Sunday, November 22, 2020

NMC guidelines for non-medical teachers are bad

The undergraduate curriculum of medical course (MBBS) is broadly divided into early non-clinical and subsequent clinical phases. The non-clinical component is further composed of pre-clinical (Anatomy, Physiology, Biochemistry) subjects taught in the first year and para-clinical subjects (Pharmacology, Microbiology, Pathology, etc) taught in the second year. The non-clinical subjects are basic and foundational whereas the students study the diseases in detail in the clinical subjects (Pediatrics, Ophthalmology, General Medicine, Surgery, Obstetrics & Gynecology, etc). 

The teachers who teach the clinical subjects in all medical colleges are always doctors (MBBS + MS/MD) whereas a minority of the teachers in the non-clinical subjects are scientists (medical M.Sc / Ph.D.), also called "non-medical" teachers. In the 1950s when not many doctors were pursuing postgraduation in non-clinical specialties, a severe shortage of teachers occurred in these specialties. The Health Survey and Planning Committee (Mudaliar Committee) of 1961 recommended opening up of the M.Sc courses in the five non-clinical subjects to non-MBBS science graduates so as to create teachers to teach in medical colleges. The medical M.Sc courses (in Anatomy, Physiology, Biochemistry, Pharmacology & Microbiology) were included in the first schedule of the Indian Medical Council Act. Since the M.Sc courses were pursued by the graduates in life sciences and MD courses in the same subjects were introduced for the medical graduates, MCI quietly withdrew the regulation of M.Sc courses. It also claims that these courses are no longer in the first schedule. At one point in time around 100 medical colleges were running medical M.Sc courses in these five non-clinical subjects, now around 35 medical colleges do. 
Excerpt from the report of Mudaliar Committee


The Teachers Eligibility and Qualifications (TEQ) guidelines of the MCI made a provision to appoint scientist teachers in Anatomy, Physiology, Pharmacology & Microbiology up to 30% of faculty strength, and up to 50% of faculty strength in Biochemistry. There are currently a couple of thousands of non-medical teachers in the various medical colleges across India working in designations ranging from Tutor to Professor & HODs. Similarly, there are plenty of non-medical teachers in centrally administered medical institutions such as AIMMS, PGI, JIPMER, ESI, etc. The appointment of scientists as teachers in the non-clinical specialties is not unique to India; it is practiced almost everywhere. In the top 10 medical colleges of the world, up to 60% of teachers are scientists. In some colleges, some departments are almost entirely composed of scientists. In the US, 21% of teachers in medical colleges are scientists. Although it may seem rational that only doctors should teach MBBS students, it must be borne in mind that non-clinical subjects can be taught effectively by the scientists, who are trained in the same subjects. 

https://journals.physiology.org/doi/full/10.1152/advan.00172.2019


One may still wonder how can a scientist teach medical students even if the subjects are non-clinical. This is because the curriculum and syllabus of medical M.Sc courses are similar in content and quality to the MD courses on the same subjects. Often, both the medical M.Sc and MD courses are conducted in the same medical college by the same faculty using the same curriculum. Both the degrees are offered under the 'faculty of medicine' by the health universities. In addition, the students pursuing medical M.Sc courses have to compulsorily undergo one-year course in Anatomy, Physiology and Biochemistry of the human body (similar to first year MBBS course) so that they are well-versed with the structure and functioning of human body.  Therefore, it can be conveniently concluded that while the underlying graduate degrees are different, the postgraduate degrees are almost similar. 



Medical M.Sc course prospectus

Due to faulty government policies, the number of MBBS UG seats rose in the medical colleges but the number of MD/MS PG seats didn't rise proportionately. There were more doctors but fewer opportunities to take up postgraduation in clinical subjects, hence an increasing number of doctors started pursuing MD in non-clinical subjects. This created competition for the teaching jobs in medical colleges. At the same time, the MCI inexplicably reduced the student-teacher ratio, thereby making the competition for limited jobs even more fierce. 

When the MCI got replaced by the NMC, it published a draft adopting the MCI guidelines regarding the appointment of non-medical teachers. It sought feedback from the stakeholders. Thousands, including non-medical teachers and "non-clinical" medical teachers sent their feedback. In just 7 working days, NMC went through these feedback and decided to reduce the permissible intake of non-medical faculty from 30% to 15% in Anatomy and Physiology, from 50% to 15% in Biochemistry, and from 30% to 0% in Microbiology and Pharmacology. This was the result of incessant lobbying by the community of non-clinical doctors who wanted all the teaching jobs for themselves. In 2018, following a representation from an association of non-clinical doctors MCI had proposed to halve and halt the appointment of non-medical teachers. A sub-committee was formed to examine this issue. The board of governors in supersession of MCI rejected that proposal. Again, following another representation from the same association, the MCI's board of governors  categorically stated in January 2020 that non-medical teachers are required as medical teachers are in short supply. Under pressure from the lobbyists, NMC took a U-turn in October 2020. 

