Dear Colleague:
Foreign medical schools that participate in the Federal Direct Loan Program are required under 34 CFR §600.55 to meet requirements that involve calculating and submitting students’ scores on the United States Medical Licensing Examination (USMLE). The scores must be disaggregated by step/test and attempt and must represent the scores earned by students and graduates during the preceding calendar year.
Traditionally, these scores were the results of students and graduates completing the USMLE steps which included Step 1, Step 2-Clinical Skills (CS) and Step 2-Clinical Knowledge (CK). In May 2020, the Step 2-CS exam was suspended due to the COVID-19 pandemic. In January 2021, the National Board of Medical Examiners and the Federation of State Medical Boards, the organizations that oversee the USMLE program, announced that the Step 2-CS exam would be cancelled permanently. The consequence of the cancellation of the Step 2-CS exam impacts two paragraphs of 34 CFR 600.55, namely (d) and (f).
34 CFR 600.55(d)(1)(iii) requires all foreign medical schools to submit scores, disaggregated by step/test and attempt, earned during the preceding calendar year by each student and graduate, on Step 1, Step 2-CS, and Step 2-CK, of the USMLE, together with the dates the student has taken each test, including any failed tests. This data must be submitted to the Department by April 30 of each year. Due to the cancellation of Step 2-CS, foreign medical schools will remain in compliance by timely submitting their students’ scores on Step 1 and Step 2-CK of the USMLE, together with the dates the student has taken each test, including any failed tests. 34 CFR 600.55(d)(2) allows schools meeting certain requirements to allow the Educational Commission for Foreign Medical Graduates (ECFMG) or other responsible third party to calculate and submit the rate to the Department on the school’s behalf. For schools meeting the requirements for this option, this particular provision remains unchanged other than there will obviously be no scores for Step 2-CS.
34 CFR 600.55(f)(1)(ii) establishes an institutional eligibility requirement for some foreign medical schools based on USMLE scores. The requirement sets a minimum threshold for passing scores on the USMLE and schools must meet or exceed the threshold. The regulatory threshold states that at least 75 percent of the school's students and graduates who took that step/test of the USMLE in the year preceding the year for which any of the school's students seeks a Title IV, HEA program loan must have received a passing score on that step/test and are taking the step/test for the first time. In the past, those scores would have included scores earned on Step 2-CS. Note that foreign medical schools in Canada are exempt from this particular requirement as are foreign medical schools who meet the requirements in 600.55(f)(2). For data submitted in 2022, pertaining to the previous calendar year, foreign medical schools subject to 600.55(f)(1)(i) will remain in compliance by meeting the regulatory threshold based on the results of the remaining USMLE steps, i.e., Step 1 and Step 2-CK. The regulations under 600.55(f)(4) address foreign medical schools with a pass rate based on fewer than eight students. This particular provision remains unchanged other than there will obviously be no scores for Step 2-CS.
The guidance contained herein is effective for data submitted to the Department to meet the April 30, 2022, deadline and will be applicable to subsequent years.
If you have questions about foreign medical school institutional eligibility, please use the Contact Customer Support form in FSA’s Partner Connect Help Center. To submit a question, enter your name, email address, topic, and question. When submitting a question related to this Dear Colleague Letter, please select the topic “FSA Ask-A-FED/Policy.”
Thank you for your continued support of the Title IV federal student aid programs.
Sincerely,
Annmarie Weisman
Deputy Assistant Secretary
for Policy, Planning, and Innovation