FAQ on AHP Act & AHPIS Registration

The followings were questions put up to us verbally or via WhatsApp  and e-mail.

The answers provided were from MIMLS not BSKB so readers should bear that in mind.

Q1.  I am employed as a Medical Laboratory Technologist in a private laboratory. I am a Biomedical Science degree holder and currently pursuing a master’s degree in embryology.

Can I register now as a Medical Laboratory Technologist and register later as a Scientific Officer when I got my masters.

A1. MIMLS Answer: 

Yes, you can register as an MLT if you are employed as an MLT and register later as Scientific Officer (Embryologist) if you are then employed as an Embryologist. However this is subject to the Malaysian Allied Health Professions Council’s (MAHPC) approval.

Q2.  In my laboratory, I am covering all the major disciplines of the medical laboratory such as

haematology, biochemistry and microbiology. If I register as a Scientific Officer in Embryology, can I still work as scientific officer who covers all disciplines of a medical laboratory?

A2. MIMLS Answer: 

This is unclear as the act is silent on this matter but probably will be addressed in the regulations. Thus far this is not a problem in the private sectors but we were made to understand that the policy in the ministry of health that biomedical scientists are not permitted to work in the biochemistry and microbiology unit of Pathology. They are allowed in the other fields of pathology such as Anatomy Pathology, Cytopathology, Haematology and Transfusion Medicine. This policy is unique to Malaysia because as far as we know this policy is not practised anywhere in the world.  Once the Act has been gazetted, we are unsure this policy will also be imposed to the private sector under the pretext of standardizing and regulating the job descriptions of each profession. However our suggestion would be to remain registered as a medical laboratory technologist as we believe that the employers in the private sector would prefer a polyvalent MLT and multitasking ability would be an added value.

Q3.  If I remain registered as a Medical Laboratory Technologist, will I be allowed to work in embryology as I am also qualified to practise this branch of laboratory science.

A3. MIMLS Answer: 

As far as MIMLS is concern you are qualified to do embryology but the final say would be from MAHPC.

Q4.  Please correct me if I am wrong, perhaps I am misinformed, but is it true that in the Ministry of Health labs, a person with a degree in Biomedical Science are not allowed to work in biochemistry and Microbiology lab? This policy is not practice in the private sectors or even in the university hospitals, will this policy be imposed on us in the private sectors once the AHP act has been passed by Parliament?

A4. MIMLS Answer: 

Please see answer for Question 2

Q5.  I am employed as a medical Laboratory scientist in a private lab and I observed that there is no such designation in AHPiS. My qualification is a diploma in MLT and a degree in Biology. Under which profession should I be registered as?

A5. MIMLS Answer:

It would be more prudent for you to register as an MLT based on your diploma qualification as a degree in biology at the moment is not recognised as the appropriate qualification to in any of the Scientific Officers listed in schedule 2. The Medical Laboratory Scientist designation in some country is equivalent to Medical Laboratory Technologist in some other countries based on their job description.

NOTE: Medical Technologist, Medical Laboratory Technologist, Medical Scientist, Medical Laboratory Scientist, Biomedical Scientist and Biomedical Laboratory Scientist are recognised and accepted professional titles for Medical Lab Professional around the globe.

Q6.  My qualification is a diploma in Biomedical Science (Singapore Polytech) and employed as a Medical Laboratory Technologist. From the list of recognised diplomas and degree and institution of education that was shown, my diploma and institution is not listed.

a) How do the council evaluate diplomas or degrees from universities not in the list?

b) Will the council review each application for registration by evaluating the qualification and universities that produce that degree or diplomas or just flatly reject because it is not in the list.

A6MIMLS Answer: 

This is a question more appropriate for the MAHPC to answer.  However MIMLS will engage with the MAHPC with this suggestion. All requests for registration with a qualification not listed in the list of recognised qualifications and institutions of higher learning or Training colleges should be evaluated by a committee appointed by MAHPC. The transcript of the course will be compared to the Standard Program in line with terms and regulations required by MQA for certification. This also applies to overseas qualifications.

Q7.  If my application to register and practicing certificate is rejected for whatever reason:-

a) Will I be reimbursed since the payment for registration and practicing certificate has been made before the registration is even approved? If it is going to be reimbursed, then how will the council return the payment to the affected person or do the affected person has to go through all the hassle just to get back his/her money?

b) If the reason for rejection is the qualification is not recognised or the degree is from an unrecognised foreign university or not in the list, does the act has provision for the affected person to request the curriculum be evaluated. If after evaluation, the curriculum is found to be equivalent to the one from a recognised university in the list, can the affected person appeal the decision of the rejection? Is there no venue in the act to this effect?

