Foreign Schools Medical, Veterinary, & Nursing Program Update

1. Session 43 Foreign SchoolsMedical, Veterinary, & Nursing Program Update Barbara Hemelt, Mike Stein, and David Bartlett | Dec. 2013 U.S. Department of Education 2013 FSA Training Conference for Financial Aid Professionals

2. Session Agenda • Funding Summary • Medical Schools • Clinical Sites and Agreements • Pass Rate Requirements - United States Medical Licensing Examinations • Educational Commission for Foreign Medical Graduates • Access to Data • Consumer Information on Medical Schools • Currently required submissions • Future required submissions • Student Aid website • Veterinary Schools • Accreditation Requirement by July 1, 2015 • Nursing Schools • Eligibility Requirements That Became Effective July 1, 2012

3. 2012-2013 Funding Summary • During the 2012-2013 award year, foreign institutions received a total of: • $1,075,677,734 • During the 2012-2013 award year, schools with a medical program received: • $698,901,552 (65%)

4. Medical Schools

5. Basic Science and Clinical Locations • No portion of a foreign medial program offered to U.S. students, other than the clinical training portion, may be outside of the country in which the main campus of the foreign medical school is located • Clinical training sites may be in the U.S. • Eligibility applications must list locations of all basic science and clinical sites, except clinical training sites not regularly used but chosen by individual students taking no more than 2 electives at the site for no more than a total of 8 weeks • Attach list of non-U.S sites on an attachment to the application

6. Clinical Locations in Other Countries Clinical training sites may be in countries other than the U.S. or the country where the main medical program is located in three situations: • The clinical site meets the following three requirements: • must be located in an NCFMEA approved comparable foreign country; • the medical school’s accreditor must have conducted an on-site evaluation and specifically approved the clinical training site; and • the clinical instruction must be offered in conjunction with medical educational programs offered to students enrolled in accredited medical schools located in that approved foreign country; OR • The clinical site is included in the accreditation of a medical program accredited by the LCME or the AOA; OR 3. No student takes more than 2 electives at the clinical site and the combined length of the electives does not exceed 8 weeks

7. Clinical Agreements Core Clinical Training or Required Clinical Rotations • Medical school must have formal affiliation agreements with sites at which all or a portion of school’s core clinical training or required clinical rotations are provided, and; Not-Required Clinical Rotations • Medical school must have either a formal affiliation agreement or other written arrangement with any site at which not required clinical rotations are provided, except: • written clinical agreements are not required for those elective clinical arrangements that are not used regularly, but are chosen by individual students who take no more than two electives at the location for no more than a total of eight weeks

8. Clinical Agreements • Clinical site agreements must address six elements: • Maintenance of the school’s standards • Appointment of faculty to the medical school staff • Design of the curriculum • Supervision of the students • Evaluation of student performance • Provision of Liability Insurance

9. Clinical Agreements • The medical school must submit its clinical agreements with hospitals and clinics to the Department with the school’s eligibility application • The medical school must seek approval for any new clinical sites added between certifications • The medical school must also submit a statement on letterhead stationery that is signed by the dean of the medical school, or his/her designee, that certifies that the required six elements have been addressed in the clinical agreement

10. Sample Clinical Agreement Certification I, [name and title] of [name of medical school], [name of city, country], certify that the attached clinical agreement between [name of medical school] and [name of clinical training provider], dated [date of agreement], addresses the following six (6) elements which are set forth in the sections, pages and paragraphs indicated below: • Maintenance of the school’s standards (Section __, Page __, Paragraph ___) • Appointment of faculty to the medical school staff (Section __, Page __, Paragraph) • Design of the curriculum (Section __, Page __, Paragraph ___) • Supervision of the students (Section __, Page __, Paragraph ___) • Evaluation of student performance (Section __, Page __, Paragraph ___) • Provision of Liability Insurance (Section __, Page __, Paragraph ___) _______________ __________________ Name and Title (Dean of Medical School) Date

