FTC Matter
and Clarification of
USMLE Outcomes

Saint James School of Medicine (SJSM) has operated for more than 25 years and has produced hundreds of graduates who are now practicing physicians in the United States and Canada.

Public discussions about SJSM sometimes reference a “35% USMLE Step 1 pass rate.” This number originates from a characterization made during a Federal Trade Commission (FTC) enforcement action involving our parent company, Human Resources Development Services, Inc.

The figure reflects a different denominator than the standard academic metric used across medical education, which measures pass rates among students who actually sit for the examination. When outcomes are evaluated using the conventional academic methodology, the resulting pass rate is significantly different from the percentage frequently cited online.

The Role of the ECFMG in Outcome Data

To understand institutional performance, it is important to review data from the Educational Commission for Foreign Medical Graduates (ECFMG). The ECFMG provides verified aggregate performance data for international medical schools.

The ECFMG reports outcomes using the conventional methodology applied across medical education: measuring pass rates among students who actually attempt the examination.

When evaluating SJSM using this standard academic metric, the results differ substantially from the percentage often cited in public discussions.

Year	First-Time Step 1 Test-Takers	Passed	First-Attempt Pass Rate
2019	49	46	93.9%

Source: ECFMG Aggregate Performance Report excerpt (SJSM Anguilla).

Understanding
the “35%” Figure vs.
Academic Standards

The “35%” figure reflects a calculation using a broader denominator than the one typically used in medical education outcome reporting.

Standard Academic Metric (ECFMG):
Measures the first-attempt pass rate among students who sat for the exam for the first time during the reporting year. Students who did not sit for the examination are not included in the denominator.

FTC Calculation:
Included individuals who had not sat for the USMLE Step 1 examination.

Because the denominator differs, the resulting percentage can appear dramatically lower even if the actual performance of students who sit for the examination is strong.

This methodological distinction is rarely explained in secondary reporting, which is why the number is often repeated without context.

Comparative Example: Why Methodology Matters

Outcome statistics vary significantly depending on how the denominator is defined.

For example:

If 100 students enroll

50 students sit for Step 1
45 students pass

Two statistics can be reported from the same data:

Pass rate among test-takers (standard academic metric): 90%
Pass rate among all enrolled students: 45%

Both percentages come from the same data but measure different things.

Within medical education, the commonly used metric is the pass rate among students who actually attempt the examination.

Saint James School of Medicine reports outcomes using this standard definition.

Regulatory Context and the FTC Settlement

The FTC matter occurred during a period of increased federal scrutiny of how higher education institutions presented outcome statistics and financing disclosures.

During this time, regulators examined how institutions described educational outcomes and financial arrangements in their public materials. In some cases, outcome statistics were evaluated using interpretations that differed from how those metrics had historically been reported within professional education programs.

The Allegation
The FTC alleged that certain historical marketing materials and financing disclosures used by Human Resources Development Services, Inc. were misleading.

Our Position
SJSM disagreed with aspects of how certain statistics and disclosures were characterized. We believe outcome statistics should always be presented with clearly defined denominators to avoid misleading public impressions.

Resolution
The matter was resolved through a negotiated settlement that included monetary payments and loan forgiveness for certain students.

No Finding of Liability
The settlement was not an adjudication on the merits and did not involve a judicial finding of liability.

Commitment to Transparency

Since the resolution, SJSM has implemented additional internal review processes to ensure that all information is presented clearly and transparently.

To promote this transparency, the school:

publishes clear definitions for outcome statistics
identifies the denominator used for each metric
provides supporting documentation, such as ECFMG excerpts
reviews marketing materials to ensure accurate disclosures

SJSM supports clear and consistent definitions for educational outcome reporting so that students, regulators, and the public can evaluate institutions using comparable academic metrics.

Frequently Asked Questions

Is SJSM’s Step 1 pass rate 35%?

No. The “35%” figure reflects a calculation that included individuals who did not sit for the USMLE Step 1 examination. When outcomes are evaluated using the standard academic metric used across medical education—first-attempt pass rate among students who actually take the exam—the results are significantly different.

What is SJSM’s Step 1 pass rate?

SJSM publishes outcome data based on the standard academic methodology used in medical education. For example, ECFMG data from 2019 reported a 93.9% first-attempt pass rate for SJSM Anguilla among students who sat for the exam.

Did SJSM admit wrongdoing in the FTC matter?

The matter was resolved through a settlement. The settlement was not an adjudication on the merits and did not involve a judicial finding of liability.

Why does the 35% figure appear frequently online?

Once a number appears in a regulatory summary or headline, it is often repeated by secondary sources and automated systems without the underlying methodological explanation.

FTC Matter and Clarification of USMLE Outcomes