Mr. Babel:

Thank y ou for taking the time to submit comments on the form and burden estimates for the Foreign Graduate Medical School Consumer Information Reporting Form ED

- 2012

- ICCD

- 0069. Your comments have been reviewed and below is our response includ ing any changes made to the proposed instructions and form. Your letter included 3 sections with questions and comments. The first section asked for clarification in the instructions referencing the definition of U.S. students and the reporting period.

“ Instructions There are two areas within the Consumer Information Reporting Form instructions for which we would like to request clarification: definition of U.S. student and reporting period. Definition of U.S. student To assist foreign graduate medical schools in identify ing the appropriate population to include in the calculations required for this information disclosure, it would be helpful if “U.S. student” were clearly defined in the instructions. In most areas, the form references “U.S. students”, but on the first page of the instructions under “Information to Disclose to Prospective U.S. Students”, the instructions refer to “the cohort of American students”, implying that onl y U.S. citizens should be included in the population for the report.
As an example, 34 CFR 600.55(d)(1)(i) specifies the MCAT score reporting requirement applies to “U.S. citizens, nationals, or eligible permanent residents”. This makes it very clear which students should be accounted for in the report. We recommend updating th e instructions for the disclosure form to include a definition of “U.S. student” similar to the one found in this regulation. Reporting period Throughout the instructions, three distinct reporting periods are mentioned, including: calendar year, academic ye ar, and award y ear. The use of all three timeframes for the report could cause confusion for the ty pical consumer. We believe award year should be used as the reporting period for all of the calculations required for completion of this form. ” Regarding the definition of U.S. student, we agree that such a definition will be useful and have revised the instructions to include the following : The definition of U.S. Student for the purposes of this consumer information collection is in 34 CFR 668.33 (a)(1) “Be a citizen or national of the United States; or” (2) “Provide evidence from the U.S. I mmigration and Naturalization Service that he or she

–(i) Is a permanent resident of the United States; or

(ii) I s in the United States for other than a temporary purpose with the intention of becoming a citizen or permanent resident;...”. Regarding the reporting period, the instructions and form in the 60 day comment period included the incorrect file. The reporting period for this information is calendar ye ar t o coordinate with the annual reporting of the U.S. Medical Licensing Examination (USML E) score requirement. All references to reporting period on the instructions and form now indicate calendar year. I apologize for the earlier error. The second section commented on the requirement to publish the findings of this report on the institution’s website and noted the similarity to required Gainful Employ ment requirements. **Similarity to Gainful Employment reporting requirements** For

- profit institutions are alr ead y required b y Gainful Employ ment regulations to calculate and disclose (§668.6(b)) nearl y identical student debt and on

- time completion information. However, the regulation requires reporting b y award ye ar (§668.6(c)(1)), not by calendar y ear as in the proposed collection. As a result, for

- profit institutions would have to calculate and disclose the same basic metrics for two different timeframes. We believe this is an undue burden, but more importantly it will likely

cause confusion among consumers, the media, regulatory agencies, and other interested parties. We either recommend that the reporting ye ars for institutions subject to this reporting requirement and the Gainful Emplo yment disclosure requirements be either aligned or that institutions subject to the Gainful Employ ment disclosure requirements be exempted from the disclosure requirement within this rule.
As Istated, the incorrect form was published with the 60 day notice and there is no requirement for the institution to include this reporting on their website. The information collect ed by this required reporting will be published by the U.S. Department of Education on the following web page: http: //studentaid.ed.gov/prepare

- for

- college/choosing

- schools/ty pes/international

. The third section commented on the suggested burden hours for this reporting task. We believe the burden hours calculated b y the Department of Education underestimate the time institutions will devote to performing the calculations and completing the associated form. We estimate that it will take approximately 11 hours per institution to prepare the data and complete the disclosure form.
**Task Total Time (in hours)**  De velopment and running of database queries 4 Initial review of query

results and perform calculations 6 Compliance review of proposed submission 6 Development/update of marketing and disclosure materials 16 Total 32We agree that the previous burden estimate of 26 minutes per institution identified in the 60 day

filing was inadequate. Itappears that the total time allotted was for the completion of the form only , not for the gathering and organization of the required data. Howev er, we do not agree that each institution will require 32 hours. As identified above, the instructions and form with the initial information collection filing was the wrong file and included disclosure requirements for the institution . As that is not a r equirement of the reporting we are subtracting the proposed 16 hours for disclosure materials. We do agree that the remaining average of 16 hours per institution for the gathering and reporting of data for this reporting requirement is a fair estimate. T his change has been reflected in the 30 day filing submitted to the Office of Management and Budget. We appreciate the time you took to review the instructions and form and to formulate your comments on this information collection. Thank y ou for sharing your expertise. Sincerel y, Beth Grebeldinger U.S. Department of Education Federal Student Aid