11. Supervision and Faculty Appointments • The clinical agreement must • State that the medical school has, does, or will appoint clinical training faculty from the clinical training site as adjunct members of the medical school faculty, or; • Submit documentation that demonstrates the medical school has appointed training faculty from the clinical training site as adjunct members of the medical school faculty • E.g. Letter from medical school dean indicating names of appointed faculty at clinical sites or acceptance letters from appointed clinical site faculty, or; • Explain how medical school addresses “Appointment of faculty to the medical school staff” and how its faculty closely supervises the clinical training provided at the site

12. USMLE Pass Rate Requirements Statutory: The reauthorization of the Higher Education Act in August 2008 increased the annual USMLE pass rate threshold from 60% to 75%, effective July 1, 2010. Foreign medical schools are required to demonstrate that their schools’ students and graduates who took Step 1, Step 2-CS, or Step 2-CK of the medical exams administered by the ECFMG in the preceding calendar year achieved a minimum 75% pass rate

13. USMLE Pass Rate Requirements Regulatory: Regulations issued on November 1, 2010 and effective July 20, 2011 made additional changes: • The 75% minimum pass rate applies separately to Step 1, Step 2- Clinical Knowledge (CK) and Step 2- Clinical Skills (CS) • Failure to meet the 75% rate on Step 1, Step 2-CK or Step 2-CS would constitute a failure leading to a loss of eligibility of the medical program • Only first-time test takers are included in the calculation. Repeat test takers are not included • Individual test taker performance data must be provided in addition to the of passing percentage rate on Step 1, Step 2-CK or Step 2-CS exams

14. Additional Rules for Pass Rate Calculations Rule of 8 If the calculation of the pass rate would result in a pass rate for Step 1, Step 2-CK, or Step 2-CS based on fewer than eight (8) results, a single pass rate for the school is determined instead by combining the performance of the school’s students and graduates on all three step tests If combining the results on all three step tests would still result in a pass rate based on fewer than eight (8) test results, the school is deemed to have no pass rate for that year and the results for the year are combined with each subsequent year until a pass rate based on at least eight (8) test results is derived

15. Exemptions from 75% Pass Rate • 1992 EXEMPTION If a foreign medical school had a State-approved clinical training program as of January 1, 1992, and the school has continued to operate a clinical training program in at least one State that approves the program, the school is exempt from having to meet the 75% pass rate requirement • Only 3 foreign medical schools currently qualify for this exemption • Although exempt from the pass rate calculation, the school is not exempt from the requirement to submit individual test taker performance data

16. Exemptions from 75% Pass Rate Exemption for Canadian Medical Schools • Not subject to the 75% pass rate requirement • Must submit the individual test taker performance data

17. Individual Test Taker Performance Data In addition to the medical school’s pass rates, federal regulations require medical schools to submit individual student and graduate data to ED by April 30 of each year, to include, test performance data disaggregated by test: • Test taker identifier for each test taker (do not use PII) • Test taker status (student or graduate) • Year of graduation • Test Taken (Step 1, Step 2-CK or Step 2-CS) • Date Test taken • Score • Result, including any failed tests • Attempt (First or Repeat) The foreign medical school is responsible for obtaining all necessary consents from test takers in order to collect and submit this performance data the ED

18. Calculation of Pass Rate Numerator for Step 1, Step 2- CK, and Step 2- CS: Any of the students or graduates in the denominator who achieved a passing score on that Step/test Denominator for Step 1, Step 2- CK, and Step 2- CS: Each student who took the Step/test for the first time in the preceding calendar year, and Each graduate who took the Step/test for the first time in the preceding calendar year and who graduated from the school either during that year or the two preceding calendar years

19. Results – By Year Foreign medical schools that failed to meet the USMLE requirements: Some of these medical schools have since regained eligibility

