1

ICRAS Tracking and OMB Number: (1957) 1845-NEW v1 Revised: 3/4/2013

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 copy 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 section1. Specify the 

review type of the collection (new, revision, extension, reinstatement with change, reinstatement 

without change). If revised, briefly 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 by the institution’s President/CEO/Chancellor. 

The foreign medical institutions are to provide to the Department the following 

information for all U.S. students attending its approved graduate medical programs: ontime 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 

mean private loan debt incurred by 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 and 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 reasonably require to carry out the purposes of the Title IV, HEA 

programs. This is being done to improve consumer information by providing 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: 3/4/2013

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 by 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 electronic submission of responses, and the basis for the 

decision of adopting this means of collection. Also describe any 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/Chancellor so the report cannot be submitted electronically at 

this time. 

4. Describe efforts to identify duplication. Show specifically why any similar information 

already 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 entity 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, county, town, township, school district, or special district with a 

population of less than 50,000.

No small businesses are impacted by 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 any 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 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 overborrowing in the Direct Loan Program.

7. Explain any special circumstances that would cause an information collection to be conducted 

in a manner:
3

ICRAS Tracking and OMB Number: (1957) 1845-NEW v1 Revised: 3/4/2013

RIN Number: XXXX-XXXX (if applicable)

 requiring respondents to report information to the agency more often than quarterly;

 requiring respondents to prepare a written response to a collection of information in 

fewer than 30 days 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 years;

 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 by 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 unnecessarily impedes sharing of data 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 confidentiality 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 by 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 by 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 any), and on the data elements 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 years – 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 30 day comment period request. There has been no change to the regulations 

currently 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 payment or gift to respondents, other than remuneration 

of contractors or grantees with meaningful justification.

There is no payment or gifts to respondents.
4

ICRAS Tracking and OMB Number: (1957) 1845-NEW v1 Revised: 3/4/2013

RIN Number: XXXX-XXXX (if applicable)

10. Describe any 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 Systems of Record Notice and the date a Privacy Impact Assessment was 

completed as indicated on the IC Data Form. A confidentiality statement with a legal citation that 

authorizes the pledge of confidentiality should be provided.2If the collection is subject to the 

Privacy Act, the Privacy Act statement is deemed sufficient with respect to confidentiality. If 

there is no expectation of confidentiality, simply state that the Department makes no pledge 

about the confidentially of the data.

The Department requirements do not cover any confidential information.

11. Provide additional justification for any 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 why 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 any steps to be taken to obtain their consent.

The Department is no requesting any sensitive data.

12. Provide estimates of the hour burden of the collection of information. The statement should:

 Indicate the number of respondents by affected public type (federal government, 

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 type: recordkeeping, reporting or third 

party disclosure. All narrative should be included in item 12. Unless directed to do 

so, agencies should not conduct special surveys 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 widely 

because of differences in activity, size, or complexity, show the range of estimated 

hour burden, and explain the reasons for the variance. Generally, 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 ROCIS IC Burden 

Analysis 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: (1957) 1845-NEW v1 Revised: 3/4/2013

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 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 for 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-profit 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 expected 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 system 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 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 widely, 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 cost 
6

ICRAS Tracking and OMB Number: (1957) 1845-NEW v1 Revised: 3/4/2013

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 analysis 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 to 

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 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 system start-up cost to the Federal government related to this collection.

15. Explain the reasons for any 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 materially 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 type of change (i.e., adjustment, program change due to new statute, 

and/or program change due to agency discretion), type of collection (new, revision, extension, 

reinstatement with change, reinstatement without change) and include totals for changes in 

burden hours, responses and costs (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 medical school by requiring the graduation and debt information is reported to 

the Department on a specific form. 

16. For collections of information whose results will be published, outline plans for tabulation 

and publication. Address any complex analytical 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: 3/4/2013

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.