NMC's orginal draft guidelines dated 13/10/2020


25th meeting of BOG held on 6th January 2020

The points that the lobbyists use against the non-medical teachers are the increased availability of medical teachers and the introduction of the new competency based medical curriculum (CBME). While there is no doubt that more numbers of non-clinical doctors are now available for the role of teachers, the vacancies still exist. Many positions are still going vacant for the want of medical teachers, which could have otherwise been filled by the scientist teachers. These conditions force the colleges to deprive the students of teachers rather than appoint scientist teachers. Even to this day, several colleges are managing with non-medical teachers because there is a shortage of medical teachers. For the last few years many PG seats in the non-clinical specialties are going vacant, hence the shortage of medical teachers is likely to continue for several years. 

The CBME involves early clinical exposure and integration (horizontal and vertical) with other non-clinical and clinical subjects right from the first year of the MBBS course. The lobbyists claim that since only the medical teachers have exposure to patients during their own MBBS days, they are better equipped to deal with the new curriculum. While medical teachers can certainly do well, we believe that it is not essential. Only 20% of the syllabus has integrations; there are several chapters that don't need integration at all. All the current teachers, whether medical or non-medical are supposed to undertake Curriculum Implementation Support Programme (CISP), Revised Basic Medical Education as well as Attitude, Ethics & Communication (AETCOM) trainings. In fact, most non-medical teachers have already undertaken these training programs. A non-medical teacher can always seek the help of medical teachers of other specialties to fill the gap. In any case, the 30% limit means only 1-2 non-medical teachers are present in the department whereas the rest (70%) teachers are doctors, who should be able to compensate the shortcomings, if any. 

Besides teaching, the non-medical teachers in the department of Biochemistry and Microbiology also take part in clinical diagnostic laboratory, train MD students, and participate in research activities. In the present COVID pandemic, non-medical teachers have been in the forefront of establishing and running the COVID testing laboratories. Scientists should be an integral component in both medical teaching and diagnostics, as is practiced in many parts of the world. Instead of supporting the scientists, upgrading them, or utilizing them better, the NMC has gone for their exclusion. This certainly is a flawed move. 

Through its FAQ document, NMC has clarified that the new guidelines would be applicable only to the new colleges that would admit students into the 2021-22 batch. The new guidelines would also apply to those medical colleges that would seek enhancement in students' admission. Also, any new appointment into the medical college, whether old or new, will have to follow the new guidelines. This effectively means that a non-medical teacher would be forced to stay put in the same college until retirement, and all possibilities to seek new employment in any college, whether new or old, would be denied. Also, the colleges that opt for seat enhancements will be forced to terminate existing employees in order to fulfill the new guidelines. This will mean that hundreds of teachers would lose jobs. Also, the students who are pursuing medical M.Sc courses hoping to join medical colleges as teachers will have their doors closed by the time they complete their education. It is to be noted here that many medical colleges clearly state in their course prospectus that students can get teaching jobs in medical colleges. These students would be cheated of their chances to earn a livelihood. Having pursued medical M.Sc courses, there are limited avenues of employments outside the medical colleges. In many Western countries, there are no PG courses for doctors in the non-clinical specialties; these areas are mostly serviced by the scientists. In a country that has skewed patient-doctor ratio, more doctors are required to provide direct healthcare, something which our government must seriously consider. 

In every way, the scientists stand to lose, therefore they are protesting it. The entire community of non-medical teachers and students pursuing these courses are alarmed, anxious, and tensed. The scientists' community feel that since NMC is populated and dominated by the doctors, this body would always take the side of doctors whenever there is a conflict of interest. Although NMC is an independent body, the scientists feel that the ministry should step in as it is expected to impartially safeguard the interests of all the stakeholders. For far too long the ministry has pandered to the doctors' community and neglected all others involved in healthcare and medical education. It is time for the government to stand up to the scientists' community and restore their due place. The scientists' community has demanded that the previous MCI norms on the appointment of non-medical teachers be restored. 

The NMC's new guidelines for non-medical teachers are bad for various reasons.

