1

ICRAS Tracking and OMB Number: ( 1957 ) 1845
- NEW v1 Revised: 3 /4 /201 3 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
. The foreign medical institutions are to provide to the Department the following inf ormation 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 by U.S. students who completed the program, the median and me an private loan debt incurred b y U.S. students who completed the program; the median and mean institutional financing debt incurred b y U.S. students completing the program; and the total median and mean debt incurred b y U.S. students who completed the prog ram. The Department’s regulations, at 34 CFR 668.14(b)(7) , require Title IV participat ing institutions to submit reports to the Department containing such information as the Secretary may reasonably

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: ( 1957 ) 1845
- NEW v1 Revised: 3 /4 /201 3 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 schools will be published on a Departmental consumer 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 electroni c submission of responses, and the basis 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 fro m the institution’s President/CEO/Chancellor so the report cannot be submitted ele ctronicall y at this time. 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 information 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 of 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 district, or special district with a population of less than 50,000. No small businesses are impac ted b y this collection. 6. Describe the consequences to Federal program or policy activities if the collection is not conducted or is conducted less frequentl y, as well as an y technical or legal obstacles to reducing burden. Without the collection and dissemination of the information via the Department’s consumer web page prospective U.S. students at a foreign medical school may not have a clear indication of total costs of the medical program they wish to attend or an indication of the successful compl etion 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. 7. Explain any

special circumstances that would cause an informat ion collection to be conducted in a manner:3

ICRAS Tracking and OMB Number: ( 1957 ) 1845
- NEW v1 Revised: 3 /4 /201 3 RIN Number: XXXX
- XXXX (if applicable)

 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 c onfidentiality 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 data with other agencies fo r 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 confidentiality to the extent pe rmitted 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 comments 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 effort s 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 elements to be recorded, discl osed, 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 perio ds. There may be circumstances that may preclude consultation in a specific situation. These circumstances should be explained. This is the 3 0 day

comment period request. There has been no change to the regulations currentl y in place. There was 1 comment received to date. The comment was reviewed and some changes were made to the instructions and form based on the suggestions made by the commenter. The burden time was increased based on the comment. 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: ( 1957 ) 1845
- NEW v1 Revised: 3 /4 /201 3 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 Impac t 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 c onsiders 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 ensit ive 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 government, individuals or households, private sector

– businesses or other fo r - 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, repor ting 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 base 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, estim ates 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 Tab le
. (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 Respo nsibilities, 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 Personall y Identifiable Information, OM : 6
- 104

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

ICRAS Tracking and OMB Number: ( 1957 ) 1845
- NEW v1 Revised: 3 /4 /201 3 RIN Number: XXXX
- XXXX (if applicable)

 Provide estimates of annualized cost to respondents of the hour burdens for collections of information, identifying and usin g 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 has revised its estimate of the time that it will take the 25 affected institutions to fulfill the reporting requirements. Based on comments received from a sector of the affected parties, we are persuaded that the original time to complete the reporting mistakenly

excluded the time fo r data gathering and required calculation time and only

identified the time needed for the completion of the form to be submitted to the Department. The Department estimates an average of 16 hours is required to complete the reporting requirements for a total of 400 hours (25 institutions by 16 hours)
. Affected Entities and Burden : Reporting required information to the Department and prospective U.S. students # of # of # of Respondents Responses Burden Hours Institutions: Not
- for
- p rofit 5 X 1 X 16 hours = 80 For Profit 3 X 1 X 16 hours = 48 Public 17 X 1 X 16 hours = 272 TOTAL 25 X 1 X 16 hours 400 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 expec ted useful life); and (b) a total operation and maintenance and purchase of services component. The estimates should take into 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 equipment, the discount rate(s), and the time period over which costs will be incurred. Capital and start - up costs include, among other i tems, 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 collection services should be a part of this cost burden estimate. In developing cost6

ICRAS Tracking and OMB Number: ( 1957 ) 1845
- NEW v1 Revised: 3 /4 /201 3 RIN Number: XXXX
- XXXX (if applicable) 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 , estim ates 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 to provid e 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 Annualiz ed 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 description 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 information. 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 resul t 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 dis aggregated 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 will ensure that prospective U.S. students can make informed decision when selecting a foreign graduate m edical school by requiring the graduation and debt information is reported to the Department o n a specifi c form
. 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 actions.7

ICRAS Tracking and OMB Number: ( 1957 ) 1845
- NEW v1 Revised: 3 /4 /201 3 RIN Number: XXXX
- XXXX (if applicable) 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. The Department is not seeking this approval. 18. Explain each exception to the certification statement identified in the Certification of Paperwork Reduction Act. The Department is not requesting any exceptions to the “Certification for Paperwork Reduction Act Submissions” of OMB Form 83
- 1.