U.S. DEPARTMENT OF EDUCATION
OFFICE OF POSTSECONDARY EDUCATION

NATIONAL COMMITTEE ON FOREIGN MEDICAL 
EDUCATION AND ACCREDITATION

GUIDELINES

  • Part I. 
    The Entity Responsible for the Accreditation/Approval of Medical schools
  • Part II. 
    Accreditation/Approval Standards
  • Part III. 
    Accreditation/Approval Processes and Procedures

The National Committee on Foreign Medical Education and Accreditation is charged with determining whether the standards of accreditation used by a foreign country to accredit medical schools offering programs leading to the M.D. (or equivalent) degree are comparable to standards of accreditation applied to M.D. programs in the United States.

In making this determination, the Committee uses the following guidelines, which it has determined provide an appropriate framework for the thorough evaluation of medical schools offering programs leading to the M.D. (or equivalent) degree. In general, these guidelines are similar to, and based upon, the standards used by the Liaison Committee on Medical Education (LCME) to accredit medical schools in the United States. The Committee wishes to make it clear, however, that these are in fact guidelines and that a foreign country’s standards and evaluation processes can differ substantially from these guidelines and the LCME standards and still be determined to be comparable to the standards used in the United States, provided the foreign country can demonstrate that its standards and processes are effective alternatives to those used in the United States. It is recognized that circumstances within a country may appropriately result in diverse institutional missions and educational objectives. However, those circumstances can never justify the accreditation of a substandard program of medical education leading to the M.D. degree. The committee expects the accreditation decisions to be consistent and in compliance with the country’s accreditation standards and evaluation processes.

Note: These guidelines, as revised by the National Committee on Foreign Medical Education and Accreditation at its September 16-17, 2004 meeting, became effective at the conclusion of that meeting.

PART I: 
The Entity Responsible for the Accreditation/Approval of Medical Schools

There should be a clearly designated body responsible for evaluating the quality of medical education in the foreign country, and that body should have clear authority to accredit/approve medical schools in the country that offer educational programs leading to the M.D. (or equivalent) degree.

PART II: Accreditation/Approval Standards
The entity within the foreign country that is responsible for evaluating the quality of medical education in the country and has authority to accredit/approve medical schools should have standards comparable to the following:

  1. Mission and Objectives
    • The educational mission of the medical school must serve the general public interest, and its educational objectives must support the mission. The medical school’s educational program must be appropriate in light of the mission and objectives of the school. 
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    • An essential objective of a program of medical education leading to the M.D. (or equivalent) degree must be to prepare graduates to enter and complete graduate medical education, qualify for licensure, provide competent medical care, and have the educational background necessary for continued learning.
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  2. Governance
    • The medical school must be legally authorized to provide a program of medical education in the country in which it is located. 
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    • There must be an appropriate accountability of the management of the medical school to an ultimate responsible authority external to and independent of the school’s administration. This external authority must have sufficient understanding of the medical program to develop policies in the interest of both the medical school and the public.
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  3. Administration
    • The administration of the medical school must be effective and appropriate in light of the school’s mission and objectives. 
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      • There must be sufficient administrative personnel to ensure the effective administration of admissions, student affairs, academic affairs, hospital and other health facility relationships, business and planning, and the other administrative functions that the medical school performs.
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      • The chief academic officer of the medical school must have sufficient authority provided by the institution to administer the educational program. That individual must also have ready access to the university president or other university official charged with final responsibility for the school, and to other university officials as are necessary to fulfill the responsibilities of the chief academic officer’s office.
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      • In affiliated institutions, the medical school’s department heads and senior clinical faculty members must have authority consistent with their responsibility for the instruction of students.
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    • The chief academic official of the medical school must be qualified by education and experience to provide leadership in medical education.
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    • The medical school may determine the administrative structure that best suits its mission and objectives, but that structure must ensure that the faculty is appropriately involved in decisions related to-
      • Admissions;
      • Hiring, retention, promotion, and discipline of faculty; and
      • All phases of the curriculum, including the clinical education portion;
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    • If some components of the educational program are conducted at sites that are geographically separated from the main campus of the medical school, the school must have appropriate mechanisms in place to ensure that-
      • The educational experiences at all geographically separated sites are comparable in quality to those at the main campus; and
      • There is consistency in student evaluations at all sites. 
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  4. Educational Program
    • Duration: 
      The program of education leading to the M.D. (or equivalent) degree must include at least 130 weeks of instruction, scheduled over a minimum of four calendar years. 
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    • Curricular Content: 
      The medical school’s curriculum must provide students with general professional education, i.e. the knowledge and skills necessary to become a qualified physician. At a minimum, the curriculum must provide education in the following:
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      • The sciences basic to medicine, including–
        • The contemporary content of those expanded disciplines that have traditionally been titled anatomy, biochemistry, physiology, microbiology and immunology, pathology, pharmacology and therapeutics, and preventive medicine; and 
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        • Laboratory or other practical exercises that facilitate the ability to make accurate quantitative observations of biomedical phenomena and critical analyses of data.
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      • A variety of clinical subjects, including at least the core subjects of internal medicine, obstetrics and gynecology, pediatrics, surgery, and psychiatry and, preferably, family medicine.

