New Delhi: A doctors' body has urged the National Medical Commission (NMC) to clarify whether medical MSc-PhD degree holders can serve as postgraduate guides or examiners for MD/MS students.

In a letter dated August 10, the Federation of All India Medical Association (FAIMA) raised concerns over the interpretation of the Medical Institutions (Qualifications of Faculty) Regulations, 2025, particularly regarding the role of MSc PhD degree holders in postgraduate medical education.

While acknowledging that the 2025 Regulations recognize MSc with PhD qualifications in specified medical subjects, including Anatomy, Biochemistry, Physiology, Pharmacology and Microbiology, for their appointment and specifically define such individuals as non-medical faculty and provide for their appointment subject to the prescribed qualifications, FAIMA has submitted representation regarding the subsequent interpretation that MSc-PhD holders may be considered eligible to serve as Postgraduate Guides for MD/MS students and/or as examiners in postgraduate medical examinations.

Regulation 16 states that a faculty member may be designated as a postgraduate guide in a broad specialty if the faculty member has at least five years of teaching experience in the respective specialty as an Assistant Professor or above.

"While the provision refers broadly to a “faculty member,” FAIMA believes that its application to MD/MS postgraduate training requires careful consideration of the distinction between medical faculty and non-medical faculty," the association said.

FAIMA has raised several key concerns. It highlighted that MD/MS training is fundamentally clinical and medical in nature. Postgraduate residents are trained not only in theoretical knowledge and research methodology but also in clinical decision-making, diagnosis, patient management, interpretation of investigations and application of medical knowledge to patient care.

Therefore, the association pointed out that the academic supervision and final assessment of an MD/MS candidate should primarily be undertaken by faculty possessing the corresponding recognized medical postgraduate qualification and appropriate clinical/medical training.

FAIMA also cited difference between academic expertise and medical postgraduate training. It said that MSc-PhD faculty can make valuable contributions to teaching, laboratory training, research methodology, basic sciences and interdisciplinary academic activities.

"However, an MSc-PhD qualification is fundamentally different from an MD/MS qualification. Possession of MSc and PhD does not, by itself, establish completion of postgraduate medical residency training, clinical training or independent medical practice in the concerned specialty. Consequently, eligibility to teach or hold a faculty position should not automatically be interpreted as eligibility to guide or examine candidates for an MD/MS medical qualification," FAIMA said. 

The doctors' body further mentioned that the NMC should clearly distinguish between the roles of MSc-PhD qualified non-medical faculty over eligibility for appointment as non-medical faculty, teach undergraduate students, participate in postgraduate academic or research activities, supervise postgraduate dissertations, or act as the principal guide or co-guide for MD/MS students.

FAIMA also said that the broad use of the term “faculty member” under Regulation 16 should not result in MSc-PhD faculty being treated at par with medical faculty for all postgraduate responsibilities.

It particularly requested clarification that MSc-PhD faculty should not be permitted to act as independent examiners for the final MD/MS postgraduate medical examination, where assessment involves comprehensive evaluation of a candidate's medical knowledge, clinical reasoning, diagnosis, management and overall competence as a postgraduate medical practitioner. The final assessment of an MD/MS candidate has direct implications for the competence of future specialists and therefore should maintain appropriate medical and specialty-specific standards.

The association said that the primary objective of postgraduate medical education must remain the production of competent and safe specialists.

The 2025 Regulations themselves distinguish between “medical faculty”, consisting of faculty having an MBBS degree and higher specified medical qualifications, and “non-medical faculty”, consisting of MSc-PhD qualified faculty. "FAIMA believes this distinction should also be preserved while determining eligibility for high-stakes postgraduate academic responsibilities such as principal guide, thesis evaluation and final examination of MD/MS candidates," the association stated.

Therefore, FAIMA urged NMC to clarify that MSc-PhD non-medical faculty shall not be treated as equivalent to MD/MS/DNB-qualified medical faculty for the purpose of acting as principal postgraduate guides for MD/MS students.

It also sought clarification that MSc-PhD faculty should not be permitted to act as independent/final examiners for MD/MS postgraduate medical examinations and also permit MSc-PhD faculty to continue contributing to postgraduate education in appropriate roles, including teaching of basic sciences, laboratory training, research methodology and dissertation-related academic support, wherever applicable.

FAIMA asked the Commission to issue a clear nationwide clarification to all medical colleges, universities and examining authorities so that there is uniform implementation and no ambiguity in the appointment of postgraduate guides and examiners, and if necessary, place the matter before the appropriate Postgraduate Medical Education Board (PGMEB) and expert committee for detailed consideration, keeping patient safety and the quality of specialist training as the paramount considerations.

Also read- NMC calls on medical colleges' faculty for participation in National Patient Safety Conference

Medical Dialogues had earlier reported that, releasing the final Medical Institutions (Qualifications of Faculty) Regulations, 2025, the National Medical Commission (NMC) Medical Institutions (Qualifications of Faculty) Regulations allowed medical MSc, PhD degree holders to be appointed as faculty in Anatomy, Biochemistry, Physiology, Pharmacology, and Microbiology departments.

This followed a 2020 change that reduced non-medical faculty appointments in these departments to 15%, with some departments like Microbiology and Pharmacology restricted to 0%. The 2025 regulations restore non-medical faculty appointments to 30% in these subjects.

Medical MSc Degree holders were allowed to teach in Anatomy, Biochemistry, Physiology, Microbiology and Pharmacology departments of medical colleges until 2020. Back then, the intake of Medical MSc and PhD teachers was allowed up to 30% of capacity per subject (50% in biochemistry).

However, in October 2020, NMC reduced the permissible percentage of Medical MSc/PhD faculty in subjects like Anatomy, Biochemistry, and Physiology from 30% to 15%, while in Microbiology and Pharmacology, NMC decreased it to zero percent.

Then, releasing the "Guidelines for Undergraduate Courses under Establishment of New Medical Institutions,l Starting of New Medical Courses, Increase of Seats for Existing Courses & Assessment and Rating Regulations, 2023", NMC had clarified that only 15% of the total number of posts in the Anatomy, Physiology, and Biochemistry departments could be filled by non-medical teachers.

On July 2, 2025, NMC released an amendment to the UG-MSR 2023 and clarified that Medical MSc and PhD holders would be allowed in Anatomy, Physiology, Biochemistry, Microbiology, and Pharmacology departments to the extent of 30% of the total number of posts in the department, subject to the non-availability of medical teachers.

Thereafter, challenging the National Medical Commission's regulations that permitted Medical MSc/PhD holders as faculty in core MBBS subjects, the doctors have filed a plea before the Delhi High Court.

In the plea, the association, the United Doctors Front (UDF), argued that allowing non-medical faculty is a dilution of medical education and a violation of constitutional/statutory provisions.

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