yes, but there's no reason why an emergency supplemental program confined to sickbay and run through the main computer would have advanced AI either. Most likely, the program was never meant to run for longer than a few hours.
I doubt many of the real doctors on starships even bothered with the EMH programs and instead treated them with distaste. They are called emergency for a reason. The attitudes programed into them really didn't help.
Also the holographic rights thing was something I'd rather not think about, since they were being used as sex toys over at DS9.