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(GEN-12-20) Subject: Consumer Information Reporting Requirements for Foreign Graduate Medical Schools

Publication Date: November 7, 2012

DCL ID: GEN-12-20

Subject: Consumer Information Reporting Requirements for Foreign Graduate Medical Schools

Summary: This letter provides guidance on new consumer information reporting requirements for foreign graduate medical institutions.

Dear Colleague:

The purpose of this letter is to inform foreign graduate medical institutions that participate in the William D. Ford Federal Direct Loan Program (Direct Loan Program) authorized under Title IV of the Higher Education Act of new consumer information reporting requirements. 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. Beginning with data from the 2012 calendar year, participating foreign institutions that offer Title IV eligible graduate medical programs must report completion rates and median and mean student debt levels for students completing the program. This new reporting requirement is in addition to the United States Medical Licensing Examination (USMLE) pass rates that are already required to be reported by these institutions for these programs. It is also in addition to the current reporting of the program’s citizenship enrollment rate, as required under 34 CFR 600.55(d)(1)(iv).

New Reporting Requirements

Foreign graduate medical schools must submit, on an educational program by program basis, the data described below, on a form approved by the Secretary, to the Department by the April 30 following the end of each calendar year, starting with April 30, 2013:

  1. The on-time completion rate for U.S. students completing the medical program in the previous calendar year (e.g., calendar year 2012 for the April 13, 2013, submittal), where a student will be considered to have completed the medial program “on-time” if the student completes all requirements for the degree within the time specified in the institution’s catalog or on its Web site;

  2. The median and mean Title IV loan debt, the median and mean private educational loan debt, the median and mean institutional education loan debt, and the median and mean combined educational loan debt incurred by U.S. students who completed the program in the previous calendar year. Thesemedians and means should include only the debt incurred by the students for attendance in the medical program.

For the purposes of the median and mean Title IV loan debt reporting requirements, all loans provided under the Federal Family Education Loan (FFEL) Program and the William D. Ford Federal Direct Loan (Direct Loan) Program are to be included in the calculation of Title IV loan debt.

For the private educational loan median and mean loan debt, the Truth-in-Lending regulations, at 12 CFR 226.46(b)(5), provide the definition of a private education loan. Examples of private education loans include, but are not limited to, loans made expressly for educational expenses by financial institutions, credit unions, institutions of higher education or their affiliates, and States and localities.

For the median and mean institutional education loan debt, institutions must include any loan (other than a Direct Loan or a loan that would be considered a private education loan), extension of credit, payment plan, or other financing mechanism that results in a debt obligation that a student must pay to an institution after completing the program and that is outstanding at the time that the student completes the program.

For the median and mean combined education loan debt, the combined education loan debt includes all loans provided under the FFEL and Direct Loan Programs, private education loans, as defined above, and institutional education loan debt, as defined above.

The attachment to this letter is a draft version of the reporting form that is currently in the Department’s review process. Though the Department will provide further guidance when the form is approved, this draft attachment will give institutions an initial idea as to the manner in which the data must be reported.

Reporting of USMLE Pass Rates

The Department’s regulations, at 34 CFR 600.55(d), require all foreign graduate medical institutions, even those that are exempt from the USMLE pass rate threshold requirement, to submit all USMLE scores, disaggregated by step/test and attempt, earned during the preceding calendar year by each student and graduate, on Step 1, Step 2-CK, and Step 2-CS of the USMLE, together with the dates the student took each test, including any failed tests.

The regulations require that institutions determine the consent requirements for, and require the necessary consents of, all students accepted for admission for whom the school must report, to enable the school to comply with these collection and submission requirements. The data must be obtained and submitted to the Department by the school at its own expense by April 30 of each year.

Disclosure of Data Reported to the Department

The Department will publish all of the information covered by the letter on its Web site. To protect the privacy of students, the Department will not publish information about a foreign graduate medical institution if the number of students used in the relevant calculation is fewer than eight.

If you have questions regarding the information in this letter, you may contact Federal Student Aid’s Foreign Schools Participation Division at (202) 377-3168 or at

Thank you for your continued participation in the William D. Ford Federal Direct Loan Program.


David A. Bergeron
Acting Assistant Secretary
Office of Postsecondary Education

Last Modified: 11/06/2012