1. It is assumed that only those with MBBS/MD are good teachers and all scientists are bad. This is a myth. There are good and bad teachers with either qualification. In fact, many scientists are excellent teachers. These guidelines will deprive medical students of potentially good scientists teachers.

2. It is assumed that since scientists lack clinical exposure (both theoretically & practically), they will not be able to do justice to the new competency-based curriculum (CBME), which has horizontal and vertical integrations with clinical subjects right from the first year. All teachers, whether medical or non-medical, have undergone the mandatory MCI-monitored curriculum implementation support programme for the implementation of CBME. The integration component is only 20%. It should not be assumed that an undergraduate student in the first or year will start practicing from the third year onwards. The first two phases of MBBS are para-clinical; they get to learn about all the ailments in the clinical subjects anyway. It is wrong to assume that the quality of medical education would not be met due to the presence of one or two scientist teachers. 70-100% of teachers in the non-clinical subjects are anyway doctors. They can always compensate for what a scientist teacher lacks. The NMC must invest some efforts to train the scientist teacher. The scientist teacher can always consult the clinical teacher for inputs, learn, and teach. After all, the scientist has studied the same thing that the medical teacher has learned in the MD curriculum. Basic medical education is undeniably useful, but the teachers from either background teach mainly on the basis of their postgraduate curriculum.

3. It is assumed that the new guidelines would apply only to the new colleges that will establish from 21-22 onwards. Our prior experience tells us there is a strong tendency among the medical colleges (especially private) to apply them as and when they wish. There are already reports of scientist teachers being sacked or asked to leave, even in instances where these rules don't apply. The exclusion of scientist teachers in the rules will give opportunity and armament to the employers to harass the existing scientist teachers and compel them to leave. Once out of job, the new rules will make it impossible to get another job in any new/old medical college.

4. It is assumed that the newly established colleges will get medical faculties. The shortage of medical teachers (including in non-clinical subjects) are very much real even now. In several instances, the positions are going vacant despite several rounds of placement advertisements and interviews. This is more so in rural, remote, under-developed or hilly areas, where most doctors don't want to go. The students will be deprived of teachers in such colleges. Currently, in these scenarios, the scientist teachers are carrying the most burden.

5. It is assumed that by selectively applying new rules to the new colleges, the quality of medical education will improve by ousting all scientist teachers. The new CBME curriculum will be applicable to all the medical colleges, both old and new. In fact, the number of students admitting to the MBBS course will be much higher in the current 542 medical colleges. The existing scientist teachers will continue in the established colleges for another decade or two until all the scientists are eventually flushed out of the system. The benefit of limiting scientists in the new colleges is negligible.

6. It is assumed that the currently employed scientist teachers will be unaffected by the new regulations. The current scientist teachers will be forced to stay in the same job because no medical college, new or old, will hire them anymore. They will be forced to work without promotion or pay hikes. The job insecurity will persist forever and their entire career will be spent on fearing termination. They could be exploited to any extent.

7. It is assumed that currently employed teachers in medical colleges under various stages of recognition will be unaffected by the new rules. As and when these colleges seek to increase their student admission, the new rules would apply. In such a scenario the current scientist teachers will be perceived as a liability. Therefore, those medical colleges that are eying to increase student admission in the foreseeable future will not regularize the current scientist teachers, resulting in their termination. 

8. Since the medical M.Sc courses were offered to the science graduate since the 1960s merely to create teachers in the non-clinical subjects, around 35 medical colleges continue to admit students for these courses. A career as a teacher in medical colleges is the prime reason why students opt for these courses. Currently, 3000-4000 students are pursuing the three-year courses. Their chances of employment are now completely wiped out. Similarly, hundreds of scientists are pursuing Ph.D. hoping for promotion or placements. Their career too would be over before it begins.

9. It is assumed that the medical teachers will be able to handle academics (teaching & practical demonstrations) and diagnostic laboratories all by themselves. In many colleges they are, but in many other colleges, it is the scientists who are jointly or mostly doing this. Not only these, but scientists are also contributing to the growth of scientific knowledge through research and publications. The contributions of the scientists must not be belittled. The fact the medical teachers are forced to undertake a course in Research Methodology, whereas the Ph.D. scientists have already gone through it in their Ph.D. curriculum. Such scientist teachers are better suited to be PG research guides.

