02/27/2026
A FLAWED MANDATE, A DANGEROUS REPORT: Why the TWG recommendations on BSC Clinical Medicine must be rejected.
The Bachelor of Clinical Medicine Graduates Association (BCMGA) categorically and totally rejects the findings and recommendations of the Technical Working Group (TWG) report insofar as they purport to justify the scrapping of the Bachelor of Science in Clinical Medicine. The report is procedurally defective, substantively flawed, and institutionally compromised.
First, the TWG exceeded its mandate. The TWG was constituted to review and harmonize scopes of practice (SoP) for healthcare professionals, not to make national policy decisions on the abolition of accredited degree programs. The recommendation to scrap BSc Clinical Medicine is therefore ultra vires, lacks locus standi, and should be set aside in limine. Decisions of this magnitude fall within statutory interprofessional oversight and policy processes under the Health Act, 2017, and must be subjected to lawful, consultative, and evidence-based procedures led
through the appropriate national mechanisms, including the relevant training and regulatory bodies.
Second, the report’s substantive reasoning is internally contradictory and analytically weak. The TWG itself identifies systemic failures, fragmented career pathways, weak curriculum harmonization, poor stakeholder engagement, weak workforce planning, and inadequate differentiation of competencies across levels of training. These are governance and regulatory failures. They are not failures inherent to the existence of the BSc Clinical Medicine degree. Abolishing a degree pathway does not fix regulatory incoherence; it merely scapegoats one cadre for system level failures. The report therefore misdiagnoses the problem and prescribes a destructive remedy.
Third, the recommendation to scrap BSc Clinical Medicine is harmful to the health system. It will shrink the clinical workforce pipeline in a context of documented shortages, weaken primary health care delivery, strand current students and graduates, waste substantial public, and household investment in training infrastructure, and expose the health sector to avoidable legal, industrial relations, and service delivery risks.
Fourth, BCMGA notes with grave concern the appearance of predetermination and policy capture in the TWG process. The TWG appears to have been instructed and predetermined to focus disproportionately on a single cadre, Bachelor of Science in Clinical Medicine, rather than undertaking a genuine interprofessional scope of practice harmonization exercise across all health cadres. The role of the
TWG was therefore not exercised for its stated purpose of neutral technical harmonization but instead reduced to a rubber-stamping process for a preconceived outcome.
Further, the Director General of Health, Dr. Patrick Amoth, has been publicly quoted on national television characterizing Clinical Medicine as a “stop gap measure” that should be abolished. Disturbingly, the TWG report mirrors this same framing and language. This creates a reasonable perception that the outcome of the TWG process was pre-judged, and that the report reflects the “handwriting” of the appointing authority rather than an independent, evidence led technical process.
Finally, BCMGA notes that key clinical medicine stakeholders who were consulted in the TWG process, thus the: Clinical Officers Council, the Kenya Clinical Officers Association (KCOA), and the Kenya Union of Clinical Officers (KUCO), did not recommend the scrapping of the BSc Clinical Medicine degree. The introduction of such a recommendation despite the absence of stakeholder support further demonstrates that the conclusion was externally driven, unsupported by consultations, and inconsistent with the evidence placed before the TWG.
This raises serious questions about the independence of the TWG, the integrity of the consultative process, and the quality of leadership and governance exercised in the conduct of the review.
When the authority that constitutes a technical working group publicly declares a policy position in advance, and the group’s final
recommendations mirror that position, the credibility of the entire process is undermined. This is not technocratic reform; it is policy laundering through a technical committee.
This report is procedurally invalid, substantively unsound, and politically compromised; BCMGA rejects it in toto and demands its withdrawal and reprocessing through lawful, independent, and consultative mechanisms.
BCMGA therefore formally trashes and rejects the TWG report in its current form. The report is unfit to guide national policy on health professional training and workforce development. BCMGA demands:
1. THAT the TWG report be withdrawn in its entirety and set aside on grounds that the process and outcomes are compromised, procedurally defective, and lack institutional credibility.
2. THAT a fresh, independent scope of practice TWG be constituted, with clear terms of reference, transparent appointment criteria, and balanced interprofessional representation.
