With a proactive concern for patient safety and quality of care, The Indian Medical Council Act 1956 prohibits a person other than a medical practitioner enrolled on a State Medical Register or the Indian Medical Register (IMR) to practice in India. Every New Medical Graduate must Register with the respective State Medical Council Register and is then allocated a registration number. With that Registration Number, the Doctor can Practice anywhere in India.
As it works Currently, apart from MCI’s National level Indian Medical Register (IMR), different state councils have their own medical Registers. The MCI then compiles data received from state medical councils.
Healthcare being a State Subject, a degree of latency creeps into the system. However, when a Doctor migrates to any other part of India, he/she often overlook to update the State Register and also similarly about recent Qualifications, Degrees, Certifications, etc.
This makes for high chances of duplication of data of Registered Doctors between the various registers. This makes the compilation and de-duplication exceedingly difficult because of the administrative dependencies which are beyond the MCI’s control.
There are also then, several unqualified or fake Doctors working in the country without proper qualifications and/or registration with IMR or State Registers. MCI has no way of tracing, tracking, and weeding out such practitioners from a wide variety of genuine Doctors working in the Country.
On the other hand, the patient also has no way of differentiating between genuine and fake doctors.
With the adoption of Universal Healthcare as a Policy in 2017, increasingly healthcare services are going to be paid for by Insurance or state programs. From a Health Insurance perspective, it becomes exceedingly difficult to establish the veracity of the Claim. The liability lies on the payer whereas there is no authentic single source of truth.
Similarly, in the event of medico-legal cases, it is hard to trace back from the prescription to build a legal case. A wide variety of degrees appear on Doctors’ Prescription pads. MCI lacks a master list of accepted Qualifications including Indian and International Degrees/Diplomas/Certificates. Hence there is no way of finding out if these Degrees are genuine, equivalent international qualifications, derecognized, or even completely fake!
There are many use cases where the sanctity and harmonization of the Registers come into question. These are some of the practical detractors to the authenticity of data on the Medical registers.
Doctor has Migrated/Died or left the practice:
- Migrated Doctor may Re-Register in the other State Register at the time of Renewal. Though a procedure exists about taking a No-Objection-Certificate from the previous State Register; but it is not very strictly followed. There is a possibility of Doctor getting counted in both Registers.
- When a Doctor dies, the Register is usually not updated with a Death Certificate.
- When a Doctor has Left the country, the Register is usually not updated because usually it is not known if the migration is temporary or long-term or permanent.
- When the Doctor has left Practice due to any reason e.g. Administrative job, Higher Education, Change of Sector, etc.
Name Change or Mismatch:
- The Register is usually not updated when Doctor Changes Name E.g. Marriage, Religious reasons, etc. This results in a Name mismatch between IMR Register and the changed Government IDs.
- The Register is usually not updated when Doctor Name Spellings is changed e.g. Family, Social or Numerology reasons, etc. This results in a Name mismatch between IMR Register and the changed Government IDs.
- Name Mismatch between Degree, Internship Certificate, and Registration. Only possible to check at the time of first Registration, later it is very difficult to harmonize.
- Demographics Mismatch between Degree, Internship Certificate and Registration. Only possible to check at the time of first Registration, later it is very difficult to harmonize.
Degrees and Specialisations
- When a Doctor attains a Specialized/ Super Specialized Degree or Certificate, it is usually not updated in the Register because there is no real mandate to do so.
- Equation of Foreign Degrees with Indian Medical Degrees e.g. MD from US equivalent to MBBS or MD or DM? DNB equated to MD or DM? Exceedingly difficult for MCI to decide if the Registration should be granted or not.
- Equation of Degrees in India e.g. Ph.D. Clinical Pathology without MBBS, or MD Pathology? MCI usually does not grant Registration for such cases. Though they may be equated Internationally. Will the documents signed by such professionals be recognized e.g. Genetic Testing Reports.
- University Mismatch – e.g. Individual Universities in Maharashtra no longer gives Medical Degrees. Nasik University has taken over that function and gives Degrees across all Medical Colleges in Maharashtra. Only possible to check at the time of first Registration, later it is exceedingly difficult to harmonize.
- If the Doctor has lost the Graduate Medical Degree. It is hard to justify the details mentioned in the IMR Register. The only way is to ask for a Duplicate Degree from the University, which is also a very long process and is usually not pursued.
- Medical Graduates of States having special status were given Provisional Registration to Practice pending the legal decision on the State – e.g. J&K, Arunachal, Sikkim, Pondicherry, Goa. Later there is no way of revalidating the data before regularizing the Registration. So the old Registrations continue to languish.
