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Doctors Registry of India
Contents
Overview................................................................................................. Error! Bookmark not defined.
Problem Statement ............................................................................... Error! Bookmark not defined.
Current Issues........................................................................................ Error! Bookmark not defined.
Recommended Solution....................................................................... Error! Bookmark not defined.
Architectural Approach for Doctor’s Registry...................................................................................6
Annexure-I: Recommended MDDS based data elements for National Doctor’s Registry....8
Annexure-2: Technical details of Federated Architecture for Doctor’s Registry...................10
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Overview
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.
Problem Statement
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!
Current Issues
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.
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• 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.
Government/Administrative Issues:
• 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.
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Recommended Solution
As per newspaper reports1, 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 2
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.
1
All practicing Doctors to have unique digital identification, 02 Oct 2017, Livemint
2
NMC Notified: http://egazette.nic.in/WriteReadData/2019/210357.pdf
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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.
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ANNEXURES
Annexure-I: Recommended MDDS based data elements for National Doctor’s Registry
MDDS
element
ID
Element Label Format Siz
e
Value set
05.005.00
01
Unique Individual Health Care
Provider ID
Varchar 18 To be generated by the
National Doctor’s Registry
G01.01 Unique Identification(UID) Provider’s Aadhar
Number
05.002.00
02
Alternate Unique Identification
Number
Varchar 18
(ma
x
size
)
Any alternate Govt
Identifier
05.002.00
01
Alternate Unique Identification
Type
Integer 2 Alternate Govt Identifier
Type (PAN card, Voter
ID,Passport Number etc.)
05.005.00
09
Care Provider Name Provider Name
05.005.00
03
Medical Council Registration
Number
Integer 3 State Medical Council
Registration Number
05.005.00
04
Care Provider Address House
Number./DoorNumber/Ho
use
Identifier/Flat Number
l Building Number./Plot
Number
building Name/ Building
Identifier
Block Name/Number or
any other qualifier
l Street Number
/Name/Mohalla/
Sector Number/any other
qualifier
Area Number/Area
Name/Suburb/Sub
district in case of
Village/any other
qualifier
Integer
State - 2
District - 3
Sub-District - 5
Village - 6
Town - 6
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05.005.00
05
Care Provider Address Type Char 1
G01.09-
00-01
Face Image Record Header Provider Photograph
Image data
G01.09-
00-02
Face Image Record Data Provider Photograph
Image data
05.005.00
07
Care Provider Mobile Number
05.005.00
08
Care Provider Email
Address/URL
05.005.00
12
Health Service Provider Type Integer 2
G01.03 Gender Identification Code Char 1 Gender Code of Care
Provider
05.004.00
54
Employment Status Integer 2
05.004.00
51
Selection Organization Facility
ID
Integer 10 Facility ID of the
organization who
employed the provider
G02.02-01 Date of Joining Date of Joining
G00.01 Date of Status Change Date (dd/
mm/yyyy)
10 Date of change in
employment status
Registration Status
Digital certificate Digital certificate /public
key of the provider
G00.01 Professional Registration Start
Date
Date (dd/
mm/yyyy)
10
G00.01 Professional Registration End
Date
Date (dd/
mm/yyyy)
10
05.004.00
12
Medical
Degrees/Certificates/Accreditati
ons
Integer 2 To be maintained at state
provider databases
05.004.00
12
Health
conferences/seminars/trainings
attended
Integer 2 To be maintained at state
provider databases
05.008.00
01
Healthcare Facility ID Integer 10 The facility where the
provider is employed or
practicing.
G00.08 VND Char 5 Defines Version number
of the data record to be
used for tracing the
history of changes.
G00.01 DOUD Date (dd/
mm/yyyy)
1
10 Date of the last Update for
ownership authority
record
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Annexure-2: Technical details of Federated Architecture for Doctor’s Registry
Proposed Doctor’s Registry Federated Architecture
2. Identify Minimum required data elements for Centrally maintained Doctor Registry
and associated directories maintained at State level
A central or nationally maintained Doctor’s registry that can be self-sustainable and easy to
maintain should not have a long list of data elements or attributes. It should consist of only a
set of minimum required data elements that help to identify the provider uniquely and can be
kept updated at all times. The recommended data elements should follow Metadata and
Data standards for India (MDDS) which is a standard notified by the Ministry of health and
family welfare (MohFW) and is maintained by Ministry of Electronics and Information
Technology (MeITY).
The provider’s credentials, certifications, medical conferences attended and employment
details, active/inactive status can be maintained if required in state medical council
directories or smaller associated provider directories maintained by a state, until the provider
requests for a transfer to another state.
The recommended minimum viable data elements are listed in the Annexure. The central
provider registry should also facilitate updation of a provider’s active/inactive status in case
of migration to other country or death via submitting a death certificate for a provider or by
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triggering a verification process using a rule engine by setting up a defined time/period for
the trigger from date of registration and updation activity.
