Barbara Hemelt and Mike Stein



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Barbara Hemelt and Mike Stein | Dec. 2014

  • Barbara Hemelt and Mike Stein | Dec. 2014

  • U.S. Department of Education

  • 2014 FSA Training Conference for Financial Aid Professionals


Medical Schools

  • 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




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

    • 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

  • Provide list of non-U.S sites on an attachment to the application



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:

  • 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 a 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



Core Clinical Training or Required Clinical Rotations

  • 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


Clinical site agreements must address six elements:

  • 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


The medical school must submit its signed (by both parties) clinical agreements with hospitals and clinics to the Department with the school’s eligibility application

  • The medical school must submit its signed (by both parties) 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



Statutory:

  • 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



Regulatory: Regulations issued on November 1, 2010 and effective July 20, 2011 made additional changes:

  • 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


Rule of 8

  • 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.


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

  • 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

  • Although exempt from the pass rate calculation, the school is not exempt from the requirement to submit individual test taker performance data



Exemption for Canadian Medical Schools

  • Exemption for Canadian Medical Schools

      • Not subject to the 75% pass rate requirement
        • Must submit the 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:

  • 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
    • Identify 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



Numerator for Step 1, Step 2- CK, and Step 2- CS:

  • 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 (3 year window)



A foreign medical school’s eligibility for the current year is determined by its USMLE test results from the prior calendar year

  • 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, 2014 to April 30, 2015 for loss based on 2013 data)



Institution may disburse Direct Loans under Heightened Cash Monitoring and process loan deferments for students currently enrolled at the institution or program if:

  • Institution may disburse Direct Loans under Heightened Cash Monitoring 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


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 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

    • ECFMG “Special Report on Aggregate Performance on USMLE” is required
  • 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





Since 2009, the ECFMG Medical School Web Portal (EMSWP) has provided access to ECFMG’s services for international medical schools

  • 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



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

  • 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



Data on Individual Examinees:

  • 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



ECFMG representatives are available to answer your questions by

  • 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




Currently Required Submissions to the Department:

  • 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

  • U.S. medical residency placements of U.S. students (New)

  • Future Required Submissions to the Department:

  • MCAT scores of U.S. students

  • Note: Other consumer disclosure requirements apply to all foreign schools that participate in the Direct Loan program



Foreign Medical School Consumer Information

  • Foreign Medical School Consumer Information

  • is now displayed on

  • StudentAid@ed.gov

  • http://studentaid.ed.gov/prepare-for-college/choosing-schools/types/international





The veterinary school provides a program of clinical and classroom instruction that is:

  • 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
    • No portion of the non-clinical training is offered outside of the country where the main campus is located


Students at for-profit schools must complete clinical training in the U.S.

  • 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




Effective Dates of New Requirements

  • 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



Associate degree, collegiate, or diploma school of nursing

  • 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



At least a 75% pass rate on National Council Licensure Examination for Registered Nurses (NCLEX-RN). Must provide to ED, either:

  • 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


For a for-profit foreign medical, veterinary, or nursing school (34 CFR 600.54(f))–

  • 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)



We appreciate your feedback and comments. We can be reached at:

  • 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







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