20. Period of Loss of Eligibility • A foreign medical school’s eligibility for the current year is determined by its USMLE test results from the prior calendar year • If a foreign medical school loses eligibility under this section, its period of ineligibility will be at least one year. (18 months, if terminated) • The due date for the USMLE data submission is April 30th – 4 months into the current year. The loss of eligibility occurs on the submission due date and the loss of eligibility period continues thereafter for at least one year (e.g., May 1, 2012 to April 30, 2013 for loss based on 2011 data)

21. Continuing Student Eligibility • Institution may disburse Direct Loans and process loan deferments for students currently enrolled at the institution or program if: • The student was enrolled at the institution or program prior to the loss of eligibility • The student has previously borrowed FFEL or Direct Loan program loans to attend the institution or program and; • The student has remained continuously enrolled

22. Reinstatement • A medical school can apply for reinstatement if it has been “out” for the requisite one year or eighteen months and can demonstrate that its prior calendar year’s test data meets the USMLE 75% pass rate requirement • A “no score” status is insufficient for reinstatement • The school must also submit the required test taker data, and continue to satisfy all other relevant Title IV, HEA eligibility requirements

23. Educational Commission for Foreign Medical Graduates ECFMG

24. ECFMG Certification • ECFMG certification is a requirement to enter a U.S. residency or fellowship program accredited by the Accreditation Council for Graduate Medical Education (ACGME) • ECFMG certification is also a requirement to obtain an unrestricted license to practice medicine in the United States • To be certified by ECFMG, a medical student must complete the Application for ECFMG Certification, pass a series of exams administered by ECFMG, and fulfill medical education credential requirements, which ECFMG will verify directly with the student’s medical school

25. Access To ECFMG Data • Since 2009, the ECFMG Medical School Web Portal (EMSWP) has provided access to ECFMG’s services for international medical schools • ECFMG will provide international medical schools with data on the performance of their students and graduates on administrations of USMLE Step 1,USMLE Step 2 Clinical Knowledge, and USMLE Step 2 Clinical Skills tests • Data may be provided to schools on examinees individually and in aggregate • Medical schools must complete a medical school profile survey in order to have access to test performance data • To participate, the medical school must establish an account with EMSWP. Information and request forms can be obtained by e-mailing the ECFMG EMSWP Administrator at EMMSWPAdmin@ecfmg.org

26. Access to ECFMG Data • Aggregate Data Reports: Aggregate Data Reports are provided to eligible medical schools on an annual basis. Aggregate Data Reports include: the number of examinees who took each exam, provided there are at least five test takers; the number and percentage of the school’s examinees who passed each exam, broken out by first attempts and repeat attempts for Step 1, Step 2 CK, and Step 2 CS. This report does not satisfy the Department’s test data requirements • Special Report: This report best accommodates the Department’s regulations by presenting data solely for first-time test takers and by limiting data on examinees who are graduates to the three-year period specified in the regulations. Schools must specifically request this report.

27. Access to ECFMG Data Data on Individual Examinees: • Data is available on the performance of a medical school’s graduates and students on USMLE Step 1, Step 2 CK, and Step2 CS, on an individual basis • The medical school can access an individual student or graduate’s test data electronically through the ECFMG Medical School Web Portal (EMSWP). This data is available for 120 days after the examinee’s score report becomes available • USMLE Student Transcript: A medical school may request an Official USMLE Transcript (Form 173) for an individual student/graduate that includes a complete results history of all USMLE Steps taken by the student/graduate. A fee is charged for a transcript • Form 173-B of the transcript request contains the student/graduate’s authorization and request to ECFMG to release the USMLE transcript to the medical school. The student or graduate must sign and date the authorization

28. ECFMG Data – Student “Opt Out” • A student (or graduate) can request to have their individual performance data withheld from their medical school • To have results withheld from the medical school, the test taker must submit a request thru ECFMG’s website at least 10 days before the test taker’s scheduled test date • A request to have exam results withheld is valid for one exam administration only. The test taker must submit a separate request for each exam administration • The request applies only to the reporting of individual performance data. If the test taker’s medical school is eligible to receive aggregate performance data on its students and graduates, the test taker’s results will not be excluded from the Aggregate Data Report as a result of this request

