Context

For many decades, the former MCI was accused of corruption and mismanagement, but also proved to be resistant to reform.8 The formal process of formulating the NMC began in 2016 but faced severe resistance from many quarters, including medical students, medical colleges and professional associations.9 10 In the meantime, when the NMC Bill was pending in Parliament, the existing MCI was superseded by a government-appointed Board of Governors (BoG) in 2018.11 The NMC Act was ultimately approved by the Parliament in 2019 (table 1).

The responsibilities of NMC not only include those of the existing MCI but go beyond to include the realm of fee structures for private colleges and common exit examinations, as well as more rigorously regulating ethical practice. The NMC has also veered into an unknown and contentious territory, by including in its mandate the training and licensure of a new cadre of non-physician clinicians, called community health providers (CHP) (table 2). The NMC is mandated to be functional from the time the central government issues a notification. Currently, while some members of the NMC have been nominated and the chairperson is appointed, the institution is yet to be functional.3 12 In the meantime, the interim BoG continues to make decisions in the realm of medical education.11

The past decade has also been highly formative for the overall Indian health sector, resulting in expanded financial protection schemes for the poor while also promoting privatisation. The most recent National Health Policy in 2017 emphasises the need to align the private sector with public health goals and suggests strategic purchasing from the private sector.13 Many recent government health policy initiatives have included measures that strengthen commercialisation, for example, having ‘viability gap funding’ for private hospitals, and setting up private medical colleges in partnership with public district hospitals.14 The most significant reform in recent times is ‘Ayushman Bharat’ (Long live India) which started in 2018 and includes a publicly financed health insurance scheme for the poor for availing secondary and tertiary care services, and health and wellness centres for provision of primary care.15 What is less clear is how these reforms in the health sector and in medical education cohere. We posit that rather than emphasising an approach driven by primary care, health equity and social justice, the current policies together promote medicalisation and corporatisation of healthcare. Additionally, rather than constituting an accountable, inclusive and transparent governance structure, current policies could result in centralisation of authority that excludes key constituents.

Medicalisation

It is evident that recent reforms in healthcare delivery have shifted the focus to providing curative medical care, at the expense of preventive and promotive care.16 A key constraint facing both the public and private sectors in such a medicalised model is the availability of doctors.17 Therefore, it is even more intriguing to note that after superseding the MCI in 2018, the intermediate BoG started a series of reform in medical education, targeted at increasing intake of undergraduate medical students and more importantly, students training for postgraduate studies in medical specialties.18 Interestingly, the NMC Act explicitly calls for an expansion in Family Medicine postgraduate programmes, a development that could support efforts to expand primary care; however, it is unclear how stakeholders plan to proceed on this front.3

Broadly, the reforms put forward by the NMC comprised relaxing the existing norms, thus resulting in significant increase in the student intake and eventually the number of general and specialist doctors. However, as the number of government medical colleges was insufficient to undertake the desired increase, the focus in privatisation has raised several questions around equity and quality.19 The rush for expansion of private medical colleges will also restrict access to those who can pay for higher education or will put significant financial burden on other families. Evidence also shows that the quality of medical education, particularly in the private sector, is variable, so there are questions around the skill and competencies of the physicians so trained.20

Corporatisation

The process of privatisation of medical education in India started in the early 1980s and the first ever health policy in India, the National Health Policy 1983, also promoted private sector for curative care, which also incidentally proved incredibly challenging to regulate effectively.21 When the production of medical professionals increased, resource-constrained public systems struggled to provide employment opportunities to medical graduates, particularly specialists.6 In the current privatised and increasingly corporatised health system in India, medical professionals are heavily incentivised to work for the private corporate sector, a sector which has thus far not actively supported primary care, particularly for the poor. This may result in even bigger challenges around reprofessionalisation of medicine and medical professionals.6 Recent decisions by the BoG have allowed profit-making companies and even consortium of companies to start medical colleges, suggesting an emerging corporatisation of medical education too along with overall healthcare system.22 Moreover, India is the only country where two parallel systems for medical specialisation are running.2 The National Board of Examinations (NBE) is a separate body which runs specialty and superspecialty trainings, including in non-academic corporate hospitals. Earlier drafts included the NBE within the NMC, but the Act is now silent on the incorporation of NBE courses.

Centralisation

These trends of medicalisation and corporatisation are enabled and reinforced by the centralisation of governance of regulatory institutions, seemingly excluding voices that could bolster calls for primary care. The composition of NMC is overwhelmingly dependent on selection and nominations by the central government. Such governance structure implicitly puts the central government in the driving seat (table 2).3 Similarly, the interim BoG is headed by a member of a central government think tank and almost all other members are from central government institutions.23 It is interesting to note how centralisation is pushed in order to expedite the reforms in medical education to support medicalised and corporatised model of UHC. Governance structures that involve practitioners working in rural areas and in primary care would be important in developing holistic, equity-driven reforms.

Implications for public health and health systems

The focus of NMC reforms is ostensibly to reform the medical education sector. Nevertheless, how NMC addresses its responsibilities has significant implications for public health and health systems in India. First, the paradigm shift in approach to UHC with a privatised model may further aggravate the scarcity of human resources for health (HRH) in the public sector health systems. Second, the current inequity in distribution of HRH may worsen if policies continue to prioritise secondary and tertiary care, which are often located in periurban or urban centres. Third, the concept of CHP as envisioned in recent health policy is innovative but if not implemented in the right spirit and manner may further fragment the already fragmented primary healthcare systems.

The NMC is envisaged to be a major reform but it remains to be seen how the institution will address the inefficiencies and issues of corruption which was associated with the erstwhile MCI. The inefficiencies, variable quality of education and corruption, especially in the private sector will require more effective and robust regulation, free of all conflict of interests. The well-intentioned policy of regulating the fee by private medical institutions will also require test of time, especially with more privatisation, corporatisation and centralisation. The NMC Act is also silent on how the influence of private corporate sector, including pharmaceutical industries, will affect medical education and healthcare services. More importantly, how will the NMC deal with two opposite paradigms of facilitating production of more doctors and specialists, and CHPs? Remarkably, the NMC has also provisioned a specialised medical ethics and regulation board but the real challenge will be to regulate the relationship between the industries, such as the pharmaceutical industry, and medical practitioners, and its influence on ethical practice.