        Note 1: 
        Medical schools that do not require clinical experience in one or another of the above disciplines must ensure that their students possess the knowledge and clinical abilities to enter any field of graduate medical education.

        Note 2: 
        Clinical instruction must cover all organ systems and include aspects of acute, chronic, continuing, preventive, and rehabilitative care. 

        Note 3: 
        The medical school’s program of clinical instruction must be designed to equip students with the knowledge, skills, attitudes, and behaviors necessary for further training in the practice of medicine. 

        Note 4: 
        Instruction and experience in patient care must be provided in both ambulatory and hospital settings.

        Note 5: 
        Each required clinical clerkship (or equivalent) must allow the student to undertake thorough study of a series of selected patients having the major and common types of disease problems represented in the clerkship.
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      • Disciplines that support the fundamental clinical subjects, such as diagnostic imaging and clinical pathology.
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      • Ethical, behavioral, and socioeconomic subjects pertinent to medicine.
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      • Communications skills integral to the education and effective function of physicians, including communication with patients, families, colleagues, and other health professionals.
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    • Design, Implementation, and Evaluation:
      • There must be integrated responsibility by faculty within the medical school for the design, implementation, and periodic evaluation of all aspects of the curriculum, including both basic sciences and clinical education. 
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      • The medical school must regularly evaluate the effectiveness of its medical program by documenting the achievement of its students and graduates in verifiable ways that show the extent to which institutional and program purposes are met. The school should use a variety of measures to evaluate program quality, such as data on student performance, academic progress and graduation, acceptance into residency programs, and postgraduate performance; the licensure of graduates, particularly in relation to any national norms; and any other measures that are appropriate and valid in light of the school’s mission and objectives. 
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  5. Medical Students
    • Admissions, Recruiting, and Publications
      • The medical school must admit only those new and transfer students who possess the intelligence, integrity, and personal and emotional characteristics that are generally perceived as necessary to become effective physicians.
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      • A medical school’s publications, advertising, and student recruitment must present a balanced and accurate representation of the mission and objectives of its educational program. Its catalog (or equivalent document) must provide an accurate description of the school, its educational program, its admissions requirements for students (both new and transfer), the criteria it uses to determine that a student is making satisfactory academic progress in the medical program, and its requirements for the award of the M.D. degree (or equivalent).
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      • Unless prohibited by law, student records must be available for review by the student and an opportunity provided to challenge their accuracy. Applicable law must govern the confidentiality of student records.
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    • Evaluation of Student Achievement
      • The medical school faculty must establish principles and methods for the evaluation of student achievement, including the criteria for satisfactory academic progress and the requirements for graduation.
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      • The medical school’s evaluation of student achievement must employ a variety of measures of student knowledge, competence, and performance, systematically and sequentially applied throughout the medical program, including the clinical clerkships.
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      • The medical school must carefully monitor the progress of students throughout their educational program, including each course and clinical clerkship, must promote only those who make satisfactory academic progress, and must graduate only those students who successfully complete the program.
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    • Student Services
      Students must have access to preventive and therapeutic health services, including confidential mental health counseling. Policies must include education, prevention, and management of exposure to infectious diseases during the course of the educational program.
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    • Student Complaints
      The medical school must have written policies for addressing student complaints related to the areas covered by the agency’s accreditation standards and processes. The student consumer information provided by the medical school to students must include the school’s policies for addressing student complaints as well as the name and contact information for the accrediting/approval entity to which students can submit complaints not resolved at the institutional level. 
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  6. Resources for the Educational Program
    • Finances: The medical school must have adequate financial resources for the size and scope of its educational program.
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    • Facilities: 
      • The medical school must have, or be assured use of, physical facilities and equipment, including clinical teaching facilities, that are quantitatively and qualitatively adequate for the size and scope of the educational program, as well as the size of the student body. 
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      • The medical school should be encouraged to conduct biomedical research and must provide facilities for the humane care of animals when animals are used in teaching and research.
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    • Faculty: 
      • Members of the medical school’s faculty must be appropriately qualified to teach in a medical program leading to the M.D. (or equivalent) degree and effective in their teaching. The faculty must be of sufficient size, breadth, and depth to provide the scope of the educational program offered.
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      • The medical school should have policies that deal with circumstances in which the private interests of its faculty or staff may conflict with their official responsibilities.
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    • Library: The medical school must have a library sufficient in size, breadth, and depth to support the educational program and adequately and professionally staffed.
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    • Clinical Teaching Facilities: The medical school should have affiliation agreements with each teaching hospital or clinical facility it uses that define the responsibilities of each party.