29. Contact ECFMG • ECFMG representatives are available to answer your questions by • E-mail at info@ecfmg.org, or • Phone at 215-386-5900, from 9:00 a.m. to 5:00 p.m., Monday through Friday • Information and request forms to obtain an account to access the EMSWP web portal can be obtained by e-mailing the ECFMG EMSWP Administrator at EMMSWPAdmin@ecfmg.org

30. Consumer Information

31. Consumer Information on Foreign Medical Schools Currently Required Submissions to the Department: • On time completion rates of U.S. students • Mean and median student debt levels • USMLE pass rates • Citizenship rates Future Required Submissions to the Department: • MCAT scores of U.S. students • U.S. medical residency placements of U.S. students Note: Other consumer disclosure requirements apply to all foreign schools that participate in the Direct Loan program

32. Consumer Information on Foreign Medical Schools Foreign Medical School Consumer Information is now displayed on StudentAid@ed.gov http://studentaid.ed.gov/prepare-for-college/choosing-schools/types/international

33. Foreign Veterinary Schools

34. Eligibility Criteria to Participate • The veterinary school provides a program of clinical and classroom instruction that is: • Supervised closely by members of the school’s faculty • Provided in facilities adequately equipped and staffed • Approved by all veterinary licensing boards and evaluating bodies whose views are considered relevant by ED • Effective July 1, 2015, a foreign veterinary school must be accredited or provisionally accredited by an organization acceptable to ED

35. Eligibility Criteria for Veterinary Schools • School has graduated classes during each of the two preceding 12-month periods • School employs faculty members whose academic credentials are equivalent of faculty members teaching at veterinary schools in the U.S. • No portion of the non-clinical training is offered outside of the country where the main campus is located

36. Veterinary Clinical Sites • Students at for-profit schools must complete clinical training in the U.S. • Students at public or private non-profit schools must complete their clinical training • In the country where the school’s main campus is located; • In the U.S.; or • Outside U.S./home country, if the site is accredited by AVMA or individual student takes no more than 2 electives at the location and the combined length of the electives does not exceed 8 weeks

37. Foreign Nursing Schools

38. Foreign Nursing Schools Effective Dates of New Requirements • July 1, 2012 for foreign nursing schools that were participating in the Title IV, HEA programs on August 13, 2008 • July 1, 2011 for all other foreign nursing schools

39. Eligibility Criteria for Nursing Schools • Associate degree, collegiate, or diploma school of nursing • Agreement with U.S. hospital or U.S. accredited nursing school to require completion of clinical training in U.S. • Graduating students receive both a degree from the accredited U.S. nursing school and the home institution • Reimburse ED for loan defaults - cost of a loan default is the estimated future cost of collections

40. Eligibility Criteria for Nursing Schools • At least a 75% pass rate on National Council Licensure Examination for Registered Nurses (NCLEX-RN). Must provide to ED, either: • NCLEX-RN exam results for U.S. students and graduates; or • NCSB reports showing percentage of U.S. students and grads who passed the NCLEX-RN in the preceding year • NCSB – National Council of State Boards

41. For-Profit Med/Vet/Nursing For a for-profit foreign medical, veterinary, or nursing school (34 CFR 600.54(f))– • No portion of an eligible medical or veterinary program may be offered at what would be an undergraduate level in the U.S. • Title IV, HEA program eligibility does not extend to any joint degree program (except where allowed for nursing schools)

42. Contacts We appreciate your feedback and comments. We can be reached at: Foreign Schools Participation Division Phone: 202-377-3168 Fax:        202-275-3486 E-mail:    FSA.Foreign.Schools.Team@ed.gov Barbara Hemelt Phone: 202-377-4201 E-mail: barbara.hemelt@ed.gov Mike Stein Phone: 202-377-4573 E-mail: michael.stein@ed.gov David Bartlett Phone: 816-268-0434 E-mail:david.bartlett@ed.gov

43. QUESTIONS?