3. THAT the mandate of the new TWG be strictly limited to scope of practice harmonization only and expressly barred from making structural recommendations on the abolition, creation, or restructuring of academic degree programs, cadres, or national training pathways.
Rebuttal to TWG recommendations: Misrepresentations of facts picked from the TWGs report.
1. “Diploma and BSc Clinical Medicine cover broadly similar modules with limited differentiation’’.
This statement is technically superficial and substantively misleading.
a) Similar modules, versus same qualification or competency: All medical and health training pathways share foundational sciences (anatomy, physiology, pathology, pharmacology, community health etc). Similarity in module titles does not amount to similarity in academic level, depth of content, duration of exposure, clinical responsibility, assessment rigor, or expected competencies. Medicine is medicine; foundational sciences are universal. The differentiation lies in depth, scope, clinical autonomy, and outcomes, not in whether the module is called “Anatomy.”
b) Degree level training is structurally different from diploma training. The BSc Clinical Medicine is a university accredited undergraduate degree pathway regulated through the Commission for University Education and the Clinical Officers Council. It entails longer duration, higher academic rigor, advanced clinical rotations, exposure to advanced research methods, than diploma programs. Collapsing these distinctions is a category error.
c) The TWG applies a flawed test of equivalence: If similarity of units were the test of equivalence, then, by the TWG’s own reasoning, the MBChB curriculum, as approved by the Kenya Medical Practitioners and Dentists Council, would be treated as equivalent to a diploma simply because it shares foundational pre-clinical, and clinical sciences medical pathways. That conclusion is obviously false, and it exposes the weakness of the TWG’s logic.
d) The finding suggests shallow curriculum review: By reducing complex curricula to “broadly similar modules,” the TWG demonstrates that it likely did not conduct a granular, competency mapped comparison of curricula (learning outcomes, contact hours, assessment standards, clinical responsibility levels). This undermines the credibility of its claim that it undertook a robust comparative curriculum review.
Therefore, TWG’s statement confuses curricular overlap with qualification equivalence. Overlap is normal in medicine; equivalence is determined by level, depth, outcomes, and regulatory status. On this basis, the finding is analytically unsound and cannot justify scrapping a degree program.
2. The “Dead-End Course” Claim is factually false.
The TWG’s assertion that the Bachelor of Science in Clinical Medicine constitutes a “dead-end” career pathway is demonstrably false, empirically contradicted by existing training pathways, and analytically careless. This claim collapses under even minimal scrutiny of current postgraduate training realities, professional progression frameworks, and international recognition of BSc Clinical Medicine graduates.
First, postgraduate progression already exists within the Clinical Medicine pathway. Bachelor of Clinical Medicine graduates are admitted into structured Master of Clinical Medicine programmes (MCMed) across multiple clinical disciplines, including (but not limited to) paediatrics, emergency and critical care, reproductive health, and family medicine among others. These postgraduate tracks deepen clinical competence, expand scope of practice within regulated frameworks, and directly address service delivery needs Kenya. The existence and uptake of these programmes alone defeat the “dead-end” narrative.
Second, doctoral pathways are available. BSc Clinical Medicine graduates access PhD programmes in Clinical Medicine and related clinical and biomedical sciences, contributing to clinical research, health systems strengthening, teaching, and policy relevant evidence generation. A cadre with access to doctoral training is, by definition, not a ‘’dead-end’’ cadre. The TWG’s claim therefore misrepresents the academic and professional ceiling available to BSc Clinical Medicine graduates.
Third, international postgraduate mobility further disproves the “dead-end” claim. Bachelor of Clinical Medicine graduates from Kenya have been competitively admitted into postgraduate medical and clinical programmes in international universities, to Master of Medicine (MMed) in internal medicine, general surgery, neurosurgery, obstetrics and gynaecology, and other clinical specialties. This external acceptance is decisive evidence that the BSc Clinical Medicine degree is recognized internationally as a legitimate undergraduate medical qualification capable of supporting advanced clinical specialization. If the degree were truly a “dead end,” it would not meet entry thresholds for competitive postgraduate medical training abroad, which has been historically a preserve for the medical officers.
3. The “Bridging / RPL” Proposal is un-informed.
The TWG recommendation that Bachelor of Clinical Medicine (BCM) graduates require “bridging programmes” and “recognition of prior learning (RPL)” in order to reach acceptable standards is technically unsound and misrepresents the academic sufficiency of the BSc Clinical Medicine pathway.