3. Clean and harmonize state and central medical register data
The first step will be to assign the MDDS based data element template to all the states and
central medical council or NMC to clean and validate information about active providers. This
activity may involve the utilization of technologies like ML or AI along with some manual
interventions. Only once the provider information for existing registered providers residing in
state medical registers is updated and cleaned, it can be pushed to central registry for
validation and generation of a Unique Registration Number as mentioned above.
4. Federated (distributed) queries to fetch data from respective data holders
An orchestration mechanism will be set up to distribute any query made for a provider data
through provider portal or any state medical council-owned application, to all the data nodes
(including central registry and state-level provider databases). The orchestration engine will
be used to route the query to central Doctor’s Registry or any state-level provider databases
and aggregate the query responses received from doctor’s registry and all provider
databases to the provide complete-provider data as response to the query.
The aggregated response of the query thus will provide the detailed information of provider
collated from the central doctor’s registry and all other provider databases where provider
data is maintained across the state medical councils. The federated query orchestration
mechanism will ensure the deduplication of provider data and maintain the uniqueness of
Doctor’s records across all data nodes in federated architecture.
5. Convert the clean, verified data using a technology partner like NIC into a registry.
The next step towards digitalizing the National Provider Registry after receiving clean and
validated data from the respective state medical council is to load the cleaned provider data
into the National Doctor’s Registry. The Doctor’s registry shall maintain mapping index of the
source ID of each provider database where provider data is maintained. The orchestration
engine shall use this indexed database to distribute the queries across the doctor registry
and various provider databases.
The loading process of provider data into the doctor’s registry shall ensure the uniqueness
and deduplication of provider data by using validation/data deduplication engine (use of
Index Matching services deployed with the doctor’s registry). A National unique provider
Identifier shall be generated for each provider populated in the doctor’s registry. The
algorithm to generate the unique provider identifier should be decided by the authority
implementing the design of doctor’s registry. The Entity Resolution and Analysis Service
maintained at Central Doctor Registry shall validate and deduplicate the data entry of a
provider in Doctor’s Registry and hence the provider data in central doctor’s registry will
always be unique for each provider.
6. Central Portal for all Provider registrations and Standard Operating Procedures for
keeping it updated
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Develop a provider portal with standard operating procedures on addition and updation of
provider data (covering use-cases e.g. provider enrollment, exit, credentialing, certifications,
conferences attended, employment details and payment verifications through DBT).
• Portal for enrolling new providers into National Doctor’s Registry and updating details
about doctor’s credentials, certifications, conferences attended, exist, employment
details, and provider payments, into state-level provider directories.
• The provider will be able to self-use this portal to update his/her details through the
provider portal. The provider shall need to authenticate himself using Aadhaar Auth
API or using any other government-issued digital identifier (Voter ID,PAN Number
etc.) or OTP on the registered mobile number/two-factor authentication before
accessing the portal.
• The data updation in state-level provider databases and central Doctor’s registry
shall be electronically synced up by using updation openAPIs/webservices. Thus
data updated by provider in provider database shall be reflected in the central
doctor’s registry as well.
7. Maintenance of Doctor’s Registry and State Level provider databases
For maintenance of Provider data in state-level provider databases and sync up of provider
data across state-level provider databases and central Doctor’s Registry, an orchestrator will
be set up to distribute the APIs between the registry and various federated provider
databases. The different state medical councils shall be open to using any applications of
their choice to maintain the provider’s data into provider database maintained by the state
medical council and the openAPIs/web services will be used to update the data from
provider database into central doctor’s registry. The central doctor’s registry will be minimum
data and data attributes will be as per defined in Annexure1. Whereas the data elements in
local and state databases will be a subset of Annexure 1.
8. Interoperability of Doctor’s Registry and State Level provider databases with other
public and private applications (Provider and Payer applications)
The Doctor Registry will be accessible to provider and payor applications by use of an
Interoperability layer and provider details can be verified from the central Doctor’s registry by
use of National Provider Identifier based data lookup openAPIs. All these openAPIs will be
deployed and mediated through the interoperability layer. The provider data will be retrieved
by data query based openAPIs/webservices from central Doctor’s Registry and the federated
provider databases and orchestrator will coordinate the retrieval of provider data from
provider databases using distributed queries.
The central Doctor’s Registry will also connect to several external applications e.g. NHA
Health Claims (HCP) platform for verification of provider in claims databases, provider
credentialing in payor databases, Automated payment verifications through DBT process or
IDSP Disease Surveillance platform.
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The Doctor’s Registry will also connect with the UIDAI database for Aadhaar based
authentication using Aadhaar Auth API/eKYC API and NPI linkages with other government
identifier databases (e.g. PAN database, Voter ID database etc.) for provider authentication
using alternate government IDs.
OpenAPIs will be published so that provider credentialing data could be accessed or
updated through mobile apps. this would be useful in telemedicine apps or apps developed
for medical colleges.