PART III: Accreditation/Approval Processes and Procedures

The entity within the foreign country that is responsible for evaluating the quality of medical education in the country and has authority to accredit/approve medical schools should have processes and procedures for granting accreditation/approval to medical schools that are comparable to the following:

  1. Site Visit
    The accreditation/approval process must include a thorough on-site review of the school (and all its geographically separated sites, if any) during which sufficient information is collected to determine if the school is in fact operating in compliance with the accreditation/approval standards. This review should include, among other things, an analysis of the admission process, the curriculum, the qualifications of the faculty, the achievement of students and graduates, the facilities available to medical students (including the training facilities), and the academic support resources available to students.

    The accreditation/approval process must include an on-site review of all core clinical clerkship sites.
    • At sites that have never been visited by an accreditor whose standards are comparable, the accreditor must conduct an on-site review within 12 months of the accreditation review of the school.
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    • At sites that have been reviewed previously and approved by an accreditor whose standards are comparable, the accreditor must conduct an on-site review at least once during the accredited period.
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    • At new sites (sites opened during the accredited period and that have never been visited previously), the accreditor must conduct an on-site review within 12 months of the placement of students at those sites.

      NOTE: 
      If an accrediting body is accrediting multiple schools that use a common core clinical clerkship site, where that site has a single coordinator responsible for the educational experience of students from the multiple schools, and where the accrediting body, whenever it visits that site, interviews students from all schools, then that site does not need to be visited more than once during the accredited period. 
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  2. Qualified On-Site Evaluators, Decision-Makers, and Policy-Makers
    The accreditation/approval process must use competent and knowledgeable individuals, who are qualified by experience and training in the basic or clinical sciences, for on-site evaluations of medical schools, policy-making, and decision-making.
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  3. Re-evaluation and Monitoring
    The accreditation/approval process must provide for the regular re-evaluation of accredited/approved medical schools in order to verify that they continue to comply with the approval standards. The entity must also provide for the monitoring of medical schools throughout any period of accreditation/approval granted to verify their continued compliance with the standards.

