India's AYUSH Model: A Blueprint for Ghana's/Africa TCIM Regulation

According to the study, Ayurveda, Unani, Siddha, Homoeopathy, naturopathy, acupuncture, chiropractic, and osteopathy are not simply different names for Ghanaian traditional medicine. They represent distinct systems with their own philosophies, diagnostic frameworks, therapeutic methods, educational pathways, and—critically—their own regulatory needs.

A comprehensive comparative analysis of India's regulatory framework for traditional and complementary medicine presents a compelling case for reform of Ghana's approach to governing healthcare systems that fall outside conventional biomedicine.

The study, titled "Understanding the Regulatory Framework of AYUSH, Acupuncture, Chiropractic and Osteopathy: Lesson for Ghana & Africa," was prepared by Prof. Raphael Nyarkotey Obu ESQ, a Ghanaian naturopathic academic, dual-qualified lawyer, and President of Nyarkotey University College of Holistic Medicine and Technology . It arrives at a moment when Ghana's Traditional Medicine Practice Council (TMPC) faces intensifying scrutiny over its regulatory mandate .

The Central Problem: One Umbrella, Many Identities

The paper's central argument is that Ghana, like many African nations, treats everything outside conventional medicine as a single, undifferentiated category called "alternative medicine." This creates profound conceptual and legal difficulties .

According to the study, Ayurveda, Unani, Siddha, Homoeopathy, naturopathy, acupuncture, chiropractic, and osteopathy are not simply different names for Ghanaian traditional medicine. They represent distinct systems with their own philosophies, diagnostic frameworks, therapeutic methods, educational pathways, and—critically—their own regulatory needs.

"Administrative convenience in placing multiple healthcare disciplines under a common regulatory institution should not extinguish the distinct educational, professional, clinical and legal identity of each regulated profession," the study states.

India's Differentiated Model: A Lesson in Complexity

India's Ministry of AYUSH formally identifies Ayurveda, Yoga & Naturopathy, Unani, Siddha, Sowa-Rigpa, and Homoeopathy as distinct systems of medicine. Each has separate education, research, practitioner, and institutional structures .

The study explains that Ayurveda, Unani, Siddha, and Sowa-Rigpa are regulated under the National Commission for Indian System of Medicine Act, 2020—a statutory framework that recognizes them as distinct medical systems with their own professional identities . Homoeopathy is separately regulated under the National Commission for Homoeopathy Act, 2020 .

Yoga and naturopathy, while located within AYUSH, possess distinct governmental, educational, research, and institutional identities. Ministry of Ayush statistics separately report naturopathy practitioners, and research architecture separately identifies Yoga & Naturopathy.

Key point: India does not treat everything outside conventional biomedicine as one homogeneous category called "alternative medicine." Instead, it differentiates between a complete medical system, a healthcare profession, a specialty, and a therapeutic technique.

The Ghana Tension: Legal Mandate Under Scrutiny

Ghana's Traditional Medicine Practice Act, 2000 (Act 575) established the Traditional Medicine Practice Council (TMPC) to "promote, control and regulate traditional medicine practice." The Act defines traditional medicine as practices based on beliefs and ideas recognized by the community to provide healthcare using herbs and other naturally occurring substances .

However, TMPC currently states it also regulates complementary and alternative medicine (CAM), citing a 2008 directive from a former Minister of Health . The Council has announced plans to implement a digital licensing system for TCIM practitioners .

According to the Council, CAM covers spas, gyms, wellness centers, nutritional health shops, organic and inorganic health shops, beauty and facial centres, massage centres, reflexology, aromatherapy, acupuncture, chiropractic, osteopathy, naturopathy, homeopathy, and Ayurvedic medicine . Section 39 of Act 575 prescribes penalties of up to two years' imprisonment for unlicensed practice .

This interpretation has been met with legal challenge. Prof. Nyarkotey Obu, who is also General Secretary of the Ghana Alternative Medical Practitioners Association (GAMPA), has challenged the TMPC's authority to regulate alternative medicine, arguing that the Act was passed to regulate traditional medicine, not alternative or complementary systems . The Attorney General reportedly clarified in a 2010 letter that Act 575 does not extend to alternative medicine—a clarification the TMPC continues to operate contrary to .

Global Context: A Growing Trend

The Ghana debate is not happening in isolation. Research on the regulation of traditional and complementary medicine across multiple African countries identifies a fragmented landscape :

• Ethiopia has only a draft proclamation governing T&CM practices

• Kenya and Uganda have implemented regulatory frameworks, but non-indigenous T&CM practices are not covered

• Ghana and India have some of the most comprehensive frameworks

• China has the most extensive coverage, with indigenous TM, TCM, acupuncture, and osteopathy receiving health insurance coverage

The scope of health insurance coverage reveals differing policy priorities. India's health system covers indigenous TM, TCM, chiropractic, and naturopathy . This indicates a more integrated approach compared to Ghana, which currently offers no health insurance coverage for traditional or alternative medicine services .

Why the Surgery Issue Matters: "Surgery" is a Competency Ladder, Not a Word in a Degree Title

A crucial section of the study addresses a potentially dangerous misunderstanding in Ghana. The presence of the word "Surgery" in an AYUSH degree title—such as Bachelor of Ayurvedic Medicine and Surgery (BAMS) or Bachelor of Homoeopathic Medicine and Surgery (BHMS)—does not mean the graduate is authorized to perform unrestricted surgery .

