Mr. Babel:

Thank you 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 including 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 identifying 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 only 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 the 

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 year, and award year. The use of all three timeframes for the 

report could cause confusion for the typical 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. Immigration and Naturalization Service that he or 

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

(ii) Is 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 year to coordinate with 

the annual reporting of the U.S. Medical Licensing Examination (USMLE) 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 Employment requirements.

Similarity to Gainful Employment reporting requirements

For-profit institutions are already required by Gainful Employment regulations to 

calculate and disclose (§668.6(b)) nearly identical student debt and on-time completion 

information. However, the regulation requires reporting by award year (§668.6(c)(1)), not 

by calendar year 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 years for institutions subject to this reporting requirement 

and the Gainful Employment disclosure requirements be either aligned or that institutions 

subject to the Gainful Employment disclosure requirements be exempted from the 

disclosure requirement within this rule.

As I stated, 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 collected 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/types/international. 

The third section commented on the suggested burden hours for this reporting task. 

We believe the burden hours calculated by 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)

Development 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 32
We agree that the previous burden estimate of 26 minutes per institution identified in the 60 day

filing was inadequate. It appears that the total time allotted was for the completion of the form 

only, not for the gathering and organization of the required data. However, 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 requirement 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. 

This 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 you for sharing your expertise. 

Sincerely, 

Beth Grebeldinger

U.S. Department of Education 

Federal Student Aid