1

ICRAS Tracking and OMB Number: (XXXX) 1845
-NEW v1 Revised: 12 / 11 /2012 RIN Number: XXXX
- XXXX (if applicable)

**SUPPORTING STATEMENT FOR PAPERWORK REDUCTION ACT SUBMISSION**  **Foreign Graduate Medical School Consumer Information Reporting Form**
**A. Justification** 1. Explain the circumstances that make the collection of information necessary . Identify any legal or administrative requirements that necessitate the collection. Attach a hard cop y of the appropriate section of each statute and regulation mandating or authorizing the collection of information , or you may provide a valid URL link or paste the applicable section 1

. Specify the review t ype of the collection (new, revision, extension, reinstatement with change, reinstatement without change) . If revised, brie fl y specify the changes. If a rulemaking is involved, make note of the sections or changed sections, if applicable. This is a request for a new collection to obtain consumer information from foreign graduate medical institutions that participate in the William D. Ford Federal Direct Loan Program (Direct Loan Program) as authorized under Title IV of the Higher Education Act of 1963, as amended, (HEA) . The request is to gain approval of a form for reporting specific graduation information to the Department of Education (Department) with a certification signed b y the institution’s President/CEO/Chancellor as well as for disseminating that information to prospective U.S. students. The fore ign medical institutions are to provide to the following information for all U.S. students attending its approved graduate medical programs: on - time graduation rates for U.S. student completing the program; the median and mean Title IV loan debt incurred b y U.S. students who completed the program, the median and mean private loan debt incurred b y U.S. students who completed the program; the median and mean institutional financing debt incurred by U.S. students completing the program; and the total median an d mean debt incurred by U.S. students who completed the program. The Department’s regulations, at 34 CFR 668.14(b)(7), require Title IV participating institutions to submit reports to the Department containing such information as the Secretary may reasona bly require to carry

out the purposes of the Title IV, HEA programs. This is being done to improve consumer information b y provid ing more specific consumer information to prospective U.S. medical students at foreign institutions.

1 Please limit pasted text to no longer than 3 paragraphs.2

ICRAS Tracking and OMB Number: (XXXX) 1845
-NEW v1 Revised: 12 / 11 /2012 RIN Number: XXXX
- XXXX (if applicable) 2. Indicate how, by whom, and for what purpose the information is to be used. Except for a new collection, indicate the actual use the agency has made of the information received from the current collection. The information calculated and provided b y the foreign medical sc hools will be published on a Departmental consumer web site. The foreign medical schools are also being instructed to provide the data in promotional materials presented to prospective U.S. students as well as on the institution’s web site. 3. Describe whether, and to what extent, the collection of information involves the use of automated, electronic, mechanical, or other technological collection techniques or forms of information technology , e.g. permitting electronic submission of responses, and the b asis for the decision of adopting this means of collection. Also describe an y consideration given to using technology

to reduce burden. The information that is reported to the Department requires a “wet” signature from the institution’s President/CEO/Ch ancellor so the report cannot be submitted ele ctronicall y at this time. It is anticipated that institution’s will utilize their web sites to provide the required information to prospective U.S. students. 4. Describe efforts to identify duplication. Show specificall y wh y an y similar information alread y available cannot be used or modified for use for the purposes described in Item 2 above. There is no duplication of data as a result of the collection of this information. 5. If the collection of i nformation impacts small businesses or other small entities, describe any methods used to minimize burden. A small entit y may be (1) a small business which is deemed to be one that is independently owned and operated and that is not dominant in its field o f operation; (2) a small organization that is any not - for
- profit enterprise that is independently owned and operated and is not dominant in its field; or (3) a small government jurisdiction, which is a government of a city , count y, town, township, school d istrict, or special district with a population of less than 50,000. No small businesses are impacted b y this collection. 6. Describe the consequences to Federal program or policy activities if the collection is not conducted or is conducted less frequently , as well as an y technical or legal obstacles to reducing burden. Without the collection and dissemination of the information prospective students may not have a clear indication of total costs of the medical program they wish to attend or an indicatio n of the successful completion by other U.S. student’s in that particular program. This will aid in prospective U.S. students making more informed decisions, and avoiding over - borrowing in the Direct Loan Program.3