The study establishes a SURGERY PRINCIPLE:

"A course may teach surgery so that a practitioner can recognize surgical disease, provide appropriate pre-operative or post-operative care, perform specifically trained procedures, and make timely referrals. The mere presence of a surgery subject—or even the word 'Surgery' in a degree title—does not by itself authorize unrestricted operative practice."

The study provides detailed breakdowns of which AYUSH professionals receive specialist surgical training and what procedures they are trained to perform :

Ayurveda – BAMS:

• Specialist surgical pathway: M.S./PG Shalya Tantra; Shalakya specialties

• Includes kshara/ksharasutra and para-surgical procedures; specified general surgical, anorectal, ophthalmic/ENT, and specialty procedures according to training

• Regulatory interpretation: UG surgical study does not mean unrestricted surgery; specialist scope follows prescribed education and competency

Unani – BUMS:

• Specialist surgical pathway: M.S. Ilmul Jarahat and related surgical/ENT/OB-GYN specialties

• Includes surgery, ophthalmology, ENT, dentistry, and specialty surgical training under prescribed programmes

• Regulatory interpretation: The postgraduate surgical qualification provides a clearer specialist identity; degree wording alone is insufficient

Siddha – BSMS:

• Specialist surgical pathway: Aruvai Maruthuvam

• Includes suturing, wound care, abscess drainage, cyst excision, venesection, selected ano-rectal/Siddha procedures, bone-setting exposure

• Regulatory interpretation: Procedure-specific competence and regulatory scope matter; not an unrestricted general-surgery licence

Homoeopathy – BHMS:

• No general surgical specialty comparable to Ayurveda Shalya Tantra identified in the current framework

• Includes recognition of surgical conditions, pre/post-operative care, and specified minor procedural exposure

• Regulatory interpretation: BHMS title does not automatically confer authority to undertake major surgery

For Ghana, the study warns against two opposite errors: prohibiting every procedure merely because the practitioner belongs to a traditional or complementary medical system, or assuming every graduate whose qualification contains the word "Surgery" is automatically entitled to perform surgery.

Proposed Ghana Rule: "No practitioner should obtain surgical authority merely from the name of a qualification. Surgical or invasive privileges should be granted only for procedures expressly supported by recognized education, supervised competency, registration, scope-of-practice rules, and appropriate facility standards."

A Proposed Pathway for Ghana

The study proposes a profession-sensitive classification model for Ghana that preserves the distinct identity of complete medical systems and healthcare professions :

The Regulatory Identity Principle

The study proposes a REGULATORY IDENTITY PRINCIPLE:

"Administrative convenience in placing multiple healthcare disciplines under a common regulatory institution should not extinguish the distinct educational, professional, clinical, and legal identity of each regulated profession."

This permits a practical middle ground: Ghana could maintain a common umbrella regulator if Parliament considers that administratively appropriate, while still creating profession-specific boards, registers, educational standards, scopes of practice, titles, ethical codes, and disciplinary arrangements .

A Note on Professional Identity

The study emphasizes that a complete medical system is not the same as a therapeutic technique. Ayurveda is not merely herbal medicine. Chiropractic is not merely spinal manipulation. Naturopathy is not merely nutrition. Acupuncture is not merely the act of inserting needles. Traditional medicine itself encompasses distinct indigenous knowledge and practices .

The Policy Implications for Ghana

The comparative lesson is clear: India does not treat everything outside conventional biomedicine as one homogeneous category called "alternative medicine." Ayurveda, Unani, Siddha, Sowa-Rigpa, and Homoeopathy are recognized as distinct systems of medicine within a developed national architecture .

For Ghana, the issue should move beyond the binary question of whether these practices are "traditional" or "alternative" to more appropriate regulatory inquiries:

• What is the identity of the system or profession?

• What education defines it?

• What scope and risks attach to it?

• What title should be protected?

• Which regulatory arrangement best protects the public?

About the Author

Prof. Raphael Nyarkotey Obu is a pioneering figure in African naturopathy, law, and public health. He is the Founder and President of Nyarkotey University College of Holistic Medicine & Technology (NUCHMT), Ghana's first naturopathic medical institution . He holds a PhD in Naturopathy, an LLB from the University of Cape Coast, a BL from the Gambia Law School, and is a Barrister and Solicitor of the Superior Courts of The Gambia—the first African Naturopath to be called to the Bar as a lawyer .

He led the development of Ghana's first national occupational standards in Naturopathy and Holistic Medicine and has championed the establishment of naturopathic curricula across several African countries, including The Gambia . He is also Legal Director of the Traditional Healers Association of The Gambia (TRAHASS) and General Secretary of the Ghana Alternative Medical Practitioners Association (GAMPA) .

Prof. Nyarkotey is a member of the World Naturopathic Federation (WNF) Research Advocacy Team and a Chartered Health Economist and Management Consultant . His vision is to integrate African indigenous healing systems into mainstream health frameworks while safeguarding their intellectual, legal, and clinical integrity .

— END —