THE “NMC FOREIGN MEDICAL GRADUATE LICENTIATE REGULATIONS 2021” AND ITS IMPACT ON INDIAN STUDENTS ASPIRING TO STUDY/ STUDYING IN THE PHILIPPINES (DOCTOR OF MEDICINE).
The New FMG Licentiate Regulation (NMC Regulations 2021) was notified in the Gazette of India on the 18th of November 2021, becoming effective on the same day bringing out the following questions:
- Will the Duration of the Medical Course in the Philippines be affected by the New Regulation?
- Are two separate internships (one in the same foreign institution & the Compulsory Rotating Medical Internship (CRMI) are required after graduation abroad?
To Answer the above questions, we will have to look into the following regulations of the National Medical Council (formerly Medical Council of India) in addition to the (Foreign Medical Graduate Licentiate) NMC Regulations, 2021:
- Regulations on Graduate Medical Education 1997, (Amendment) 2019 (4th November 2019). (For MBBS course starting from academic year 2019-20 onward)
- National Medical Commission (Compulsory Rotating Medical Internship) Regulations, 2021
Check related Article on “India Today” here.
Question 1: Will the duration of the Medical Course in the Philippines be affected by the Section 4 (a) (i) of the New Regulation?
“Section 4 (a) (i) undergone a course leading to foreign medical degree with minimum duration of fifty-four months;”
The current duration of the Primary Medical Qualification (hereafter PMQ) in the Philippines (Doctor of medicine, MD) is 4 years or 48 months after an undergraduate degree (commonly known as premed)
Currently the duration of premed is 18 months, making it 66 months to complete the entire program
Going forth, the NMC requires the course, curriculum, clinical training equivalent to that of the MBBS of India.
“Schedule – I Section 1. The guiding principle for licensing a foreign medical graduate to practice in India is to ensure that the Foreign Medical Graduate fulfills the requirements of education and training equivalent or commensurate with that of an Indian medical graduate”
Schedule – I Section 2. Eligibility for primary medical qualification in a country outside India: (i) Duration of course and training in subjects leading to primary medical qualification: (a) Any person who pursue the foreign medical degree should have undergone a course of theory, practical and clinical training equivalent to Bachelor of Medicine and Bachelor of Surgery (MBBS) of India;
According to the requirement of Schedule 1 Section 1 & 2, The total duration of the foreign medical qualification must be equivalent to “theory, practical and clinical training equivalent to” MBBS of India which is governed by “Regulations on Graduate Medical Education 1997, (Amendment) 2019 (4th November 2019)” and duration of the course is 4.5 years or 54 months. Therefore, the primary medical qualification obtained from a foreign country must be 54 months as stated in Section 4 (a) (i).
The Philippine Commission on Higher Education (CHED) requires the PMQ to be of minimum 4 years in duration but does not restrict the maximum duration and additional subjects to be included. There is precedence where the 4-year MD course had been extended to 4.5 years for some graduates intending to practice in California, USA to include additional subjects required by the Medical Board of California. A similar approach will be followed to meet the requirement of the National Medical council of India.
So yes, the total duration of the MD course will be required to be 4.5 years. But the total duration of the course which is 66 months will not have to necessarily change. It is possible by the university/ college to offset the additional 6 months required during the MD program by decreasing the same duration from the Premedical course. Therefore, when applying for admission to Medicine in the Philippines, Students must confirm if provisions are available at the college they are applying to.
Question 2: Are two separate internships (one in the same foreign institution & the Compulsory Rotating Medical Internship (CRMI) are required after graduation abroad?
The wording used in the Regulation is quite tricky and maybe difficult to understand. To clarify we will also be looking into the additional two regulations as mentioned earlier.
We need to read the title of Schedule -I Section 2 (i) “Duration of course and training in subjects leading to “PMQ”. Section 2 (i), (a) and (b) lists the required course structure and the clinical subjects required during an internship of twelve months. The title does not say that “after “PMQ but “leading to”. It is clear from the title itself that internship requirement stated here is the clinical training obtained during the course and not after. We will confirm this again.