ICRAS Tracking and OMB Number: (XXXX) 1845
-NEW v1 Revised: 12 / 11 /2012 RIN Number: XXXX
- XXXX (if applicable) 7. Explain any

special circumstances that would cause an information collection to be conducted in a manner:

 requiring respondents to report information to the agency more often than quarterl y;  requiring respondents to prepare a written response to a collection of information in fewer than 30 day s after receipt of it;  requiring respondents to submit more than an original and two copies of any document;  requiring respondents to retain records, other than health, medical, government contract, grant - in
- aid, or tax records for more than three y ears ;  in connection with a statistical survey , that is not designed to produce valid and reliable results than can be generalized to the universe of study ;  requiring the use of a statistical data classification that has not been reviewed and approved b y OMB;  that includes a pledge of confidentiality that is not supported by

authority established in statute or regulation, that is not supported by disclosure and data security policies that are consistent with the pledge, or that unnecessaril y i mpedes sharing of d ata with other agencies for compatible confidential use; or  requiring respondents to submit proprietary trade secrets, or other confidential information unless the agency can demonstrate that it has instituted procedures to protect the information ’ s confid entiality to the extent permitted by law. The information collection requirements require no special circumstances. 8. As applicable, state that the Department has published the 60 and 30 Federal Register notices as required b y 5 CFR 1320.8(d), soliciting c omments on the information collection prior to submission to OMB. Summarize public comments received in response to that notice and describe actions taken b y the agency in response to these comments. Specifically address comments received on cost and hour burden. Describe efforts to consult with persons outside the agency to obtain their views on the availability

of data, frequency

of collection, the clarity

of instruction and record keeping, disclosure, or reporting format (if an y), and on the data elem ents to be recorded, disclosed, or reported. Consultation with representatives of those from whom information is to be obtained or those who must compile records should occur at least once every 3 y ears
– even if the collection of information activity

is the same as in prior periods. There may be circumstances that may preclude consultation in a specific situation. These circumstances should be explained. This is the 60 day

comment period request. There has been no change to the regulations currentl y i n place. 9. Explain any

decision to provide any

pay ment or gift to respondents, other than remuneration of contractors or grantees with meaningful justification
. There is no pay

ment or gifts to respondents.4

ICRAS Tracking and OMB Number: (XXXX) 1845
-NEW v1 Revised: 12 / 11 /2012 RIN Number: XXXX
- XXXX (if applicable) 10. Describe an y assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or agency policy
. If personally

identifiable information (PII) is being collected, a Privacy Act statement should be included on the instrument. Please provide a citation for the Sy stems of Record Notice and the date a Privacy Impact Assessment was completed as indicated on the I C Data Form . A confidentiality statement with a legal citation that authorizes the pledge of confidentiality should be provided. 2 If the collection is subject to the Privacy Act, the Privacy

Act statement is deemed sufficient with respect to confidentiality . I f there is no expectation of confidentiality , simply state that the Department make s no pledge about the confidentiall y of the data. The Department requirements do not cover an y confidential information. 11. Provide additional justification for an y questions of a sensitive nature, such as sexual behavior and attitudes, religious beliefs, and other matters that are commonly considered private. The justification should include the reasons wh y the agency considers the questions necessary , the specific uses to be made of the information, the explanation to be given to persons from whom the information is requested, and an y steps to be taken to obtain their consent. The Department is no requesting an y s ensitive data. 12. Provide estimates of the hour burden of the collection of information. The statement should:

 Indicate the number of respondents by affected public ty

pe (federal govern ment, individuals or households, private sector

– businesses or other for
- profit, private sector

– not - for
- profit institutions, farms, state, local or tribal governments) , frequency of response, annual hour burden, and an explanation of how the burden was estimated, including identification of burden t ype: recordkeeping, reporting or third party disclosure. All narrative should be included in item 12. Unless directed to do so, agencies should not conduct special survey s to obtain information on which to ba se hour burden estimates. Consultation with a sample (fewer than 10) of potential respondents is desirable. If the hour burden on respondents is expected to vary widel y because of differences in activity , size, or complexity , show the range of estimated hour burden, and explain the reasons for the variance. Generall y, estimates should not include burden hours for customary and usual business practices.  If this request for approval covers more than one form, provide separate hour burden estimates for each form and aggregate the hour burdens in the ROCI S IC Burden Analy sis Table
. (The table should at minimum include Respondent types, IC activity , Respondent and Responses, Hours/Response, and Total Hours)

2 Requests for this information are in accordance with the following ED and OMB policies: Privacy Act of 1974, OMB Circular A
- 108

– Privacy Act Implementation

– Guidelines and Responsibilities, OMB Circular A
- 130 Appendix I

– Federal Agency Responsibilities for Maintaining Records About Individuals, OMB M
- 03
- 22

– OMB Guidance for Implementing the Privacy Provisions of the E
- Government Act of 2002, OMB M
- 06
- 15

– Safeguarding Personally Identifiable Information, OM : 6
- 104

– Privacy Act of 1974 (Collection, Use and Protection of Personally Identifiable Information)5

ICRAS Tracking and OMB Number: (XXXX) 1845
-NEW v1 Revised: 12 / 11 /2012 RIN Number: XXXX
- XXXX (if applicable)

