February 18, 2013 

Director, Information Collection 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 Graduate Medical School Consumer 

Information Reporting Form. This response is being made on behalf of 

the following DeVry institutions: Ross University School of Medicine and 

American University of the Caribbean School of Medicine, which 

together serve approximately 5,000 U.S. students. 

We applaud the efforts of the Department to ensure that students 

enrolling in medical programs offered at foreign institutions have access 

to appropriate consumer information to assist them in selecting the 

institution that best meets their educational and career objectives. 

Our commentary will include a discussion of: 

 Instructions 

 Similarity to Gainful Employment reporting requirements 

 Burden 

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. 

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. 
Burden 

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

Thank you again for the opportunity to comment on this proposed 

information collection. Please feel 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