10. It is assumed that by purging the scientists from medical teaching, the standards of education can be raised. This is similar to Hitler holding the Jews responsible for Germany's miseries and consequently purging them- "the final solution". The fact that premier central institutions such as AIIMS, JIPMER, PGI, etc continue to employ scientist teachers without any bias, is indicative that scientists are an integral part of medical education. The same is the practice in developed countries; 21% of teachers in US medical colleges are scientists. It is the golden rule in surgery that every attempt to save the body part must be undertaken before taking the easy but radical measure of amputation. Here, the NMC has gone straight for the amputation.



Thursday, February 20, 2020

Timeline of events regarding signatory role in diagnostic laboratories


Timeline of events regarding signatory role in diagnostic laboratories

Several lakhs of diagnostic laboratories (aka pathology laboratories) exist in India. Only a few are run professionally (Thyrocare, Dr Lal PathLabs, SRL, Apollo, Metropolis etc). The situation is worse in small cities and towns.

In order to maintain quality and standards, accreditation by agencies are followed. National Accreditation Board for Testing and Calibration Laboratories (NABL), a constituent body of Quality Council of India is the leading accreditation body in India. Only 1076 "medical labs", including those in the public sector, private sector, and medical colleges are currently accredited for various tests. Accreditation is a voluntary endeavor.

Diagnostic lab reports are routinely signed by doctors (MBBS/DCP/MD/DNB) and clinical scientists (medical M.Sc/Ph.D) in the specialties of Biochemistry and Microbiology. Pathology Reports are exclusively signed by the doctors with MD/DNB/DCP in Pathology.

January 2005 - The Executive Committee of the Medical Council of India (MCI) and the Adhoc Committee appointed by the Supreme Court approved the recommendation of its own ethics committee that persons with M.Sc. qualifications with or without Ph.D are entitled to independently or solely sign a medical Biochemistry report in a clinical laboratory.

August 2010 - In order to bring quality and accountability to the various types of clinical establishments (including labs), union health ministry enacted the Clinical Establishments Act (CEA) 2010. Health being a state subject, it is the prerogative of the states to adopt the central act, modify it or formulate their own. As of now, the central act is applicable only in ten states and six union territories.

May 2012- Rules under the CEA are framed. The National Council for Clinical Establishments is formed.

NABL had prescribed M.Sc qualification for signatory role in the diagnostic laboratories for accreditation in 2013 or earlier.

March 2014- National Council for Clinical Establishments under the Chairmanship of Director General of Health Services, Government of India in releases a draft on minimum standards for various categories of Clinical Establishments for implementation of the Clinical Establishments Act. Seeks feedback from the stakeholders. It was the first instance to evoke controversy. It excluded the clinical scientists from signatory role. NMMTA objects.

December 2015 -  NMMTA files a grievance with the Health and Family Welfare Department through an online portal. The grievance was forwarded to the MCI, which replied "matter is not under the purview of MCI" and the grievance was closed without addressing the issue.

July 2016- The National M.Sc Medical Teachers' Association (NMMTA) files a Writ Petition in Bangalore High against these guidelines. Union Health Ministry, NABL and MCI are respondents.

August 2016- NABL writes to the MCI asking for its opinion on the qualifications prescribed by it.

December 2016 - Union Health Ministry writes to NABL pressurizing it to fall in line with its guidelines. Seeks response.

January 2017 - NABL responds to the ministry; states that laboratory accreditation is voluntary; it grants accreditation in accordance with International stand ISO 15189. It stressed that the authorized signatories can be M.Sc (non-medical or Medical) with experience in working in clinical laboratory. It added that NABL assesses not just the qualification but also the knowledge and competence of personnel. It said it was awaiting MCI's reply to its letter.

May 2017- Union Health Ministry publishes draft guidelines through a gazette notification and seeks feedback from the stakeholders.

March 2017 - NMMTA members held a protest event "Delhi Chalo" at Delhi. It included dharna, procession, and press conference. Memorandum was submitted to MoHFW.

July 2017 -  MCI responds to NABL letter, replies stating "all lab reports to be signed/countersigned by persons registered with MCI/State Medical Council". NABL writes to all the accredited labs to comply with the MCI "order".

July 2017  -  NMMTA files an online grievance with the PMO, which forwards it to MoHFW. The ministry closes the grievance stating that as per its guidelines tests reports in the basic composite labs which are machine-generated or reports of basic laboratory test where interpretation is not required may be submitted by lab technicians/ Medical Laboratory Scientist.

August 2017 - A team of NMMTA office-bearers meet the top officers at PMO, NITI Aayog, and MoHFW as well as the union health minister and submit memoranda against the CEA guidelines.

August 2017 - Similar WP filed in Delhi High Court by another association of scientists- the Association of Clinical Biochemists and Microbiologists.

