Short-term students in a foreign health care program – [R186(p)] – Authorization to work without a work permit – International Mobility Program

All in-Canada visitor extension, study permit and work permit applications must be submitted electronically, with some exceptions. Consult the list of programs that are exempt from the in-Canada mandatory electronic application requirement.

This section contains policy, procedures and guidance used by IRCC staff. It is posted on the department’s website as a courtesy to stakeholders.

Paragraph 186(p) of the Immigration and Refugee Protection Regulations (IRPR) authorizes temporary residents to work without a work permit if

  • they are a student in a health field at a foreign learning institution,
  • the work is primarily for the purpose of acquiring training for a limited period of time, and
  • they have written approval from the body in Canada that regulates that field.

This includes work dealing directly with patients, such as work as part of a medical elective in their program of study or in a support role in a health care environment (like as a clinical clerk at a medical teaching institution in Canada).

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A “student in a health field” is a foreign national who has not yet completed their Doctor of Medicine (MD). Therefore, foreign nationals who have finished their Doctor of Medicine and are completing their residency do not meet the requirements of paragraph R186(p).

For the purpose of the work permit exemption under paragraph R186(p), the medical elective or clinical clerkship at a medical teaching institution in Canada (host employer) is short term, usually 1 term that a student from a foreign learning institution is completing in Canada as part of their Doctor of Medicine program, after which they will return to their foreign learning institution to complete their MD.

Medical teaching institutions are identified in the IRPR as employers for medical students under paragraph R186(p). However, workplaces such as private clinics are also permitted if they are providing human health care training.

Health care fields include the following:

  • medicine (including dentistry)
  • occupational and physical therapy
  • medical technology
  • nursing
  • other professions in human health care that are regulated by provincial or territorial governments

There is no requirement for wages to be paid. However, where the position is unpaid or of minimal recompense, foreign students must demonstrate that they have the means to support themselves while in Canada.

The primary purpose of the work must be to acquire training in a field related to the foreign national’s studies, not to conduct research. Non-research training in a health research facility (such as a laboratory) is permitted.

Who is not eligible for this work permit exemption

Work not directly related to human health care (that of veterinarians, sociologists, etc.) is not covered by paragraph R186(p).

Foreign nationals who intend to perform work that is an essential part of a post-secondary academic, vocational or professional training program offered by a designated learning institution (DLI) in Canada are required to obtain a co-op work permit (LMIA exemption code C32). The work cannot form more than 50% of the total program of study.

Since medical residents and medical fellows are no longer considered students, in that they have obtained their MD, they are required to obtain a work permit to complete their residency or fellowship periods. Foreign medical residents and medical fellows coming to work temporarily (regardless of length of work) in Canadian clinical settings or research facilities for paid training or to conduct research are not work permit exempt under paragraph R186(p). However, they may qualify for a Labour Market Impact Assessment (LMIA) exemption as Foreign medical (or dental) residents and medical research fellows [C45]. An LMIA-exempt offer of employment submitted by their prospective employer, usually the training institute, is required. When the work permit is approved and issued, the employer is then responsible for specific conditions for employing foreign nationals in Canada, such as working conditions, including location and wages.

Required medical examination

Health care is a designated occupation that requires an immigration medical examination as per subparagraph R30(1)(a)(ii).

For guidance on medical requirements, please consult Immigration medical examination: Healthcare students who are work permit-exempt.

Temporary resident visa (TRV)-required citizens will have their medical examination instructions sent to them as part of the TRV application process.

Those who are TRV exempt are encouraged to seek a facilitation letter from the migration office stating that they have completed an immigration medical examination with a designated panel physician and the results can be accessed under the unique client identifier (UCI) provided in the letter. If foreign nationals can’t obtain a letter, they can provide proof that they completed their medical examination to the border services officer.