Internationally, undergraduate medical degrees are benchmarked on minimum training intensity and exposure, including a widely accepted threshold of over 5,500 contact hours comprising structured preclinical instruction, supervised clinical rotations, and competency-based training.
These benchmarks are reflected in global medical education frameworks promoted and referenced by bodies such as the World Federation for Medical Education, the World Health Organization, and regulators whose standards are used internationally, including the General Medical Council.
The BSc Clinical Medicine curriculum meets and exceeds this threshold of 5,500 contact hours, with extensive preclinical and clinical exposure. It is therefore already structured and delivered as a medical degree level programme, not a sub threshold qualification.
Therefore, the TWG’s proposal for “bridging” is conceptually flawed because:
a) Bridging frameworks are designed for sub degree or non degree pathways, not for full undergraduate medical degrees that already meet recognized training thresholds.
b) BSc Clinical Medicine graduates from Kenya are recognized in multiple jurisdictions internationally for clinical practice as doctors and offered postgraduate training without being subjected to “bridging into medicine,” precisely because their training meets medical education standards.
c) Proposing bridging falsely implies that BCM training is academically deficient, when in fact it already satisfies internationally recognized contact hour and competency benchmarks for a medical degree.
d) This recommendation exposes that the TWG did not meaningfully review the BCM curriculum, despite purporting to have conducted a curriculum analysis.
4. Duplication of roles and role conflict: A regulatory failure, not an education problem
The TWG’s own recommendations acknowledge that the core dysfunction in the health system is duplication of roles and role conflict in service delivery, arising from weak regulation, and poor enforcement of scopes of practice (SoPs). The problem is therefore not how professionals are trained at foundational level, but how cadres are regulated, deployed, and managed in practice.
Duplication of roles arises when: Scopes of practice are poorly defined or inconsistently enforced, regulators and ministries operate in silos, producing blurred professional boundaries, and when facility level job descriptions are misaligned with legally approved scopes of practice.
These are governance failures. They cannot be cured by abolishing a degree pathway. Scrapping BSc Clinical Medicine would not resolve duplication of roles; it would merely shift the same regulatory dysfunction onto fewer cadres, while worsening workforce shortages and service delivery pressures.
Global best practice shows that role duplication is managed through regulation, not elimination of cadres. In India, multiple medical degree cadres coexist within one national health system under differentiated scopes of practice and regulatory oversight, including:
a) MBBS – Bachelor of Medicine and Bachelor of Surgery
b) BAMS – Bachelor of Ayurvedic Medicine and Surgery
c) BHMS – Bachelor of Homeopathic Medicine and Surgery
d) BUMS – Bachelor of Unani Medicine and Surgery
e) BNYS – Bachelor of Naturopathy and Yogic Sciences
These cadres operate in parallel without being abolished on grounds of role duplication. Where role conflict arises, it is addressed through scope definition, regulatory oversight, and deployment frameworks, not by scrapping entire professional pathways.
The TWG’s report, as presented, is fundamentally compromised, procedurally ultra vires, and substantively reckless. By straying beyond its mandate to harmonize scope of practice and venturing into cadre elimination and training pathway abolition, the TWG has produced a report that is legally vulnerable and institutionally unsound, inviting unnecessary and protracted court battles, judicial review, injunctions, and compensation claims by affected students, graduates, and institutions. This overreach is not just bad process; it is bad policy. Kenya is a resource constrained health system facing persistent workforce shortages and access gaps and cannot realistically function on a single clinical cadre.
Global best practice shows the opposite approach works: in India, multiple medical degree pathways coexist under defined scopes of practice and regulatory oversight; in the United States, Doctor of
Medicine and Doctor of Osteopathic Medicine physicians practice side by side under separate professional traditions and regulatory arrangements without collapsing the system. The lesson is clear: plural, well regulated cadres expand access and strengthen service delivery.
The TWG’s attempt to constrict medical care to a single pathway is therefore both legally reckless and strategically regressive, and it threatens to paralyse health workforce reform in avoidable litigation rather than strengthen patient care.
BCMGA- NEC
