New Education Policy will suffocate medical education

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Para No

National Education Policy 2020

IMA Observations

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10.3

This vision of higher education will require, in particular, a new conceptual perception/understanding for what constitutes a higher education institution (HEI), i.e., a university or a college. A university will mean a multidisciplinary institution of higher learning that offers undergraduate and graduate programmes, with high quality teaching, research, and community engagement. The definition of university will thus allow a spectrum of institutions that range from those that place equal emphasis on teaching and research i.e., Research-intensive Universities, those that place greater emphasis on teaching but still conduct significant research i.e. Teaching-intensive Universities. Meanwhile, an Autonomous degree-granting College (AC) will refer to a large multidisciplinary institution of higher learning that grants undergraduate degrees and is primarily focused on undergraduate teaching though it would not be restricted to that and it need not be restricted to that and it would generally be smaller than a typical university.

Medical Research and Medical teaching are very much interdependent and integrated. Hence separating Medical Research and Medical Teaching is not a practicable concept and should be discouraged.

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10.7

By 2030, all higher education institutions (HEIs) shall aim to become multidisciplinary institutions and shall aim to have larger student enrolments preferably in the thousands, for optimal use of infrastructure and resources, and for the creation of vibrant multidisciplinary communities. Since this process will take time, all HEIs will firstly plan to become multidisciplinary by 2030, and then gradually increase student strength to the desired levels.

Interdisciplinary curricula is time consuming and takes collaborative team work to create, which can seem like hard and exhausting as disadvantages. In the end, the interdisciplinary approach inhibits many favoured skills that are sought by the future colleges and employers. Students and their teachers will lose focus  in respect of critical thinking, out of box reasoning, effective  communication, innovation and creativity, pedagogy, and other essential and vital academic attributes.

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11.5

Imaginative and flexible curricular structures will enable creative combinations of disciplines for study, and would offer multiple entry and exit points, thus, removing currently prevalent rigid boundaries and creating new possibilities for life-long learning. Graduate-level, master’s and doctoral education in large multidisciplinary universities, while providing rigorous research-based specialization, would also provide opportunities for multidisciplinary work, including in academia, government, and industry.

Major concern raised in this policy regarding professional education is the utility and employability of the courses. Multiple entry and exit points will lead to the loss of focus on the core subject of study and precipitate further dilution of  the curriculum, teaching, training and resultant learning thereto. This will operate as a vicious circle whereby the utility and employability will be adversely effected in a continual and ongoing manner as a positive feedback system.

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11.6

Large multidisciplinary universities and colleges will facilitate the move towards high-quality holistic and multidisciplinary education. Flexibility in curriculum and novel and engaging course options will be on offer to students, in addition to rigorous specialization in a subject or subjects. This will be encouraged by increased faculty and institutional autonomy in setting curricula. Pedagogy will have an increased emphasis on communication, discussion, debate, research, and opportunities for cross-disciplinary and interdisciplinary thinking.

Giving the responsibility of fixing the Curriculum, deciding on pedagogy etc to the universities and colleges will take away the uniformity in the field of professional education. This by itself is grossly contradictory to the core concept of exit examination embodied in this policy itself.

If the respective universities and colleges are vested with the powers to fix the curriculum and pedagogy, then the role of apex nation body NMC is rendered to nullity. As a matter of fact the need of a uniform core curriculum is inevitably necessary in a huge country like ours. What is required is an autonomy to be vested with the examining Universities to be able to upgrade the said core curriculum in terms of felt needs as an augmentation of it and not a compromise with the same.

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11.9

The structure and lengths of degree programmes shall be adjusted accordingly. The undergraduate degree will be of either 3 or 4-year duration, with multiple exit options within this period, with appropriate certifications, e.g., a certificate after completing 1 year in a discipline or field including vocational and professional areas, or a diploma after 2 years of study, or a Bachelor ’s degree after a 3-year programme. The 4-year multidisciplinary Bachelor's programme, however, shall be the preferred option since it allows the opportunity to experience the full range of holistic and multidisciplinary education in addition to a focus on the chosen major and minors as per the choices of the student. An Academic Bank of Credit (ABC) shall be established which would digitally store the academic credits earned from various recognized HEIs so that the degrees from an HEI can be awarded taking into account credits earned. The 4-year programme may also lead to a degree ‘with Research’ if the student completes a rigorous research project in their major area(s) of study as specified by the HEI.

