This webpage shares our 10 year long, and ongoing, struggle with the National Medical Commission (NMC), formerly the Medical Council of India (MCI), to obtain registration for a US trained doctor to practice medicine in India.
Medical schools in the United States offer two medical degrees, namely Doctor of Medicine (MD) and Doctor of Osteopathic Medicine (DO). These two degrees are legally and professionally fully equivalent and practically indistinguishable. The MCI has registered US trained MDs, but not DOs. The Indian medical law makes no distinction between MDs and DOs, and there is no reason to not register DOs.
This webpage (and an older version which tells the story from 2012 to 2015) is a chronicle of our efforts for getting registration for a US trained DO to practice medicine in India. We want that American DOs in India be treated legally equal to their American MD counterparts, consistent with how DOs are treated in the US, Europe, and several other countries.
This story raises several issues. It highlights inefficiencies of the Indian bureaucracy and the slowness of the courts, but importantly, it shows how as a country we are wasting opportunity knocking at the door. Training a doctor takes plenty of resources and not allowing US trained doctors to practice in India is not in the country's interest, especially when Indian trained doctors continue to migrate to the US and other high-income countries.
This webpage also tells a personally story -- of patience, perseverance, and hope.
There are two medical degrees awarded by medical schools in the US. They are called Doctor of Medicine (MD) and Doctor of Osteopathic Medicine (DO). Both DO and MD are professional degrees for physicians and surgeons. DO and MD graduates have equivalent rights, privileges, and responsibilities, and both DO and MD physicians are licensed to practice the full scope of medicine and surgery in all fifty states in the US. Medical training for a DO and an MD is virtually indistinguishable; the only notable difference is that DO doctors learn, in addition to what their MD colleagues learn, a technique called Osteopathic Manipulative Treatment (OMT) which involves hands-on manipulation of the human musculoskeletal system.
Several US MDs have been registered to practice medicine in India by the MCI. However so far DOs have not been registered by MCI. We (Sonali Shah, a US trained DO) applied for medical registration to the MCI in 2012.
After years of efforts including intervention from the Delhi High Court, in Sep 2019, MCI recognized the Doctor of Osteopathic Medicine or DO degree from the US to be equivalent to the MBBS of Indian Medical Schools. At that time, it asked us to demonstrate the equivalence of Sonali's specialization (postgraduate training) in Obstetrics and Gynecology to that obtained by a US MD. As per the law, Sonali's postgraduate training needs to be recognized before she can be registered to practice. We submitted all requested documents in December 2019 and have sent several reminders to the National Medical Commission. We are waiting to hear from them.
Important events in the story so far are listed in the section "Timeline of Events" below.
Sonali Shah did her undergraduate studies at the University of Michigan, studied medicine at Michigan State University and did her residency in Obstetrics and Gynecology at Philadelphia College of Osteopathic Medicine. Anirban Hazra did his undergraduate studies at IIT Bombay, PhD at Princeton University and postdoc at Penn State University, all in Chemistry.
We met in the US and eventually got married. We both are stubbornly committed to living and working in India. Sonali is deeply sympathetic about women who cannot afford healthcare and wants to use her expertise as a physician to help. She wants to be a doctor for the women in India who don't get good healthcare, and that is the reason she wants to move to India.
We planned to move to India around 2011. That is when Anirban took up a faculty position at the Indian Institute of Science Education and Research, Pune. The plan was that Sonali would spend a year or so practicing medicine in the US while completing the formalities to get registered with the MCI to practice in India before moving here. We applied for registration with the MCI in 2012, but we have still not received it.
In the meanwhile, we have been staying on different countries for almost 9 years, with brief stints where we have been able to spend a few months together. Sonali has been committed to practicing medicine throughout and she has largely worked with poor and under served women in the US in her practice. Anirban has taught, performed research and guided PhD students in India.
We are continuing our struggle based on the premise that the truth ultimately prevails and honest efforts succeed. We have to see how these ideals play out in this case.
The delay by the National Medical Commission (previously MCI) to give Sonali registration to practice, is likely due to an incorrect assumption about her medical degree, DO. This is explained below.
Sonali's medical degree is Doctor of Osteopathic Medicine or DO, which in the United States, is one of the two degrees (the other being Doctor or Medicine or MD) that medical schools in the US give. Medical training for an MD and DO is virtually indistinguishable; the only notable difference is that DO doctors learn, in addition to what their MD colleagues learn, a technique called Osteopathic Manipulative Treatment (OMT) which involves a set of hands-on techniques to diagnose, treat and prevent illness or injury. In the US, DOs and MDs are completely equivalent.
In contrast to the US, in the rest of world the term "Osteopathy" refers to a type of alternative medicine (like Traditional Chinese medicine or Ayurveda) that emphasizes physical manipulation of the body's muscle tissue and bones.
MCI is very likely mixing up a US DO physician who practices modern scientific medicine with an Osteopath who practices a type of alternative medicine.
That said, taking 8 years for a Central Government body to ascertain some relative simple and well established facts is simply unexplainable.
We have provided documentation from several credible authorities confirming that DOs and MDs are considered legally equivalent to practice medicine in the US. These authorities include:
We have also provided a copy of the US Federal and State Medical Laws confirming the legal equivalence of DOs and MDs to practice medicine in the US.
Indian law is very clear on allowing US trained physicians to practice in India
The law regarding registration of foreign medical graduates can be found on the National Medical Commission webpage.