A7. MIMLS Answer:
a) This is again a question more appropriate for the Allied Health Science Division (BSKB) to answer. We were assured by BSKB that if registration is rejected the fee collected will be reimbursed but the mechanism of reimbursement has not yet been regulated.
* UPDATE 3/2/2016: BSKB has informed us that the registration fee will not be reimbursed.

b) The answer is similar as to Question 6, please see above. If after evaluating the transcript of the course provided by the requesting person by the appointed committee and finds it to be compatible to the Standard program, the person will be registered as an MLT or Scientific Officer or any of the Allied Professions with the appropriate qualifications.  As far as we know, venue to appeal if the qualification is rejected has not yet being regulated.

Q8.  I am a biomedical science degree graduate and I am a COO of a company selling laboratory products. Do I need to register?

A8. MIMLS Answer:  NO, unless you are planning to practice in the near or distant future.

Q9.  I am a lecturer in a private university and I am a biomedical science graduate with MSc in Biotechnology. I teach MLT (Diploma),Biomed(Degree) Programmes and also other allied health programmes.

a) Do I need to register?

b) If I have to register, then under which profession?

A9MIMLS Answer:

a) No, you do not need to be registered unless in the teaching process, it requires you to practically handle biological specimens.

b) There are no fixed rules on Academic professionals by BSKB so far. Until there is, we suggest you register based on your qualification. That is if you have a degree in Medical Laboratory Technology, you should register as a Medical Laboratory Technologist and if a Biomedical Science Degree, you should register as Scientific Officer (Biomedicine). But if your degree is not any of these examples such as Biology or Biotechnology we suggest you register as a Medical Laboratory Technologist.

Q10.  Dear Sir, first I would like to thank MIMLS and BSKB for uploading the powerpoint presentation of the talk on the MIMLS website so that we can scrutinize the content to understand further of the subject concern.

I am currently employed in a small laboratory aligned to a small private hospital. I am a diploma holder while some of my colleagues are degree holders. Believe it or not, sometimes, our salaries are not as high as our counterparts in government service, depending on the company employing the MLTs.

a) Does this fee for registration and Annual Practicing certificate apply to both sectors?

b) Who would be paying for the APC?  The practitioner or the employer?

I also observed that the Allied Health Professionals consists various grade of officers, from diploma holders with low starting pay to degree graduates whose paycheck is much higher but paying the same fee of RM100.00. Though this is fine with professionals with degree pay but it is too high for diploma holders. 

c) Can MIMLS negotiate with BSKB to lower the fee so that it would not be a burden to the diploma holders? That is, the fee should be affordable to all, including diploma holders.

We are already paying RM30 annually (that would be RM60 for 2 years) for MIMLS membership subscription and another RM200 biennially for the Practicing Certificate.

A10. MIMLS Answer:

a) Yes, the Registration and Practicing Certificate fees apply to both public and private practitioners.

b) The question of who should bear the cost for the registration and the biennial practicing certificate is clearly beyond MIMLS or BSKB jurisdiction. The employees should engage with the employers on the best course of action on this matter.

c) Though we understand the issue faced by the diploma holders but this has been accepted and endorsed by the 23 Head of Professions and BSKB.  However we concur that all the head of professions are from the public sectors of who may not be sensitive to the private sectors predicament. MIMLS may engage with BSKB on this matter but this would just be an exercise in futility if no other professional association voice out the matter in solidarity.

*Note: MIMLS membership subscription and the Registration and APC fees are two different issues and should not be placed in the same basket.

Q11.  Who will pay the fee for Registration and Practicing Certificate? I am a lab manager and have 200 MLTs working under me in my lab. The employer may be reluctant to pay for the staffs as it would be a significant amount to absorb. At the end of the day, the employees will have to pay for their own, to remain employed.  The fee is much too high for lab techs as we know that our colleagues in the nursing profession pays only RM10 for their APC and their pay is higher than us.

A11. MIMLS Answer:

Please see answer for question 10, as the answer would be similar.       


Q12.  Dear MIMLS, from the talk by one of the speakers, I understand that if a person who did not renew his Practising Certificate after 4 years has lapsed, he will have to re-register and to sit for an exam or passed a competency test designed by the council.

For MLTs in the ministry of Health where their job function are only confined to traditional lab work e.g. microbiology, biochemistry etc. that is fine. However for MLTs in the universities, their scope of work has expanded and we have an extended role in healthcare service so much so that MLTs perform tasks such as Ultrasound, do research and being part of the Cardiology team.

How will the council come out with exam questions or competency tests for these MLTs?

If the council limit the job functions of MLTs through this Act, how will the profession progress? Will this not stifle the profession and eventually taken over by some other profession?

A12. MIMLS Answer:      

This is a question best answered by the MAHPC.  MIMLS can suggest to the council that the questions for the renewal of registration must be based on the applicant’s area of expertise. However as we were made to understand that the MLTs scope of work, as far as BSKB is concerned, is confined only to the traditional job as described in the list of duties based solely on the Ministry of Health Hospitals and Health facilities. Other jobs being done not in line with this will not be attended. Thus we are not optimistic in being able to convince them otherwise.