‘Gross negligence’: NMC’s new MBBS curriculum guidelines can harm 3.6 crore Indians

NEW DELHI: The Competency Based Medical Curriculum (CBME) for MBBS students, released by National Medical Commission (NMC), is being called out for ignoring the rights of persons with disabilities and persons with gender incongruence.

In its latest revision, prompted by the Madras High Court’s intervention, NMC has removed references related to the LGBTQ community. However, the commission is yet to add disability competencies.

Air Cmde (Dr) Sanjay Sharma (retd) is CEO and managing director of Association for Transgender Health in India (ATHI) – a Delhi-based organisation which, along with Dr. Satender Singh, professor at University College of Medical Sciences (UCMS), New Delhi and disability rights activist, has been opposing the NMC guidelines.

He spoke to Careers360 on NMC’s flip-flops on the CBME guidelines, impact of the latest MBBS curriculum on medical education and healthcare of disabled and transgender people. Edited excerpts below.

Q. Tell us more about your organisation, ATHI.

The Association for Transgender Health in India (ATHI) is a non-profit organisation founded on November 1, 2018, that works towards diversity and gender inclusion in India. After finding that nothing was being done about transgender healthcare in India, I got together with like-minded people, who essentially understood the need of getting transgender healthcare in India, and established ATHI.

We got involved with the ministry of health, ministry of social justice and empowerment, and National AIDS Control Organization (NACO) to get them to look at holistic transgender health. In 2019, we were involved with the community to push for the Transgender Persons (Protection of Rights) Act, 2019 (TPA).

Through our efforts, we got a section in the TPA that talks about the need for changes in medical education and also for setting up protocols, or a health manual, which was in line with the guidelines that were developed by the World Professional Association for Transgender Health (WPATH), US.

In 2020, we brought out the Indian Standards of Care for Transgender and by December 2023, we got the Centre of Excellence for transgender healthcare at All India Institute of Medical Sciences (AIIMS) Delhi.

Q. What are the provisions in the Rights of Persons with Disabilities Act, 2016, or RPDA 2016 and TPA 2019 that make it necessary for the NMC to include disability and transgender rights in medical education curriculum?

Both RPDA and TPA talk about autonomy. Both laws talk about the respect that needs to be given to these individuals and their choices. Both talk about how disabled and transgender people should not be seen as those having some disease that needs to be cured. Disability and gender incongruences are human conditions.

The TPA instructs all government agencies to make sure that the right to self-affirmation of gender is respected. It provides for reservations in jobs and the need for medical care of transgender communities. The Act says it is a medico-social issue and a health manual should be developed and protocols be followed for giving gender-affirmative care.

The Act talks about the need for a change in education curriculum and asks teachers, doctors, or providers of medical care to do continuing education.

It essentially gives directions to authorities to make changes in the medical curriculum so that people with disability and gender incongruence are not seen as people with diseases. It asks them to make a health manual while following the guidelines put out by the World Health Organization (WHO) and WPATH.

Q. Has NMC followed the provisions of RPDA and TPA?

No, they have not. NMC’s CBME curriculum continues to have literature that identifies transgender people as having some pathology. It is majorly in the textbook of forensics but also in all medical texts, starting from the basic text of physiology.

The language of the CBME document is very derogatory when it comes to referring to these people. NMC has failed despite WHO, in June 2018, saying that gender incongruence is not a mental health issue. Despite being told repeatedly, NMC has gone on to not respect self-affirmation, not having the right language, and not having the right protocols.

I think NMC is wrong in its approach and very misinformed. It is not listening to what the courts are saying, what the WHO is saying, what medical activists are saying. So this is gross negligence on NMC’s part.

I think people who are advising the NMC, if at all there is somebody, have not read the latest standards of care that have been put out by WPATH. They still think this is a western idea. They are still in the colonial mindset of following a binary education system.

Q. In the latest revision to the CBME guidelines, NMC has removed LGBTQ references and said it is still reviewing disability competencies. How do you see this?

We have people as young as 18 who enter the medical stream and allied healthcare subjects.

Through the medical curriculum, NMC is asking medical students to consider males and females with two arms and two legs who can perform to a certain normal standard as normal, and the rest are considered abnormal or pathological.

NMC excludes people with disabilities and those who don't conform to the binary and it is telling medical students to look at the people with disabilities and gender incongruence as having pathologies.

The education system is designed to promote the binary perfect human being model. It needs to be corrected at curriculum levels to provide more role models to students with disabilities and gender incongruence.

Q. Will the CBME curriculum affect the treatment and healthcare of the disabled and transgender community?

If the NMC doesn’t make corrections in line with international medical evidence and guidelines, people with disability and gender incongruence won’t be able to get medical care. They will continue getting thrown out of their families, and that's a social burden that is going to increase.

The incidence of gender incongruence is now pitched at something between 2% and 8%. Even if we take it as 2%, we are talking about 3.6 crore Indians who are going to be denied medical care because the NMC is not getting ready to accept the medical evidence.

NMC is constituted of medical practitioners and they need to follow the oath – ‘First of all, do no harm’ – provide care, and not bring out policies that are exclusionary or which are against human rights.

Q. You had warned NMC that you would complain to the World Federation of Medical Education (WFME) about the CBME curriculum. Have you done it?

This is something we thought we needed to do. But I very strongly feel that the moment I do it, I will be writing against my country and I would be again calling out people in an international forum.

This makes me take a step back and allow NMC to at least realise that the CBME curriculum is wrong on so many levels.

At international forums, we talk about how we are making strides in transgender healthcare. Now, I feel sad in pointing out or exposing my own fellow citizens.

I would like to see NMC making some proper changes. I think it is their moral responsibility to take our letter as a wake up call. They need to follow international laws and should not damage the image of the country.

Q. What would be your appeal to NMC?

I would appeal that NMC involves people from WPATH, ATHI and disability organisations before finalising a medical curriculum.

The overhauling of medical education should be based on scientific evidence. I would urge NMC to take the opportunity of becoming world leaders in medical education and not fall back in lines of countries where people with diversity are being neglected or people with disabilities are being thrown out of the main society.