NMC Member writes to NMC on MBBS internship guidelines
New Delhi: Expressing concern on the overall duration of the MBBS internship period as well as the inclusion of the Indian System of Medicine as a special elective in the program, Dr. Sahajanand Prasad Singh, a member of the National Medical Commission (NMC) has written to the NMC chairman, sharing his observations and objections on the new draft regulations for Compulsory Rotating Internship 2021.
In the letter directed to Dr. Suresh Chandra Sharma, the Chairman of NMC, Dr. Singh has raised his concerns regarding several aspects related to the internship program, including the time distribution among several specialities, the inclusion of electives group (especially Indian Medicine), the question of availability of the elective at all the institutions, a probable conflict between regulatory authorities regarding modern medicine and the Indian system of Medicine. He also pointed to the inconsistency in the draft regulations between the time distribution of the internship and goal and objective of the internship program, and the inclusion of other fields of medicine being violative of Supreme Court's previous observations.
The National Medical Commission recently issued the Draft Regulations For Rotational Compulsory Regulations, 2021 and has invited comments and suggestions from various stakeholders asking them to submit their responses before August 7th, 2021.
Acting on the invitation on the part of NMC, Dr Singh, a member of NMC has shared objections pointing out that these guidelines need pruning to make them cogent for the internship program.
Duration of Internship
The member pointed out that while 4.1 defines CRRI as 12 months, section 4.3 later deals with the detailed breakup of the duration of the internship exceeds 12 months.
Section 4 clearly prescribes duration of internship at Seriatim 4.1 as "Every candidate shall be required to undergo compulsory rotating internship to the satisfaction of the college authorities and university concerned after passing the final MBBS examination / NEXT whenever operational, for a period of 12 months so as to be eligible for the award of degree of Bachelor of Medicine and Bachelor of Surgery (MBBS) by the respective universities and permanent registrations in accordance with the Permanent Registration Regulation 2021 of the NMC."
As per Section 4.3, the time distribution of internship whereunder the mandatory and exclusive internship is mandated in Community Medicine for a period of 2 months, in General Medicine for 1.5 months, in Psychiatry for 2 weeks, in Pediatrics for 1 month, in General Surgery 1.5 months, in anesthesiology and critical care 2 weeks, in Obst. And Gyne including Family Welfare Planning for 1.5 months, in Orthodopedics including Physical medicine and rehabilitation 2 weeks in emergency/ trauma/ casualty 2 weeks, forensic medicine and toxicology 1 week, in dermatology veneralology and laprology 1 week, in Otorhinolaryngology 2 weeks, in ophthalmology 2 weeks, and in laboratory sciences and hospital support system 4 weeks. The duration so stipulated is cumulatively amounting to 12 months the whole period of rotating internship.
Further, as a part of the internship, MBBS medicos will also have to spend time taking elective exclusives. These include 2 weeks in one of the chosen of broad specialities group and one week in chosen of the super-specialities group. Additionally now, as per the guidelines, an MBBS intern will also have to spend 1 week of training in one of the departments of ISM and may choose any of the given electives, provided the discipline is available in the same College/ Institution where the Internship is done. The options given include Ayurveda, Yoga, Unani, Homeopathy, Siddha and Sowa-Rigpa.
Pointing out that the 5-months time period mentioned for the Electives (broad specialities group for 2 weeks, Super speciality group for 2 weeks, and Indian System of Medicine of 1 week) is over and above, the stipulated period of 12 months of rotating internship, Dr. Singh has mentioned in his letter that, "it is difficult to decipher how is it the period of electives in three distinct categories are required to be dispensed by the intern as against very clearly spelt out period and break up thereto of 12 months which is binding in nature and mandatory in character."
Electives choice limited to the availability of college
He has also requested attention on the fact that "for each of the electives group to be dispensed it is clearly spelt out that the same is required to be done in the chosen specialty/ discipline that is available in the same college/institution where internship is being done," meaning these electives would become "applicable selectively only to those interns at those specified colleges where the concerned specialites are available."
Dichotomy of AYUSH Internship
In his letter questioning the validity of the AYUSH internship, the member pointed out that a medical intern needs to pick up any one of the streams including Ayurveda, Yoga, Unani, Siddha, Homeopathy, and Sowarigpa. Almost all the disciplines, except for Homeopathy, are covered under the authority and jurisdiction of the Ministry of Ayush in the Govt. of India and Central Council for Indian Medicine. Homeopathy, on the other hand, is governed by Central Council for Homeopathy.
"Therefore, the material question of said avenues being available in a college of modern medicine, which is under the Ministry of Health and Family Welfare with National Medical Commission as the Regulatory Authority thereto and further being governed by enabling regulations notified by it from time to time seems to be farfetched nay impossible in every segment of reality," Dr. Singh, who is also the National President-elect of Indian Medical Association (IMA) stated in the letter.
"As such, the dichotomy which is inbuilt into the regulation itself specially with reference to the mandatory electives allocable period thereto along with a mandatory elective in Indian System of Medicine been over and above the 12 months period of mandatory an exclusive inclusions in the 12 month prescribed period of rotating internship blended with a rider of subject to availability of the avenues for the said dispensation makes the entire construction lose and without any diligent application of mind," the letter further mentioned, adding that "the entire dispensation of allocation of period at Clause 4.3 of the Draft Regulations is totally inconsistent and non-congruent with the goal and objective of rotating internship as delineated in section 3.1 and 3.2 of the very regulation."
Section 3.1 describes the goal of the rotating internship that is to train medical graduates to fulfill their roles as doctors of first contact to the community. On the other hand, Section 3.2 describes the objectives of the internship program mentioning that at the end of the internship program, a medical graduate will possess certain competencies required of 'Indian Medical Graduate'.
Pointing out that the entire rotating internship program needs to be structured keeping in mind the competency-based undergraduate curriculum having been put into force, Dr. Singh added, "any ancillary inclusion not having any material bearing in regard to the expected outcome commensurate with the set-out goal and objective is bound to be superfluous in nature and irrelevant in character."
Stick to one pathy
Further mentioning about the Supreme Court's observations that a registered medical practitioner belonging to a specific field is entitled to practice in the said profession and not trespass any other profession, Dr. Singh stated in the letter that "This being the binding and established position of law any posting in the name of elective in the period of internship which have no bearing in regard to the competencies that the intern would be entitled to practice as a registered medical practitioner are neither open nor permissible for inclusion in the said internship program, otherwise, it will be violative of this binding settled legal position in terms of it being law of the land."