Public Comment

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
Development and running of database queries

Total Time
(in hours)
4

Initial review of query results and perform calculations
Compliance review of proposed submission
Development/update of marketing and disclosure
materials
Total

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
[email protected]

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