of a fully functional Central Council of Medical Laboratory Sciences, it's not known how the curriculum of AHS can hold the legal sanctity.

 

2. Lack of Adequate Participation from States/UTs: The process did not ensure meaningful participation from State/UT Governments and their respective academic bodies, resulting in a curriculum that may not address regional healthcare needs. There is no representation from the premier Government institutions like PGIMER, JIPMER and Many other Central Govt Institute etc which have been running this course for the last 50-60 years. 

 

3. Reduction in Course Duration: The proposed shortening of the course duration by reducing the existing 3 years and 6 months of theory to only 3 years of theory will compromise academic depth and professional competency, thereby affecting patient safety and service quality in the profession. It is pertinent to mention that the duration of few courses like Physiotherapy and Optometry have been increased to five years whilst MLS which is a multidisciplinary profession has been reduced from 3.5 years to 3 years without any substantial ground and without incorporating the latest advancements in the field of MLS.

 

4. Arbitrary Changes in Job Roles and Career Pathways: The draft introduces changes to job titles, scopes of practice and promotional avenues without stakeholder consensus. This could lead to de-skilling and downgrading of the profession. It was decided 10 years back in previous Curriculum to gradually phase out diploma level program in MLS, now after 10 years again the draft curriculum proposes to retain Diploma course. This will reflect the lack consistency in the approach towards the profession.

 

5. Inclusion of Non-Experts in Review Committees-Several individuals involved in the review process lack the required qualifications and experience in Medical Laboratory Sciences, which can dilute the technical accuracy and relevance of the curriculum. It's known how life Science Professionals without any MLS UG degree can contribute in MLS yet several members are there from Basic Sciences.

 

6. Absence of Consultation with Professional Associations- National professional bodies/ Associations are critical in professional advocacy and play an important role in professional growth yet they were not engaged in the review, which overlooks decades of collective expertise in the field. Surprisingly even the Experts who had designed the previous curriculum have not been included in review process. Rather they were insulted by removing their name as contributors from the group. The expert group was created twice and dissolved subsequently without giving any reason. But on the other side selectively the names of previous Experts were mentioned in Curriculum like Physiotherapy.

 

7. Weak Clinical, Research and Managerial Training Components-The draft reduces exposure to many important topics which are essential for industry-ready graduates.

 

8. Lack of Alignment with industry requirements in private and public health sector establishments- Indian Healthcare Laboratory network is very diverse and requires inputs from Expert members from Government and Private sector including Faculty, Professionals which are missing.

 

9. Absence of Specialization Pathways, job Roles and Responsibilities and Specialization tracks in MMLS Clinical Biochemistry, Hematology, Medical Microbiology, Molecular Diagnostics, Histopathology, Total Quality Management etc are not adequately addressed, limiting advanced career options. This was accepted and recommended in previous Curriculum almost 10 years back but it has been dropped in proposed curriculum. Therefore, the current review appears to downgrade MLS Curriculum and its components.

 

10. No Clear Implementation Roadmap: The draft fails to specify transition provisions for current students, timelines for infrastructure upgrades or training programs for faculty adaptation.

 

We request that our objections be duly recorded and addressed before finalizing the curriculum to ensure that the interests of students, educators, professionals and the healthcare system are safeguarded. Further, we also have serious objections that few outsiders without any official position and expertise in the field of MLS are creating strong influence and biases in day-to-day functioning of the Commission. We seriously apprehend that present degradation move in MLS is the part of such selective and arbitrary approach against MLS Professionals.

 

A fresh review may be conducted with proper representation from States/UTs, professional bodies, and subject experts from Government and Private Healthcare Laboratory network. The curriculum be aligned with global standards and retain adequate duration, content, clinical training and specialization opportunities.

 

In view of the above-mentioned points, we strongly recommend that the review process be deferred until necessary Rules under the NCAHP Act are notified and NCAHP start functioning fully with the representation of all stakeholders including the experts nominated by the States and UTs through Professional Councils and suggestion of Central Advisory Council and Professional Associations.