    The accreditation/approval process must provide for the accrediting/approval entity’s review of complaints it receives from students and, as appropriate, investigation and follow-up action. The entity’s procedures need to ensure the timely, fair, and equitable handling of all complaints related to the standards and procedures for accreditation/approval. The procedures also need to ensure that follow-up action, including enforcement action, is appropriate based on the results of the investigation. In addition, the accreditation/approval entity must consider the complaints it has received regarding a medical school when re-evaluating the medical school for accreditation. 
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  4. Substantive Change
    The accreditation/approval process must require medical schools to notify the appropriate authority of any substantive change to their educational program, student body, or resources and must provide for a review of the substantive change by the appropriate authority to determine if the school remains in compliance with the standards.
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  5. Controls against Conflicts of Interest and Inconsistent Application of Standards. 
    The accreditation/approval process must include effective controls against conflicts of interest and the inconsistent application of the accreditation/approval standards.
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  6. Accrediting/Approval Decisions
    It is recognized that circumstances within a country may appropriately result in diverse institutional missions and educational objectives. However, those circumstances can never justify the accreditation of a substandard program of medical education leading to the M.D. degree. The accreditation/approval process must ensure that all accreditation/approval decisions are based on compliance with the accreditation/approval standards. Also, the decisions must be based, in part, on an evaluation of the performance of students after graduation from the medical school.

New York State Evaluation of Foreign Medical Schools:

New York’s approach to the evaluation of foreign medical schools consists of 2 components. The first concerns the registration or accreditation of some programs. This means that graduates of these programs are subject to the same licensing requirements as graduates of Liaison Committee Medical Education (LCME) and American Osteopathic Association (AOA) accredited schools. The second is the review and possible approval of certain schools for purposes of placing long-term clinical clerks in hospitals in New York state. The graduates of this second category of institutions must meet the same licensing requirements as graduates of any other non-LCME or AOA-accredited institution.

In addition to New York’s general requirements for medical licensure, such as age and good moral character, there are specific requirements of education, professional experience or postgraduate training, and examination. The requirement of experience or postgraduate training differs for graduates of registered or accredited schools and graduates of unaccredited or unregistered schools. This latest group of medical schools includes all institutions located outside the United States and Canada, except for the American University of Beirut and the New York Scholarship program at Sackler Medical School in Tel Aviv. These two programs are registered by the New York State Education Department and their graduates are required to satisfy the same licensing requirements as domestic graduates.

The educational requirements for graduates of all types of medical schools are identical:

Completion of at least 2 years of acceptable pre-professional education
Completion of a program of medical education of not less than 32 months
receipt of an acceptable degree

In addition to satisfying the educational requirements and passing the appropriate licensing examination, graduates of accredited or registered programs must complete a year of approved postgraduate training. Graduates of unaccredited or unregistered programs, that is, most foreign medical schools, must pass an acceptable proficiency examination, i.e., be certified by Educational Commission for Foreign Medical Graduates (ECFMG), complete 3 years of approved graduate medical education, and pass the United States Medical Licensing Examination (USMLE).

In 1981, the New York State Board of regents approved regulations governing the circumstances under which students enrolled in unaccredited/unregistered medical schools might engage in clinical clerkships totaling more than 12 weeks in new York state. As provided by section 60.1 of the Regulations of the Commissioner of Education, ” Students enrolled in medical programs not registered (by the state education department) may serve in clinical clerkships in teaching hospitals in this state provides that… the program in the medical school attended has been determined by the Department, after a site visit conducted at the expense of the applicant by persons designated by the department and experienced in medical education program evaluation, to meet substantially the requirements of section 60.1 (a)(1) of part 60 and of parts 50 and 52 (of commissioner’s regulations). In addition, students wishing to enroll in a teaching hospital with which the medical college has an approved affiliation agreement”

Within this context, a teaching hospital is defined as an institution which has an Accreditation Council of Graduate Medical Education (ACGME) or AOA-Accredited postgraduate training process in those clinical areas in which clerkships are being performed.

The process of evaluating and approving an unaccredited/unregistered medical school seeking to operate a portion of clinical component of its program of medical education in New York State is patterned on the philosophy and procedures of accreditation and registration. Accreditation is a process of determining the quality and integrity of educational institutions or individual programs. The state Education Department’s registration process is similar but focuses on individual programs. The resultant recognition entitles colleges and universities to the confidence of the educational community and the public. The accreditation and registration process require institutions and programs to examine goals, operations, achievements, and to be evaluated by a visiting team of peers in the context of standards that are general in nature. Neither registration nr accreditation is inflexible, measuring every institution by fixed and highly specific criteria. In essence, both registration and accreditation are reviewed by colleagues, according to generally stated and commonly accepted indices of quality. The process for approving unaccredited/unregistered medical schools for clerkship purposes is distinguished from registration and accreditation by its more limited scope.