First 1 to 2 years common course for all science graduates, next 3 years to specialize as doctors, dentists or nurses is neither properly conceived nor properly defined and out layed. The fate of those students who undergo basic foundation course and if they fail in NEET is ambiguously  unclear.

There is no clarification of what a student who receives 1 year Certificate or 2years Diploma is empowered to legally practise.

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18.2

To address the above-mentioned issues, the regulatory system of higher education will ensure that the distinct functions of regulation, accreditation, funding, and academic standard setting will be performed by distinct, independent, and empowered bodies. This is considered essential to create checks-and-balances in the system, minimize conflicts of interest, and eliminate concentrations of power. To ensure that the four institutional structures carrying out these four essential functions work independently yet at the same time and work in synergy towards common goals. These four structures will be set up as four independent verticals within one umbrella institution, the Higher Education Commission of India (HECI).

All these aspects are adequately represented in NMC Act

Hence there would be duplication of regulatory authority

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18.4

The primary mechanism to enable such regulation will be accreditation. The second vertical of HECI will, therefore, be a ‘meta-accrediting body’, called the National Accreditation Council (NAC). Accreditation of institutions will be based primarily on basic norms, public self-disclosure, good governance, and outcomes, and it will be carried out by an independent ecosystem of accrediting institutions supervised and overseen by NAC. The task to function as a recognized accreditor shall be awarded to an appropriate number of institutions by NAC. In the short term, a robust system of graded accreditation shall be established, which will specify phased benchmarks for all HEIs to achieve set levels of quality, self-governance, and autonomy. In turn, all HEIs will aim, through their Institutional Development Plans (IDPs), to attain the highest level of accreditation over the next 15 years, and thereby eventually aim to function as self-governing degree-granting institutions/clusters. In the long run, accreditation will become a binary process, as per the extant global practice.

All these aspects are adequately represented in NMC Act which has provision for accreditation of medical colleges and universities by a notified body incorporated in the said Act.

Hence there would be duplication of regulatory authority

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18.6

The fourth vertical of HECI will be the General Education Council (GEC), which will frame expected learning outcomes for higher education programmes, also referred to as ‘graduate attributes’. A National Higher Education Qualification Framework (NHEQF) will be formulated by the GEC and it shall be in sync with the National Skills Qualifications Framework (NSQF) to ease the integration of vocational education into higher education. Higher education qualifications leading to a degree/diploma/certificate shall be described by the NHEQF in terms of such learning outcomes. In addition, the GEC shall set up facilitative norms for issues, such as credit transfer, equivalence, etc., through the NHEQF. The GEC will be mandated to identify specific skills that students must acquire during their academic programmes, with the aim of preparing well-rounded learners with 21st century skills.

All these aspects are adequately represented in NMC Act which has provision for accreditation of medical colleges and universities by a notified body incorporated in the said Act.

Hence there would be duplication of regulatory authority

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18.14

Private HEIs having a philanthropic and public-spirited intent will be encouraged through a progressive regime of fees determination. Transparent mechanisms for fixing of fees with an upper limit, for different types of institutions depending on their accreditation, will be developed so that individual institutions are not adversely affected. This will empower private HEIs to set fees for their programmes independently, though within the laid-out norms and the broad applicable regulatory mechanism. Private HEIs will be encouraged to offer freeships and scholarships in significant numbers to their students. All fees and charges set by private HEIs will be transparently and fully disclosed, and there shall be no arbitrary increases in these fees/charges during the period of enrolment of any student. This fee determining mechanism will ensure reasonable recovery of cost while ensuring that HEIs discharge their social obligations.

Giving the power to fix the fee structure to the respective institutions will result in worst commercialisation of the professional education in terms of substantially increasing the cost of education,  thereby depriving the poor, marginalised, and rural section of students from accessing professional education,  which is contrary to the concepts mentioned in this education policy in its prologue that the aim is to decrease the cost of education and to improve access to rural students. As such the proposal in the present form as mooted is an antithesis to the lofty objective enshrined in the report itself. It is a classical case of content in total contempt of the intent.