- How do you split the Medical Graduates between States that were split or newly carved out – e.g. Goa, Uttarakhand, Chhattisgarh, Jharkhand, Telangana. Later there is no way of revalidating the data before regularizing the Registration for the New State. So the old Registrations continue to languish.
- Medical College recognized by the State but not by MCI Govt of India. State Register gives the Registration, but MCI does not recognize it.
- Medical College derecognized by MCI Govt of India. State Register gives the Registration, but MCI does not recognize it.
- Provisional Registration is granted in cases of Emergency e.g. Disasters and Epidemics. This should be withdrawn after the Emergency. However, no clear process has been defined for this purpose.
Foreign Degrees and Passports:
- Foreign Passport but studied from Medical College in India. State Register gives the Registration though the foreign national will not practice in India e.g. Nepal, Bhutan, Sri Lanka, ASEAN, Africa, West Asian countries.
- Indian Citizen but studied from Foreign Medical College e.g. Russia, China. MCI Register gives the Registration after an examination. Though many of these Indian nationals migrate out and do not practice in India.
As per newspaper reports, In 2017 the Medical Council of India had directed all states to provide a unique permanent registration number (UPRN) to every Doctor Registered in their jurisdiction.
MCI had envisaged a digital platform. The MCI initiated the process of implementing e-governance through digital mission mode project (DMMP); one of the ambitious modules under DMMP project is the implementation of new IMR through unique permanent registration number generation for each Registered Doctor in India, the MCI said in a letter sent to the Indian Medical Association (IMA).
On implementation of the system, the existing registration numbers of the Doctors shall be migrated to a standard system of UPRN. Doctors shall also apply online for additional qualification registration in IMR like Postgraduate, super-specialty etc. After commissioning, Doctors can use the system to make online applications for services like issue of certificates etc.
The initiative will put an end to the duplication of Doctors Registered by various state medical councils as well as the Indian Medical Register under the MCI and provide a clear picture of how many Doctors are practicing in India. A UPRN number is to be generated for the over one million Doctors recorded in the IMR.
We will get to know about the actual number of Doctors and the list of medical specialists practicing in the country. We will have all the details about a Doctor, ranging from addresses to personal details, and Specializations. Currently, we seek information about Doctors from the state medical council. Once all the Doctors are given a separate code or UPRN, it will become amazingly easy to trace them in a case of medical emergency, epidemics, disasters, negligence, or second opinions for their expertise.
However, from 2019 the MCI role has now been taken over by the National Medical Commission [NMC]. The handover of charge by MCI BoG to the NMC is awaited.
Para 31 of The NMC act of 2019, mandates it to ensure electronic synchronization of National and State register in such a manner that any change in one register is automatically reflected in the other register 
Fortunately, this can easily be accomplished by leveraging the MDDS recognized in the National Digital Health Blueprint, 2019. This would make it possible for the IMR to evolve into a single-source-of-truth and be looked up appropriate stakeholders.
Recent events like the COVID 19 Pandemic have brought the vital role that Telemedicine and similar technologies can play sharply into focus. Para 32 of the NMC act also conceives a role for a limited number of Community Health Providers to work under the supervision of a medical practitioner.
These emerging trends make the authenticity of the medical register critical to healthcare delivery in a safe, accessible and equitable way.
Architectural Approach for Doctor’s Registry
1. Federated Architecture for Doctor’s Registry
As per NMC Act, the Ethics and Medical Registration Board shall maintain a central National Medical Register (aka National Doctor’s Registry) containing the set of minimum data elements for identification and credentialing of a licensed medical practitioner (aka provider) practicing anywhere across the country. To enable this a federated architecture design is recommended for the National Doctors Registry that it can be kept updated at all times and will not have a single point of failure.
The National Medical Register will be responsible for allocating a Unique National Provider Identifier (NPI) to every new provider that gets registered through a state medical council or directly through the central medical register by performing de-duplication and validation of a new provider record. This unique identifier will remain unique for the lifetime of a provider.
Every state medical council will then use this Unique Provider Identifier to maintain and regularly update the state register (aka as Provider Directory at the state level) for the providers registered within that state with not only the registration details but also with additional information about their credentials, employment, training, qualifications, CMEs attended and active status etc. There will be an electronic mechanism to update the central register with the data from the state level provider directories for new provider registration as well as for any information update through the state register. Lookup the details in ANNEXURE – 2.