Documentation requirements

Foreign nationals meeting the requirements of paragraph R186(p) are exempt from obtaining a work permit. If they are also visa exempt, they may travel to Canada on an electronic travel authorization (eTA). The onus is on foreign nationals to provide documentary evidence that they meet the requirements of the work permit exemption.

Documentary evidence includes the following:

  • proof from the foreign student’s home educational institution stating that the student is completing a clinical clerkship or short-term practicum that forms part of their health care educational program (the letter should include the expected duration of the clerkship or practicum)
  • a letter of no objection from the Canadian body that regulates the particular health care field (note: specific provincial and territorial colleges of physicians and surgeons’ requirements for medical students are described below)
  • a letter or email from the Canadian medical institution confirming the student’s acceptance for the period of training
  • proof of completion of a medical examination, as above

Role of the port of entry

The final decision to allow entry into Canada rests with border services officers. Border services officers should review the documents provided, including evidence of having passed the immigration medical examination and other required documentation, to ensure that the foreign national meets the requirements.

Note: If the foreign national is required to report for medical surveillance, the Medical Surveillance Undertaking form [IMM 0535] must be finalized at the port of entry.

In order to impose the conditions regarding employer and occupation, the border services officer may issue a visitor record. The visitor record should be for the length of the elective or clerkship and should state that the foreign national is only authorized to work for a specific employer and occupation as per section R185. The border services officer may indicate in User Remarks that the foreign national is authorized to work as per paragraph R186(p).

No objection from provincial and territorial colleges of physicians and surgeons

Provincial and territorial colleges of physicians and surgeons have identified distinct requirements related to work performed by foreign national health care students. Border services officers should consult the requirements for the stated province or territory of destination and ensure that the health care student demonstrates that the requirements have been met.

Ontario does not require a letter from the college of physicians and surgeons.

The College of Physicians and Surgeons of Ontario has informed Immigration, Refugees and Citizenship Canada (IRCC) that it does not need to be involved in individual applications and that it does not object to foreign health students working in medical teaching institutions in Ontario. This non-involvement can be interpreted as approval from the regulatory body for visa officers to process applications without written approval for each one.

British Columbia does not require a letter from the college of physicians and surgeons. A letter of acceptance from a university in British Columbia suffices.

The College of Physicians and Surgeons of British Columbia has advised IRCC that it licenses all foreign medical students who arrive under paragraph R186(p) for short-term practicums, whether they are at the undergraduate or postgraduate level. The college and the universities have special procedures in place that are strictly adhered to. Acceptance by the university is, thus, sufficient proof that the college has given approval.

Alberta does not require a letter from the college of physicians and surgeons. A letter of acceptance from a university in Alberta suffices.

The College of Physicians & Surgeons of Alberta has advised that it treats undergraduate medical students doing electives in Alberta the same way it treats out-of-province undergraduates. They must first register with the undergraduate elective office at either the University of Alberta or the University of Calgary, which then provides applicants with all the information the university requires and also provides them with the college's undergraduate elective application for registration.

The entire process is handled through the university, which then notifies the College of Physicians & Surgeons of Alberta to finalize the registration. In essence, proof of acceptance by a university in Alberta (Edmonton or Calgary) is sufficient evidence of approval by the regulatory body, that is, the College of Physicians & Surgeons of Alberta.

Quebec requires a letter from the college of physicians and surgeons.

The Collège des médecins du Québec has advised that a foreign student coming to Canada for a short clinical internship must obtain a “lettre d'admissibilité” (admissibility letter) from the Collège des médecins du Québec. The issuance of a letter from a university is not sufficient to authorize the student to perform a short internship. Medical students coming to Canada for observation or research internships are not required to obtain this admissibility letter.

Saskatchewan does not require a letter from the college of physicians and surgeons. A letter of acceptance from a university in Saskatchewan suffices.

For other provinces and territories, if the college of physicians and surgeons for the province or territory has not provided the student with written approval, the visa office should contact the Immigration Program Guidance Branch for assistance in determining whether the province or territory has elected to be involved in health care student practicums for international students.

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