Now, Section 2 (ii) “Content of course or Training leading to primary medical qualification” says, (a) The course and internship or clinical clerkship shall commensurate with the MBBS course of India in accordance with the Regulations on Graduate Medical Education, 1997 and subsequent amendments thereto, and shall include the subjects mentioned therein as are duly recognized by the Commission under sub- section (2) of section 61 of the Act;”
The above section reconfirms that the PMQ should be equivalent to the MBBS Course structure and Duration. The (amended last in 2019) Regulations on Graduate Medical updated in 2019 updates the curriculum of MBBS for all Medical Colleges in India from Academic Year 2021- 21 to “Competency based learning would include designing and implementing medical education curriculum that focuses on the desired and observable ability in real life situations.” This means increased weightage to clinical training from first year. It also requires Clinical Posting in the college hospital from the 3rd year of studies. This is also known as Clinical Phase/Third Professional (Part 1 and 2 for 2.5 year) as listed in table 8 of Section 8 of the above regulation. This clinical training is also called as Junior Internship or Clinical Clerkship as stated in Section 9.5 “Learner-doctor method of clinical training (Clinical Clerkship)”
The list of subjects in Section 2(i) (b) of the FMG Licentiate Regulations, is the same as the list of clinical subjects in Section 8 Table 8 of the “Regulations on Graduate Medical education” which is a part of the 4.5-year MBBS course. This clinical training during the MBBS course or PMQ of a foreign institution is also sometimes identified as Internship, Junior internship, clinical training or clinical clerkship and this is distinct from and must not be confused with the CRMI which is to be completed after (Schedule – II Section 1 (b) (1.) The Final MBBS Examination of various Universities or institutions…”
The National Medical Commission (Compulsory Rotating Medical Internship) Regulations, 2021 Section Likewise, the National Medical Commission (Compulsory Rotating Medical Internship) Regulations, 2021 Schedule – II Section 2 states, “Foreign Medical Graduates (a) All Foreign Medical Graduates, as regulated by the National Medical Commission (Foreign Medical Graduate Licentiate) Regulations, 2021, are required to undergo internship at par with Indian Medical Graduates if they desire to seek Permanent Registration to practice Medicine in India. (i) All Foreign Medical Graduates, unless otherwise notified shall be required to undergo CRMI at par with Indian Medical Graduates after the National Exit Test Step-1 after NExT becomes operational.”
The CRMI (which is also know in other countries as Post Graduate Internship) is compulsory to both Indian Medical Graduates (IMGs) as well as FMGs after the completion of the Primary Medical Qualification and the National Exit Test (NeXT) Step -1. And is distinct from the internship/ clerkship required during the primary medical qualification. NMC will post FMGs to different Medical Colleges or Institutions through counseling or seat allocation.
The FMG Licentiate Regulation Schedule – I Section 2 (iii) Location of medical college or institution and administration of the course or training: States “The entire course, training and internship or clerkship shall be done outside India in the same foreign medical institution throughout the course of study and no part of medical training and internship shall be done in India or in any country other than country from where the primary medical qualification is obtained.”
The above section also reiterates the internship stated as required as part of the PMQ is clerkship. And the entire course must be completed at location in the institution abroad which includes a internship or clinical clerkship.
It’s clear that NMC requires the Primary Medical Qualification acquired abroad must be commensurate with that of MBBS in India in course, duration, and clinical training. The duration is 4.5 years for MBBS including the clinical postings. It is also clear that the clinical training obtained during the final year of the Doctor of Medicine is equivalent to the clinical postings/ clinical clerkship of the MBBS course in India and the regulation does not mean a separate internship is to be completed after the graduation. Only the CRMI is required after graduation which is the same for both IMGs and FMGs.
- The total duration of the Philippines Medical Program will not change or increase.
- There is no need for two internships.