ICRAS 1469 1845-0106 v2 – Affected Public – Private Institutions 7/18/2013

This request is to extend the information collection for the requirements in the policies and 

procedures related to the eligibility of foreign schools to apply to participate in Title IV, HEA programs 

that were added by the Higher Education Opportunity Act of 2008 (HEOA). The HEOA added specific 

reporting requirements for foreign graduate medical schools in relation to acceptable minimum test 

scores. These regulations continue the policies to ensure comparability between domestic institutions and 

foreign institutions regarding academic year definitions for non-degree programs and showing the method 

used to show that equivalency. And these regulations continue requirements to development and 

collection of consent forms that students in graduate medical programs will have to complete to allow the 

schools to request specified test scores from appropriate testing agencies and to then report those scores to 

their accrediting agency, and the Department as required. Also the regulations continue the additional 

reporting by graduate medical schools to their accrediting agencies of any material changes to the 

education programs offered or changes to the oversight bodies or affiliation agreements with hospitals and 

clinics. Foreign graduate medical schools are also required to publish all of the languages in which 

instruction is offered.

The information identified below is used by the Department during the initial review for 

eligibility certification, recertification and annual evaluations. These regulations help to ensure that all 

foreign institutions participating in the Title IV, HEA programs are meeting the minimum participation 

standards. 

§600.54 – Criteria for determining whether a foreign institution is eligible to apply to participate in the 

Direct Loan Program.

The regulation §600.54 (e)(3)(ii) requires foreign institutions receiving Title IV, HEA program 

funds to demonstrate to the satisfaction of the Department that their method of determining academic 

work in a non-degree program is equivalent to the definition of an academic year that is required for 

domestic schools (§668.3) in determining program eligibility. This determination is made on a program 

by program basis by the Department in both initial and recertification reviews.

§600.55 – Additional criteria for determining whether a foreign graduate medical school is eligible to 

apply to participate in the Direct Loan Program.

Regulation §600.55(c)(2) requires a foreign graduate medical school to determine the consent 

requirements to meet their specific country’s privacy laws and require the necessary consents of all 

students, who are U.S. citizens, nationals, or eligible permanent residents, that have been accepted for 

admission to enable the foreign school to comply with the collection and submission requirements in 

§600.55(d) for Medical College Admission Test (MCAT) scores, residency placement, and U.S. Medical 

Licensing Examination (USMLE) scores. 

Section 600.55(d) includes the changes to reporting requirements for foreign graduate medical 

schools as identified in HEOA Section 102(a)(2)(A)(i). 

The regulations in §600.55(d)(1) require a foreign graduate medical school to obtain, at its own 

expense, and by April 30 of each year submit to its accrediting authority for all students who are U.S.

citizens, nationals, or eligible permanent residents: (i) MCAT scores, for those admitted during the 

preceding award year and the number of times each student took the exam; (ii) the percentage of students 

graduating during the preceding award year who are placed in an accredited U.S. medical residency; (iii) 

all USMLE scores earned during the preceding award year, disaggregated by step 1, step 2-CS and step2-

CK, by each student and graduate and the date each student took each test, including any failed tests and 

(iv) a statement of its citizenship rate for the preceding calendar year and the methodology used to obtain 

the rate. A school would have to submit the data on MCAT scores and placement in an U.S. residency to 
ICRAS 1469 1845-0106 v2 – Affected Public – Private Institutions 7/18/2013

the Department only upon request, but would be required to submit the USMLE data to the Department 

by April 30, unless notified by the Department. These changes are required by statutory changes in 

HEOA section 

Regulation §600.55(d)(2) allows for certain foreign medical schools to allow direct reporting of 

USMLE and/or citizenship pass rates to the Secretary by the Educational Commission for Foreign 

Medical Graduates (ECFMG) or another responsible third party. This will require the school to submit a 

written consent acceptable to the Department in which the school agrees that the pass rates calculated will 

be considered conclusive for purposes of compliance with the required rates. In this context, ECFMG or 

others will contract with the Department, and the school’s burden is based on development and 

submission of acceptable written consent to use the rates as calculated.

The regulations at §600.55(e)(2) require a foreign graduate medical school to notify their accrediting 

body within one year of any material changes in (1) the educational programs, including clinical training 

programs; and (2) the overseeing bodies and in the formal affiliation agreements with hospitals and 

clinics.

Finally, the regulations in §600.55(g)(3) require a foreign graduate medical school to publish all 

the languages in which instruction is offered.

The burden hours calculated below include time for reviewing the regulations; for determining 

the method and means to incorporate any changes; develop or update systems and forms and formats for 

gathering the required information; and to prepare any required reports. The burden is all related to 

reporting. The Department is identifying a net overall decrease in the amount of burden related to these 

regulations due to a change in the number of institutions participating in the foreign school graduate 

medical programs.

Section 600.54 – Criteria for determining whether a foreign institution is eligible to apply to participate in 

the Direct Loan programs.

§600.54 (e)(3) – Demonstration of academic year equivalency in non-degree programs.

# of Respondents # of Responses Hrs/Response # of Burden Hours

Private institutions

28 28 X .17 5

Section 600.55 – Additional criteria for determining whether a foreign graduate medical school is eligible 

to apply to participate in the Title IV, HEA programs.

§600.55(c)(2) – Admission criteria

# of Respondents # of Responses Hrs/Response # of Burden Hours

Private institutions

 5 5 X .50 3

§600.55(d)(1) – Collection and submission of data.

# of Respondents # of Responses Hrs/Response # of Burden Hours

Private institutions

3 3 X 1.41 4

§600.55(d)(2) – Alternate submission of data.

# of Respondents # of Responses Hrs/Response # of Burden Hours

Private institutions

2 2 X .75 2
ICRAS 1469 1845-0106 v2 – Affected Public – Private Institutions 7/18/2013

§600.55(e) – Requirements for clinical training.

# of Respondents # of Responses Hrs/Response # of Burden Hours

Private institutions

1 1 X .82 1

§600.55(g) – Other criteria.

# of Respondents # of Responses Hrs/Response # of Burden Hours

Private institutions

5 5 X .33 2

TOTALS

Responses 44

Respondents 44

Burden Hours 17