Public health experts have raised serious concerns over the National Medical Commission’s (NMC) decision to withdraw the Maintenance of Standards of Medical Education Regulations, 2023. Critics have warned that the move removes specific penalties for violations, potentially weakening oversight of medical colleges, including checks on faculty strength and infrastructure.
While the requirement for medical colleges to submit Annual Disclosure Reports (ADRs) remains in force under the National Medical Commission Act, 2019, the withdrawal has removed the specific penalty framework that was prescribed under the 2023 regulations. The regulations had originally been notified on September 19, 2023, under Sections 10, 24, 25, and 57 of the NMC Act, 2019, read with Section 21 of the General Clauses Act, 1897. The same provisions were used to withdraw them.
Although medical colleges must still file their ADRs, experts contend that filing a report is not equivalent to having it verified. Under the previous framework, colleges reported their own faculty strength and infrastructure while facing specific penalties for false or deficient declarations, alongside provisions for verifying infrastructure, faculty availability, and student feedback. Without these specific rules, experts argue there is less deterrence against overstatement and fewer processes to catch discrepancies.
A doctor in a Central government hospital in Delhi stated that colleges can now write anything in their reports without immediate structural deterrence. Babu KB, an RTI activist and ophthalmologist from Kerala, pointed out that the National Medical Commission Act still empowers the Medical Assessment and Rating Board to act against colleges that fall below minimum standards. However, he noted that enforcement is not legally impossible, but questioned how actively those powers will be used without a dedicated penalty framework.
Experts also noted that physical inspections had already become less frequent for processes such as applications to add seats in existing colleges, making it harder to catch issues like "ghost faculty" or claimed infrastructure that does not exist. Critics have further alleged that the regulator appears to prioritize increasing medical seats over ensuring adequate faculty and infrastructure.
Responding to these concerns, Abhijat Seth, Chairman of the National Medical Commission, stated that the de-notification does not dilute regulatory oversight or medical education standards. He clarified that the decision is a measure of regulatory rationalization intended to remove overlapping procedures, ensure clarity in statutory functions across different Boards, and simplify compliance requirements for medical colleges.
The NMC Chairman emphasized that the requirement for Annual Disclosure Reports remains mandatory. Medical colleges will continue to submit annual disclosures concerning faculty, infrastructure, clinical facilities, patient load, and other prescribed parameters. According to Seth, these disclosures remain available for scrutiny and verification through the statutory assessment and inspection mechanisms of the Medical Assessment and Rating Board, making suggestions that annual disclosures will become unverified claims misplaced.
"Regulatory changes in critical sectors like education and healthcare require a delicate balance between easing compliance for institutions and maintaining strict accountability. When specific penalty frameworks are removed, it places a heavier burden on regulatory bodies to proactively verify disclosures. Ensuring transparency and robust oversight is essential to maintain quality standards, especially in professional education where infrastructure and faculty integrity directly impact public outcomes." — Dr. Shishir Gupta, Founder & CEO, StartupLanes
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