Foreign Medical Schools:

Education Should Improve Monitoring of Schools That Participate in the Federal Student Loan Program

GAO-10-412, Jun 28, 2010

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Each year, the federal government makes a significant financial investment in the education and training of the U.S. physician workforce. A quarter of that physician workforce is composed of international medical graduates (IMG) and they include both U.S. citizens and foreign nationals. In fiscal year 2008, the federal government loaned $633 million to U.S. students enrolled in foreign institutions--including medical students--through the Federal Family Education Loan (FFEL) program. The government also makes a substantial domestic investment in the graduate training of the physician workforce. For example, in fiscal year 2008, federal support for residency training in the United States amounted to nearly $9 billion. As with medical students educated in the United States, this training is required of all IMGs--U.S. citizens and foreign nationals alike--who seek to practice medicine without supervision in the United States. The Department of Education (Education), which administers the federal student loan program, must also monitor foreign schools that seek to participate in the program with respect to specific statutory requirements. Among these is the statutory requirement that at least 60 percent of their students who take the U.S. medical licensing exam must pass the exam. Most recently, Congress increased the pass rate to 75 percent, effective July 2010. Little is known about IMGs with respect to how much they borrow overall, or the outcome of their medical studies, leading some policy makers to question the federal return on investment in IMGs. Therefore, Congress mandated that GAO study the performance of IMGs educated at these schools and other aspects of a foreign medical education, including the potential effect of the new 75 percent pass rate requirement on school participation in the federal loan program. This report examines the following questions: 1) What amount of federal student aid loan dollars has been awarded to U.S. students attending foreign medical schools? 2) What do the data show about the pass rates of international medical graduates on license examinations? 3) To what extent does Education monitor foreign medical schools' compliance with the pass rate required to participate in the federal student loan program? 4) What is known about schools' performance with regard to the institutional pass rate requirement? 5) What is known about where international medical graduates have obtained residencies in the United States and the types of medicine they practice?

In summary, we found the following: 1) From 1998 to 2008, U.S. students enrolled at foreign medical schools borrowed $1.5 billion in FFEL loans to attend free-standing medical schools. Although this amount represents less than 1 percent of all federal student loans borrowed during this period, borrowing has grown significantly, in part because of increases in tuition, student enrollments, and the availability of additional loan funds for graduate and professional students. 2) IMGs, as a group, have consistently passed their medical licensing exam at lower rates over the past decade than their U.S.-educated peers, but have narrowed this performance gap for most of the exam steps. 3) Education has not been able to fully enforce the institutional pass rate requirement needed for continued federal student loan eligibility. The three private organizations that administer each step of the exam have declined to release student scores on grounds that the data are proprietary in nature and should not be used for marketing purposes. As a result, Education reviews pass rates only when a school applies for the program, when it periodically seeks recertification, or when there is a change in ownership. 4) Our own analysis of 2008 pass rate data of institutions located in countries that participate in the federal loan program indicates that while a majority of foreign medical schools in these countries met the current 60 percent student pass rate requirement, very few--11 percent--would likely meet the newly required 75 percent pass rate. 5) IMGs have entered into residency programs in all states, though they are concentrated in the eastern United States, and a larger proportion tend to practice in primary care than do U.S.-educated graduates. Nationwide, in academic year 2008-2009 there were 109,482 medical residents, over 30,000 of whom were IMGs (about 27 percent). Overall, few significant differences exist between all IMGs and U.S.-educated physicians with regard to either disciplinary actions that would revoke or suspend their licenses or with regard to malpractice payments--and rates of disciplinary actions are low for physicians as a whole. GAO is making several recommendations to the Department of Education concerning the lack of student consumer data on foreign medical institutions and also the department's monitoring of pass rates for foreign medical schools whose students take the U.S. medical licensing exam. We provided a draft of this report to the Departments of Education and Health and Human Services (HHS). Education agreed with our recommendations and plans to collect consumer information on foreign medical schools. In its comments, HHS noted that increasing the pass rate requirement will adversely affect federal student loan availability for future students attending foreign medical schools, adding that IMGs contribute a significant percentage of primary care residents in the United States.

