New doctor registration rules become another flashpoint

The tussle for authority and registration revenue seems at the heart of this latest turf war between the NMC and state medical councils

While the new regulations governing the registration of doctors released by the National Medical Commission (NMC) on May 10 are a step in the right direction, the NMC needs to quickly fix some contentious issues before operationalising them. Called the Registration of Medical Practitioners and Licence to Practice Medicine Regulations, 2023 the regulations specify the eligibility criteria to register in the National Medical Register (NMR). Each registered doctor will receive a Unique Identification (UID) generated centrally by the NMC’s Ethics & Medical Registration Board (EMRB), granting the doctor registration in NMR and eligibility to practice medicine in India.

For patients, the new regulations and the UID system offer hope that a central registry will make it easier to track unscrupulous doctors, who may have been barred from practice in a certain state due to unethical practices but often set up practice in another state.

However, the regulations have created confusion among doctors and resentment among state medical councils. The tussle for authority and registration revenue seems at the heart of this latest turf war between the NMC and the state medical councils.

The grouse that the NMC did not incorporate the detailed observations sent by associations representing doctors in response to the draft circulated in 2022 seems reasonable. In a four page letter to Sandhaya Bhullar, Secretary, NMC dated May 20, 2023, Dr Sharad Kumar Agarwal, National President, and Dr Anilkumar J Nayak Honorary Secretary General, Indian Medical Association (IMA) made several critical observations on the clauses of the May 10 notification, stating that ‘the final regulations that has been put into operations continues to be plagued by inconsistencies, inadequacies and contradictions…’

For starters, the letter alleges that the May 10 notification does not define ’Registered Medical Practitioner’. Neither does it specify how state medical councils are supposed to regulate professional conduct, promote medical ethics or take disciplinary action against doctors. This would therefore need a separate regulation.

A major bone of contention is that the new regulation makes NMC the primary registering authority for doctors, allowing them to practice across the country, thereby taking away the powers of state medical councils.

Similarly, the letter points out that the processing fee of generation of the UID, ‘the lone source of revenue receipt is pocketed by the NMC making them (the state medical councils) lifelong redundant and bankrupt as well.’

The fact that the new regulation proposes that the registration will be valid for five years will benefit doctors, as it reduces their paperwork, and also allows them to practice in multiple states without too many administrative hassles.

However, the IMA letter points out that this move would be ‘perilous for the State Medical Councils, especially from the point of view of their receipt revenue for the purposes of Renewal of Registration ….’

State councils argue that registering at the central level is already being done, as part of the Indian Medical Register (IMR). Would the NMR be a duplication of efforts as doctors are also required to register with their state medical councils?

How soon will existing data from the IMR be migrated to the NMR? Will registered doctors need to re-register themselves?

In the era of social media, misinformation has a tendency to spread faster than truth. For instance, doctors received a social media post, with a link supposedly to the IMR, asking them to check their details on the IMR. Panic broke out when doctors noticed a ‘disparity’ in the IMR data.

On May 25, the Maharashtra Medical Council (MCC) had to issue a public notice, that contrary to viral social media posts, the NMC had not yet provided the electronic format or software for doctors to file and search for their details in the IMR. Hence most of the sections/clauses of the May 10 gazette notification were currently not executable.

While the MCC letter mentioned that as per usual practice, they had sent their data to NMC for updating the IMR, it is a reported fact that while state councils are required to send the state-wise registration data to the NMC to update the IMR on a periodic basis, most states do not do this as diligently as required.

The May 20 IMA letter also points out that though the new regulation requires doctors to apply via a web portal of the EMRB, no such web portal has been notified as of now. In the absence of such a portal, a transition period of 3 months from the publishing and notification of the Regulation is too short, reason the IMA functionaries.

Some state medical councils have their state medical registers in a digital format, and the IMA letter proposes that the entire information of such state medical registers should be transferred to the NMR without compelling individual doctors included in such electronic formats to make individual applications for inclusion in the NMR.

The IMA letter reasons that 30 days is too short a period for state medical councils to verify registration applications, as it involves authentication of all documents, including certificates, especially internship completion certificates and confirmations. In the case of foreign medical graduates, this includes confirmation of documents submitted by them from foreign universities and vetting of documents from the embassies.

One hopes that the central and state medical councils find a middle path to this latest flashpoint and start focusing on real issues like shaming errant doctors, weaning out unethical medical colleges, revamping medical education in India, protecting doctors from violence and above all, nurturing trust between doctors and patients.


IMAMaharashtra Medical CouncilNational Medical CommissionState Medical Council
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