 Provide estimates of annualized cost to respondents of the hour burdens for collections of information, identifying and using appropriate wage rate categories. The cost of contracting out or paying outside parties for information collection activities should not be included here. Instead, this cost should be included in Item 14. The Department estimates that it will take the 25 affected institutions approximately 2 6 minutes (0.4 3 hours) to complete the reporting requirements for a total of 11 hours
. Affected Entities and Burden : Reporting required inf

ormation to the Department and prospective U.S. students

# of # of # of Respondents Responses Burden Hours Institutions: Not
- for
- profit 5 5 X . 43 hours = 2.2 For Profit 3 3 X . 43 hours = 1 .3 Public 17 17 X . 43 hours = 7.3 TOTAL 25 25 (26 min.) 11 Hours

13. Provide an estimate of the total annual cost burden to respondents or record keepers resulting from the collection of information. (Do not include the cost of any hour burden shown in Items 12 and 14. )

 The cost estimate should be split into two components: (a) a total capital and start
- up cost component (annualized over its expected useful life); and (b) a total operation and maintenance and purchase of services component. The estimates should take i nto account costs associated with generating, maintaining, and disclosing or providing the information. Include descriptions of methods used to estimate major cost factors including s ys tem and technology acquisition, expected useful life of capital equipm ent, the discount rate(s), and the time period over which costs will be incurred. Capital and start - up costs include, among other items, preparations for collecting information such as purchasing computers and software; monitoring, sampling, drilling and testing equipment; and acquiring and maintaining record storage facilities.  If cost estimates are expected to vary widel y, agencies should present ranges of cost burdens and explain the reasons for the variance. The cost of contracting out information col lection services should be a part of this cost burden estimate. In developing cost burden estimates, agencies may consult with a sample of respondents (fewer than 10), utilize the 60
- day

pre - OMB submission public comment process and use existing economic or regulatory

impact anal ys is associated with the rulemaking containing the information collection, as appropriate.  Generally , estimates should not include purchases of equipment or services, or portions thereof, made: (1) prior to October 1, 1995, (2) to achieve regulatory compliance with requirements not associated with the information collection, (3) for reasons other than to6

ICRAS Tracking and OMB Number: (XXXX) 1845
-NEW v1 Revised: 12 / 11 /2012 RIN Number: XXXX
- XXXX (if applicable) provide information or keep records for the government or (4) as part of customary and usual business or private practices. Also, these estimates should not include the hourly costs (i.e., the monetization of the hours) captured above in Item 12 Total Annualized Capital/Startup Cost : Total Annual Costs (O&M) :

____________________ Total Annualized Costs Requested : There is no additional cost burdens associated with this collection. 14. Provide estimates of annualized cost to the Federal government. Also, provide a descrip tion of the method used to estimate cost, which should include quantification of hours, operational expenses (such as equipment, overhead, printing, and support staff), and any other expense that would not have been incurred without this collection of info rmation. Agencies also may aggregate cost estimates from Items 12, 13, and 14 in a single table. There is no new sy stem start - up cost to the Federal government related to this collection. 15. Explain the reasons for an y program changes or adjustments. Generally, adjustments in burden result from re
- estimating burden and/or from economic phenomenon outside of an agency ’ s control (e.g., correcting a burden estimate or an organic increase in the size of the reporting universe). Program changes result from a deliberate action that materiall y changes a collection of information and generally are result of new statute or an agency action (e.g., changing a form, revising regulations, redefining the respondent universe, etc.). Burden changes should be disaggregated by t ype of change (i.e., adjustment, program change due to new statute, and/or program change due to agency discretion) , ty

pe of collection (new, revision, extension, reinstatement with change, reinstatement without change) and include totals for changes in burden hours , responses and cost s (if applicable)
. This is a new information collection request. This is a program change that, b y requiring the graduation and debt information be reported to the Department directly as well as requiring it be made available to prospective U.S., will ensure that prospective U.S. students can make informed decision when selecting a foreign graduate medical school. 16. For collections of information whose results will be published, outline plans for tabulation and publication. Address any complex analy

tical techniques that will be used. Provide the time schedule for the entire project, including beginning and ending dates of the collection of information, completion of report, publication dates, and other acti ons. The Department intends to publish the provided graduation and debt information on a Departmental consumer web site. The first reporting to the Department is due on April 30, 2013. 17. If seeking approval to not display the expiration date for OMB approval of the information collection, explain the reasons that display would be inappropriate.7

ICRAS Tracking and OMB Number: (XXXX) 1845
-NEW v1 Revised: 12 / 11 /2012 RIN Number: XXXX
- XXXX (if applicable) The Department is not seeking this approval. 18. Explain each exception to the certification statement identified in the Certification of Paperwork Reducti on Act. The Department is not requesting an y exceptions to the “Certification for Paperwork Reduction Act Submissions” of OMB Form 83
- 1.