February 18, 2013

Director, Information Coll ection Clearance Division U.S. Department of Education 400 Maryland Avenue SW LBJ, Room 2E117 Washington, DC 20202-4537

RE: Notice of Proposed Information Collection Federal Register, December 19, 2012
ED-2012-ICCD-0069

Dear Director:

Thank you for the opportunity to comment on the proposed information collection request, Foreign Gradu ate Medical School Consumer Information Reporting Form. This response is being made on behalf of the following DeVry inst itutions: Ross University School of Medicine and American University of the Cari bbean School of Medicine, which together serve approximatel y 5,000 U.S. students.

We applaud the efforts of the D epartment to ensure that students enrolling in medical progr ams offered at foreign institutions have access to appropriate consumer information to assist them in selecting the

institution that best meets their e ducational and career objectives.

Our commentary will include a discussion of:

 Instructions

 Similarity to Gainful Empl oyment reporting requirements

 Burden

Instructions

There are two areas within the Co nsumer 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 calculati ons required for this information disclosure, it would be helpful if “U.S. student” were clearly defined in

the instructions. In mo st areas, the form refer ences “U.S. students”, but on the first page of the instructions under “Information to Disclose to Prospective U.S. Students”, the inst ructions 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 the instructions

for the disclosure form to include a def inition 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 y ear, 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 calculat ions required for completion of this

form.

Similarity to Gainful Employment reporting requirements

For-profit institutions are already required by Gainful Employment regulations to calculate and disclos e (§668.6(b)) nearly identical student debt and on-time completion informat ion. However, the regulation requires reporting by award year (§668.6( c)(1)), not by calendar year as in the proposed collection. As a resu lt, 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 subj ect to this reporting requirement and the Gainful Employment disclosure requirements be either aligned or that institutions subject to t he Gainful Employment disclosure requirements be exempted from the di sclosure requirement within this

rule.Burden

We believe the burden hours calc ulated by the Department of

Education underestimate the time inst itutions will devote to performing the calculations and completing the asso ciated 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 result s and perform calculations 6

Compliance review of proposed submission 6

Development/update of marketing and disclosure

materials 16

Total 32

Thank you again for the opportunity to comment on this proposed

information collection. Please fe el free to contact me with any questions regarding these comments.

Sincerely,

Thomas Babel Vice President, Regulatory Affairs DeVry Inc. 3005 Highland Parkway Downers Grove, IL 60515-5799

(630)515-3133 tbabel@devry.edu