IMA Suggests that power to fix fee should be with the Fee Regulatory Authority and education for the poor and marginalised students should be subsidized in private funded institutions on par with public funded institutions

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19.2

Through a suitable system of graded accreditation and graded autonomy, and in a phased manner over a period of 15 years, all HEIs in India will aim to become independent self-governing institutions pursuing innovation and excellence. Measures will be taken at all HEIs to ensure leadership of the highest quality and promote an institutional culture of excellence. Upon receiving the appropriate graded accreditations that deem the institution ready for such a move, a Board of Governors (BoG) shall be established consisting of a group of highly qualified, competent, and dedicated individuals having proven capabilities and a strong sense of commitment to the institution. The BoG of an institution will be empowered to govern the institution free of any external interference, make all appointments including that of head of the institution, and take all decisions regarding governance. There shall be overarching legislation that will supersede any contravening provisions of other earlier legislation and would provide for constitution, appointment, modalities of functioning, rules and regulations, and the roles and responsibilities of the BoG. New members of the Board shall be identified by an expert committee appointed by the Board; and the selection of new members shall be carried out by the BoG itself. Equity considerations will also be taken care of while selecting the members. It is envisaged that all HEIs will be incentivized, supported, and mentored during this process, and shall aim to become autonomous and have such an empowered BoG by 2035.

Giving the responsibility of fixing the Curriculum, deciding on pedagogy etc to the universities and colleges will take away the uniformity in the field of professional education. This by itself is grossly contradictory to the core concept of exit examination embodied in this policy itself.

If the respective universities and colleges are vested with the powers to fix the curriculum and pedagogy, then the role of apex nation body NMC is rendered to nullity. As a matter of fact the need of a uniform core curriculum is inevitably necessary in a huge country like ours. What is required is an autonomy to be vested with the examining Universities to be able to upgrade the said core curriculum in terms of felt needs as an augmentation of it and not a compromise with the same.

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20.2

Professional education thus becomes an integral part of the overall higher education system. Stand-alone agricultural universities, legal universities, health science universities, technical universities, and stand-alone institutions in other fields, shall aim to become multidisciplinary institutions offering holistic and multidisciplinary education. All institutions offering either professional or general education will aim to organically evolve into institutions/clusters offering both seamlessly, and in an integrated manner by 2030.

Professional education having dedicated Technical and Health universities have streamlined the courses, improved the academics, encouraged research, brought in uniformity in students assessment in the respective sectors.

Backtracking on this focused attention in the Higher education field will bring in deterioration in quality of education and would be counterproductive on several counts both tangible as well as non-tangible at this juncture.

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20.5

Healthcare education needs to be re-envisioned so that the duration, structure, and design of the educational programmes need to match the role requirements that graduates will play. Students will be assessed at regular intervals on well-defined parameters primarily required for working in primary care and in secondary hospitals. Given that people exercise pluralistic choices in healthcare, our healthcare education system must be integrative meaning thereby that all students of allopathic medical education must have a basic understanding of Ayurveda, Yoga and Naturopathy, Unani, Siddha, and Homeopathy (AYUSH), and vice versa. There shall also be a much greater emphasis on preventive healthcare and community medicine in all forms of healthcare education.

NSSO Health survey 2014 report provides the statistics of providing healthcare by various systems of treatment in India. It is categorically stated that 98 % of the Inpatient care & 94% outpatient care is provided by Modern Medicine. All other complimentary systems together provide rest of the treatment. Hence the statement that the Indians have always exercised pluralistic choices in healthcare, seeking help from different systems of medicine for different needs is contrary to the above survey findings and is palpably erroneous to that extent. The modification of the Medical education policy of the country should not be based on wrong concepts and ill-conceived perceptions and notions which are not backed by quantitative data of any type.

The concept of improving the quality of Medical education, Healthcare Practitioner and the Quality of healthcare delivery is very much appropriate and the education and Health policy should be centered  aroundthis principle. Providing lateral entry to various medical courses, permitting crosspathy in the guise of plurality are grossly contradictory to the enshrined objectives in the policy.

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26.7

The matter of commercialization of education has been dealt with by the Policy through multiple relevant fronts, including: the ‘light but tight’ regulatory approach that mandates full public self-disclosure of finances, procedures, course and programme offerings, and educational outcomes; the substantial investment in public education; and mechanisms for good governance of all institutions, public and private. Similarly, opportunities for higher cost recovery without affecting the needy or deserving sections will also be explored.

The concepts of giving power to fix fee structure, providing multiple entry and exit points, providing lateral entry to various medical courses, ultimately aims and focuses to the only goal of permitting, validating and legalizing cross-pathy in the guise of plurality. The modality would end up in generation of validated quacks and legalized quackery.