September 2017 - Delhi HC rules that the technical reports, which don't contain a diagnosis, can be signed by scientists with M.Sc qualifications. It states, "a technical report stating test results and indicating the analysis of samples without recording any opinion thereon, would not fall within the scope of medical laboratory reports". It also added "all test reports must necessarily bear a disclaimer to the effect that the report are strictly for the use of medical practitioners and pathologists and the reports are not medical diagnostic results".

November 2017 - The union health ministry convenes another meeting of the stakeholders on the issue of signatory roles in the diagnostic laboratories. NMMTA put forth arguments on the eligibility of scientists with medical M.sc qualification.

December 2017 - The Supreme Court while taking up a special leave petition of a dispute between Gujarat's pathologists and laboratory technicians ruled "We dispose of all these special leave petitions and other pending applications, if any, by taking a view that the stand of the Medical Council of India that Laboratory Report can be countersigned only by a registered medical practitioner with a post graduate qualification in pathology is correct". Scientists with M.Sc/Ph.D were not a party to this case and hence their qualification was not contested.

December 2017 - MCI writes to NABL and all the State Medical Councils to abide by the Supreme Court's ruling.

March 2018 -  NMMTA withdraws its writ petition in the Bangalore High Court frustrated over the delay caused by the respondents in filing replies.

March 2018 - MoHFW convenes a meeting to discuss the Supreme Court's judgment. NMMTA was not invited to the meeting. The subcommittee felt that this judgment overrides the Delhi HC's judgment.

April 2018 - NMMTA files a fresh writ petition in the Delhi High Court over the CEA guidelines for the diagnostic laboratory.

May 2018 - Union Health Ministry publishes the guidelines for diagnostic laboratories through a gazette notification and once again excludes clinical scientists with Medical M.Sc/Ph.D qualifications.

May 2018  - Association of Clinical Biochemists and Microbiologists files a writ petition in the Delhi High Court. Other petitioners join and all cases are subsequently clubbed together.

August 2018 - NMMTA organizes a protest event at Delhi. Its officers bearers meet officials of NITI aayog and MoHFW and submits a memorandum.

August 2018 - NABL convenes a meeting for several stakeholders and decides to stop prescribing eligibility norms for diagnostic labs.

October 2018 -  NMMTA submits MCI a dossier with several documents and evidence supporting the eligibility of scientists to interpret and sign lab reports. Also, the situation and data from other parts of the world are also provided.

December 2018 - NMMTA team visits MCI headquarters and meet BoG's chairman and secretary and requests them to consider the eligibility of scientists.

May 2019 - NMMTA office bearers met the Secretary, & Additional Secretary of MoHFW at New Delhi and requested the ministry to consider their qualifications. A dossier with a variety of documents and evidence was submitted for consideration.

August 2019 - Delhi High Court directs MoHFW to not only consider the representations made but also give hearing to one member of each of the petitioners before reaching a final conclusion.

August 2019: A letter was sent to the Under Secretary of the Ministry of Health and Family Welfare with objections & recommendations on the Human Resource guidelines for the three categories of the diagnostic laboratories. It was requested to include medical M.Sc (with or without Ph.D) as a recognized qualification for all the three categories of the laboratories.

September 2019 - MoHFW convenes another meeting of the stakeholders. NMMTA once again presents its eligibility and requests the ministry to consider M.Sc qualifications.

November 2019: Letter is written to the Board of Governors in supersession of MCI asking them to recognize the qualifications of M.Sc/Ph.D for signing lab reports. A letter is also written to the Union Health Minister asking the ministry to consider M.Sc qualifications for diagnostic labs under CEA.

January 2020 - MoHFW convenes another meeting of the stakeholders. NMMTA argues and gives written submission to include M.sc/Ph.D qualification.

February 2020 - MCI reverses its hostile position and restores the signatory authority to scientists with M.Sc/Ph.D qualifications and writes to MoHFW stating its position.

February 2020 - NMMTA has written to the MoHFW and urged to modify the CEA guidelines based on MCI's letter and provide eligibility to scientists with M.Sc/Ph.D qualifications in Microbiology & Biochemistry in all the three categories of labs to interpret and sign lap reports.

February 2020 – MoHFW updates its human resource guidelines on diagnostic laboratories through a gazette notification wherein signatory grants are given to persons with M.Sc in Medical Microbiology & Medical Biochemistry in all the three categories of labs, although Ph.D is required for medium and advanced labs. Also, the scientists can’t provide any diagnostic opinion.