Status Legend:

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  • Review Pending-GAO has not yet assessed implementation status.
  • Open-Actions to satisfy the intent of the recommendation have not been taken or are being planned, or actions that partially satisfy the intent of the recommendation have been taken.
  • Closed-implemented-Actions that satisfy the intent of the recommendation have been taken.
  • Closed-not implemented-While the intent of the recommendation has not been satisfied, time or circumstances have rendered the recommendation invalid.
    • Review Pending
    • Open
    • Closed - implemented
    • Closed - not implemented

    Recommendations for Executive Action

    Recommendation: To enhance information available for prospective students of foreign medical schools and strengthen monitoring of foreign medical schools participating in the federal student loan program, the Secretary of Education should verify data submitted by schools, for example by entering into a data sharing agreement with the testing organizations.

    Agency Affected: Department of Education

    Status: Open

    Comments: The Department of Education agreed with this recommendation. Education reported that it should have a mechanism to verify the USMLE pass rate data received from foreign medical schools, although they note that this will require the cooperation of the private organizations that administer the exams. Toward that end, they will attempt to establish a data sharing agreement with those organizations. In FY12, ED reported that they attempted to reach an agreement but could not. It will be important to understand what steps Education has taken to verify the accuracy of student pass rate data without the cooperation of the private organizations that administer the exams.

    Recommendation: To enhance information available for prospective students of foreign medical schools and strengthen monitoring of foreign medical schools participating in the federal student loan program, the Secretary of Education should require foreign medical schools to submit aggregate institutional pass rate data to the Department annually.

    Agency Affected: Department of Education

    Status: Closed - Implemented

    Comments: The Department of Education agreed with this recommendation. They sent a letter to foreign medical schools asking for US Medical Licensing Examination (USMLE) pass rate information starting with exams taken during the award year ending June 30, 2010. (I would add....) They followed the correspondence to schools with a July 2011 Federal Register notice. ED subsequently issued a July 2011 Federal Register notice in which the Secretary required that 2010 pass rate data be submitted by September 30, 2011 and data for all subsequent years be submitted by April 30.

    Recommendation: To enhance information available for prospective students of foreign medical schools and strengthen monitoring of foreign medical schools participating in the federal student loan program, the Secretary of Education should collect consumer information, such as aggregate student debt level and graduation rates, from foreign medical schools participating in the federal student loan program as recommended by the National Committee on Foreign Medical Education and Accreditation and make it publicly available to students and their families.

    Agency Affected: Department of Education

    Status: Open

    Comments: In FY12, ED reported that data system enhancements have been implemented in the Common Origination and Disbursement (COD) System to capture students' educational program of study (i.e. medical, veterinary medicine, nursing and other) for foreign institutions that originate Direct Loan awards by using the web-based COD Direct Loan Origination Tool or by other software that collects data for the Program of Study field. Now that ED has demonstrated its capacity to collect loan usage data at the student level, it should consider making these and other data, such as graduation rates, publicly available to students and their families.

    Recommendation: To enhance information available for prospective students of foreign medical schools and strengthen monitoring of foreign medical schools participating in the federal student loan program, the Secretary of Education should evaluate the potential impact of the newly enacted 75 percent pass rate requirement on school participation in the federal student loan program and advise Congress on any needed revisions to the requirement.

    Agency Affected: Department of Education

    Status: Open

    Comments: The Department of Education agreed with this recommendation. Education reported that it has begun to evaluate the potential impact of the 75% pass rate requirement on foreign medical schools through the development of regulations to implement the statutory requirement. A Notice of Proposed Rulemaking (NPRM) is scheduled for publication in Summer 2010, which involved gathering input from the public through three public hearings and forming a negotiated rulemaking committee comprising individuals representing key stakeholder constituencies for issues related to foreign institutions participating in the federal student financial aid programs. The pass rate provision received a significant amount of discussion, and the resulting NPRM will propose regulatory language to properly implement the statute, while addressing concerns raised by the negotiating committee. Public comment on the NPRM will provide Education with additional information necessary for its continued evaluation, along with the collection and verification of pass rate data. The final regulations were published on November 1, 2010. In FY12, ED reported that the letter to Congress, which will contain recommendations for change, is being drafted and should be finalized by Fall 2012. GAO will close this recommendation when the letter is finalized.

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