Will doctors be able to practice in multiple states? New Rules on License Transfer leaves medical fraternity confused

New Delhi: The recent announcement of the National Medical Commission to have a common National Medical Register that will have entries of all doctors practicing in the country has indeed been welcomed by the medical fraternity. The move, doctors have pointed out, will for the first time lead to a centralized register that will give us the actual count of doctors in the country, avoid duplication of entries and names, and also be a major dent on quackery by making relevant information of registered doctors available on public domain.

However, there are still some clauses of the recent notification that have left many doctors confused, especially on what will be status of their practice if they are working in multiple states and border areas. Doctors are now demanding the NMC give out a clarification onthe matter leaving no doubt for any ambiguity, or even withdraw the regulations and take out a fresh one that is clear on the important silent aspects.

i. If any medical practitioner registered with the State Medical Council, desirous to practice medicine in another State may apply to the concerned State through the web portal of the Ethics & Medical Registration Board in accordance with the procedure specific in Clause 6(ii) of these Regulations.
ii. On submission of an application for transfer of Licence to Practice, an intimation shall be received by the State Medical Council where the medical practitioner is registered for practice and the State Medical Council within a period of 30 days shall approve the application for transfer of Licence to Practice, if it has no objection thereon.
iii. If no decision is taken within 30 days of receipt of the transfer of registration the same shall be deemed to have been approved. 
iv. On receipt of an application for transfer of Licence to Practice by the State Medical Council of the state where the medical practitioner desires to practice, shall subject to the requirement of clause (i) and (ii) above, issue aLicence to Practice certificate to practice medicine in that state. Provided that the unique number of the registration shall remain the same and the prefixed Code of the concerned State/Union Territory shall be substitute with the Code of the new State/Union Territory.
v. The changes made in respect of the State, shall automatically reflected in the National Register.

The guidelines state clearly on the process on the transfer of license, however, remain silent on the issue of multiple state licenses. It is clear that the UID will remain the same but if a doctor is practicing in multiple states, it is not clear how many prefixes will be attached/altered in cases of doctors who wish to practice in multiple states

What will happen to licenses if doctor practices in multiple states?

The NMC regulations while being clear on the transfer of license seem to be silent in case of registrations with various state medical council, a case that will be faced by many senior doctors. 

A super-specialist practicing in Delhi, Noida, and Gurgaon explained to the Medical dialogues team," I live in Noida and operate out of my clinic there every evening. For this practice, i need a registration with UP Medical Council. In the mornings i go to a super-specialty hospital in Gurugram and for this, i need registration with Haryana Medical Council. I am also attached as a visiting consultant with a Delhi-based multi-speciality hospital and for this, I need registration with Delhi Medical Council. I am not clear, with the new guidelines whether these multiple practices be allowed and if yes, how prefixes will be attached against my registration ID."

This confusion has been voiced by many Senior Consultants/Super Speciality doctors. These doctors, who are very fewer in number, often practice in more than two/three States at the same time.

What Will Happen in case of National Emergencies?

It's a known fact, that in case of national emergencies and disasters, the Indian medical fraternity is always known to be stepping up and rushing to various parts of the country to provide immediate aid. However, doctors have pointed out that with a 30 timeline on the transfer of license and no provision for such emergencies/exceptions, it will be against the idea of an Indian Doctor- a helping hand and an aid to society to do his/her job in the need of the hour 

Issue draft regulations and take Stakeholders' Comments, say Doctors 

Calling the NMC Gazette notification dated May 10, 2023 "bureaucratic, regressive & against the idea of Indian Doctor", Kannur-based health activist Dr. Babu KV has already written to the Chairman of the NMC in this regard.

In his letter addressed to NMC Chairman, Dr. Babu referred to the fact that "Prior to Gazetting the Notification, the draft was not put on the Public Domain. Only to mention about it was the NMC RMP regulations put on the Public Domain on 23.05.22."

"NMC should withdraw the notification & issue new one after discussing with all the stakeholders," he opined.

"It is clear that the Notification dated 10th May 2023 do not address the issue of RMPs practising across that Nation,though UID will be issued. In this context, I request the NMC to withdraw the notification & issue a new one after discussing the issue with all the stakeholders," he mentioned in the letter.

Also Read: Finally, NMC Announces A Common National Medical Register for All Doctors

Commenting on the matter, Dr. KV Babu told Medical Dialogues, "In the present era where doctors have to practice in two or more states due to various reasons, it will be ideal to allow doctors with UID to practice across the Nation. Unfortunately, the regulations gazetted on 10th May by the EMRB of the NMC is bureaucratic and regressive. I appeal the NMC chairman to withdraw the present regulations and introduce a new one addressing the concerns of doctors so that all doctors with UID can practice across the nation as Indian doctors."

Also Read: National Medical Register- Five Things you need to know about the Unique ID of Doctors