Point number (4) on this page is most relevant for Sonali and is quoted below:
"(4) Provided further that a person seeking provisional or permanent registration shall not have to qualify the Screening Test if he/she holds an Undergraduate medical qualification from Australia/Canada/New Zealand/United Kingdom/United States of America and the holder thereof also been awarded a Post Graduate medical qualification in Australia/Canada/New Zealand/United Kingdom/United States of America and has been recognized for enrolment as medical practitioner in that country. "
Sonali holds undergraduate and postgraduate medical qualifications from USA and has been recognized for enrollment as a medical practitioner in the USA. She thus qualifies for permanent registration.
There are several US trained physicians, all holding the MD degree, who are currently registered to practice in India (A list was provided by the MCI in response to an RTI application filed in 2015). One of them is Shriram Madhav Nene who happens to be the Bollywood actor Madhuri Dixit's husband. Unlike MDs, there is no precedence of a US physician with the DO degree being registered.
In the US, DO and MD physicians have equivalent rights, privileges, and responsibilities, and both DO and MD physicians are licensed to practice the full scope of medicine and surgery in all fifty states in the US.
Clearly if DO and MD are equivalent in the US, and if MDs have been given registration to practice in India, then DOs should also be registered to practice in India.
So one may ask: If things are so clear, why is the NMC not getting it? The only answer we can think of is that they have not applied their mind to this. They have not considered the documentation we have provided or done their independent evaluation to ascertain that DOs and MDs are indeed equivalent in the US.
In September 2019, MCI recognized the DO degree to be equivalent to the Indian MBBS degree. This is the first item in the minutes of the meeting of the Board of Governors on 21st August 2019 at the MCI office in New Delhi.
At that time, MCI requested documentation from us to establish the equivalence of the DO postgraduate specialization with that of an MD specialization. We provided this information in December 2019 and are waiting for the NMC to respond.
As per the law, both undergraduate and postgraduate medical qualifications from USA have to be recognized before Sonali can be registered to practice.
We have send several reminders since then by post and through the complaints section of the NMC webpage.
We would appreciate if you could share this story as much as you can. If you know of news outlets who can publish this story, please put us in touch. If more people know and this story receives some attention, hopefully the National Medical Commission will move faster and do what is the right thing to do.
As you would have realized if you have read the sections above, the legal framework for providing Sonali registration is already in place. All we ask is for the bureaucracy to do its job. If you can bring this story to the attention of any of the officials who can make a difference, we will really appreciate it.
If you are a US trained DO and are interested to practice in India, please get in touch with us so that we can share notes and work together. We want to ensure that DOs are not discriminated against because of their degree and can start practicing medicine in India, conforming with Indian law.
Email: drsonirban@gmail.com
Here is a timeline of the most significant events starting from our application for registration to MCI in 2012.
Nov 2012: Sonali Shah, DO applies to MCI for medical registration.
Jun 2013: MCI rejects the application citing an incorrect section of the law.
Jul 2013: We write to MCI pointing to the correct section of the law and provide documentation of the equivalence of the DO and MD degrees.
Jul 2014: MCI replies that "the matter is being placed before the Registration and Equivalence Committee at its meeting scheduled to be held on 24th June [sic]".
Sep 2014: MCI responds to an RTI application requesting the minutes of the above meeting saying Sonali is not eligible for registration.
Jan 2015: Request to MCI for a personal hearing to present the case and all documentation.
Jun 2015: MCI responds saying Sonali Shah's qualification cannot be considered for registration.
Dec 2015: We file a petition in Delhi High Court challenging MCI's decision of refusing Sonali Shah's application for registration [Reference of writ petition: W.P.(C). 11443/2015].
December 2015: Delhi High Court orders MCI to respond and us to file a rejoinder if needed.
Apr 2016: MCI responds to Delhi High Court reiterating the contents of its earlier letters.
Apr 2016: We file a rejoinder stating that the MCI has not attempted to counter any of our documentary evidence or arguments about why Sonali Shah should be registered.
Jul 2016: Delhi High Court orders that the counsels for the parties file brief synopsis of their submissions not exceeding three pages within four weeks.
Aug 2016: We file a brief synopsis as ordered by the court.
Feb 2017: Delhi High Court orders MCI to file their brief synopsis.
Mar 2018: Delhi High Court hears the matter.
Jul 2019: Delhi High Court hears the matter and outlines the case in its order. It orders us to make a comprehensive representation to MCI with all relevant documents, and MCI to take an informed decision before the next hearing.
Jul 2019: We submit a comprehensive representation to MCI along with 19 supporting documents.
Sep 2019: MCI recognizes the Doctor of Osteopathic Medicine or DO degree from the US to be equivalent to the MBBS of Indian Medical Schools. Further MCI asks us to demonstrate the equivalence of Sonali Shah's specialization (postgraduate training) in Obstetrics and Gynecology to that obtained by an US MD.
Dec 2019: We submit documentation to demonstrate the equivalence of Sonali Shah's specialization training in Obstetrics and Gynecology with that of an US MD.
Jan 2020 till date: We are waiting to hear from the NMC after we submitted the requested documents in Dec 2019. Meanwhile, the date of hearing at Delhi High Court which was fixed on on 11/May/2020 has been
postponed (1) to 8/Jun/2020,
postponed (2) to 29/Jul/2020,
postponed (3) to 23/Sep/2020,
postponed (4) to 27/Nov/2020,
postponed (5) to 3/Feb/2021,
postponed (6) to 22/Mar/2021,
postponed (7) to 13/May/2021,
postponed (8) to 29/Jul/2021,
postponed (9) to 15/Sep/2021,
postponed (10) to 12/Nov/2021,
postponed (11) to 5/Jan/2022
because of the COVID-19 pandemic.
We have tried to contact NMC multiple times after we sent the documents, by letter and through the complaints link on the NCM webpage, but have not heard from them. Here is one such letter sent on Feb 5, 2021.