An unregistered and unaccredited medical school may seek approval to place students in clinical clerkships in teaching hospitals in New York State by submitting an application to the State Education Department . The medical school must submit a completed database document along with current catalogs, handbooks, and all other materials concerning the institution’s program of medical education. The school must also agree to cover all expenses connected with the evaluation process.
The department’s system for the evaluation of medical school programs for the placement of clinical clerks in New York is based on generally accepted procedures for academic program review. the institution presents documents in English and in a format specified by the department that provides information required by the department and relevant to the regulations of the commissioner of education and the guidelines for Evaluation of Medical Programs. The department then designates several people to review these materials. After the initial review of the materials submitted by the school, a site visit team visits the campus and representative clinical facilities, which may be located at other sites, such as New York hospitals.

Prior to the visit , the school requiting approval must provide extensive information concerning the curriculum, faculty , students, resources and administration of the institution. The site visit provides an opportunity to verify the accuracy and completeness of the data and permits an in-depth review of such program components as :

  • the depth and breadth of the curriculum and the integration of the basic sciences and clinical experiences
  • the use of acceptable standards of admission , the maintenance of student records, and the provision of student services
  • the adequacy of basic science facilities, including faculty offices, laboratories, classrooms, libraries and other resources
  • the levels of faculty and student morale, intellectual stimulation and academic achievement

Program evaluators use specific guidelines to review the program of medical education. these guidelines include but may not be limited t the following:

The medical school is organized as a definable academic unit , responsible for an educational program of not less than 32 months, which leads to the MD degree or equivalent as determined by the department. The institution is listed in one or more of the generally accepted resource volumes in international education, and its program is legally recognized and approved for the training of the physicians by the competent authorities of the jurisdiction in which it is located.

A completed educational program is maintained , the structure and the content of which provide an adequate foundation in the basic and clinical sciences

An administrative and governing system is provided that allows the schools to accomplish its objectives.

The faculty is composed of sufficient number of representatives of the biological, behavioral and clinical sciences to implement the objectives of the institution.

Acceptable standards concerning admission requirements and the student selection process are in place, and a system is maintained for keeping adequate student records.

Financial resources are available that allows the institution to conduct its program in a satisfactory manner

Adequate facilities, or access to them, including buildings and equipment are available to provide an environment conducive to the maximum productivity of faculty and students in fulfilling the objectives of the school.

In conclusion , the objectives of the New York State Program to regulate clinical clerks from unregistered and unaccredited medical schools are been met. An effective system that clearly defines those conditions under which clerkships may be performed has been established.

This system also exerts quality control measures over the educational experiences available to students. The use of USMLE step 1 as a screening device provides directors of medical education, as well as state officials , with a mechanism for measuring student performance in the basic science areas after 2 years of medical school.

The system and criteria for the review of medical education programs outside of the United States and Canada has had another positive effect. Through an ongoing process of program review , New York state is able to assure that students in selected unregistered and unaccredited medical schools are receiving a reasonable education. This has positive result for both the students and the citizens of New York state. In addition, the medical schools that have been evaluated have benefited from a process based on mutual cooperation and objective assessment. It should also be noted that detailed information concerning unaccredited and unregistered schools, which has never been really available before , is now obtainable from the New York State Education Department. The availability of information concerning these schools and the judgments that have been made based on reasonable standards and procedures are major steps forward in international medical education.

Medical schools approved for this purpose are :

  • St.George’s university School of Medicine, Grenada
  • Ross University School of Medicine, Dominica
  • Autonomous University of Guadalajara, Mexic
  • Fatima College of Medicine, MAnila, Philippines
  • The four year English program St. Medical University of Lublin, Lublin, Poland
  • and the four year English Language program at the Medical University of Silesia, Katowice, Poland.