Evaluation of Government Assisted Refugees (GAR) and Resettlement Assistance Program (RAP)
2. Key findings: GAR program
2.1 Relevance
Summary of findings – Relevance
- The Government Assisted Refugee (GAR) program is positively viewed by stakeholders, both within CIC and externally (UNHCR, IOM, other Government of Canada departments), as a key program that demonstrates Canada’s support for the protection of refugees.
- Canada has been utilizing the GAR program for situations in which voluntary repatriation and local integration are not viable options.
- The GAR program also aligns well with the Government of Canada‘s commitment to the 1951 UN Convention on Refugees, and the 2002 Agenda for Protection, as well as departmental objectives.
- The GAR program is closely aligned with Government of Canada objectives, and should remain a federal responsibility given that the issue of refugees cuts across several sectors under federal jurisdiction including international development, humanitarian policy, peace building, diplomacy and immigration.
2.1.1 Continued need for Government-Assisted Refugee (GAR) Program
As a signatory to the United Nations 1951 Convention Relating to the Status of Refugees, and in recognition of the 2002 United Nations High Commissioner for Refugees (UNHCR) Agenda for Protection, Canada agreed to the importance of protection of refugees.
Through the course of the evaluation, a common theme that emerged was that the GAR program demonstrated Canada’s commitment to refugees and supports the underlying principles enshrined in the 1951 Convention and the 2002 Agenda. Key informants, including individuals associated with the Government of Canada (CIC, DFAIT, CIDA) as well as external stakeholders (UNHCR, IOM), universally believed that there is a continued need to provide protection to refugees, and that the GAR program was an important tool to demonstrate Canada’s commitment.
It should be further noted that key informants also believe that the problem of displaced persons/refugees is a growing one. Data from the UNHCR supports this opinion. For example, the UNHCR estimates global resettlement needs at about 805,500, with only 80,000 spaces available for resettlement in 2010. UNHCR estimates that 2010 resettlement placements represent only 46% of identical resettlement needs for 2011. In addition, the UNHCR foresees a continued increase (+10% in 2011) in the number of refugees requiring resettlement in the future (United Nations High Commissioner for Refugees, 2010a). Not only is the number of refugees increasing, but the situations in which refugees find themselves are more protracted. As of 2006, the UNHCR key informants estimate that up to 60% of refugees are in protracted situations, in that they have been in a refugee situation for an extended length of time (Betts et al., 2006a).
In two of the international case studies selected for the evaluation (i.e., processing of refugees in Thailand associated with the Singapore CVOA, and the processing of Somali refugees from Kenya – Nairobi CVOA), it was noted that Canada was processing refugees who had been registered with the UNHCR since the early 1990s, suggesting that Canada was indeed processing refugees who had been in protracted situations.
Resettlement is only one of the three options available to address refugee situations. The UNHCR defines a durable situation as:
A solution that allows refugees to “rebuild their lives in dignity and peace. There are three solutions open to refugees: voluntary repatriation; local integration; or resettlement to a third country in situations where it is impossible for a person to go back home or remain in the host country.” (UNHCR, 2011)
As part of the international case studies, key informants were asked why resettlement was seen as an important solution relative to repatriation or local integration. Analysis of the information provided by stakeholders suggests that for many of the refugee populations for which Canada utilizes the GAR program, repatriation and/or local integration are not viable options.
Repatriation
In general, repatriation was not seen as a viable option for the regions visited. For example, refugee situations for the Karen population in Thailand, the Iraqi population in Syria, and the Somali population in Kenya remain protracted in that local conditions in home countries do not currently provide these populations with the protection or security required for repatriation. The lack of stability in the refugees’ home countries and the limited likelihood that the situations would improve suggests that, for many of the refugee populations, repatriation would not be a viable option. This is not to say that repatriation cannot occur. As the UNHCR noted, with political changes taking place in Sudan Footnote 8, individuals leaving Sudan were no longer considered to be refugees and large-scale repatriation was occurring in the southern regions of Sudan (UNHCR, 2009). The UNHCR also noted relatively limited voluntary repatriation among Iraqis living in Syria Footnote 9 (UNHCR, 2010b).
Local integration
Local integration refers to instances in which host countries accept refugees and develop solutions to integrate such individuals to become nationals or have designated rights within the host country. During the course of the evaluation, stakeholders identified several challenges associated with the use/promotion of local integration as a durable solution for both refugees and host countries. These challenges can be summarized as follows:
- Economic capacity – In most instances, the host country lacks the economic capacity to support the integration of large numbers of displaced persons. Countries visited as part of the international case studies (Thailand, Syria, Kenya, Ecuador) all were reported to have over-subscribed health, social and/or educational infrastructure, and also suffered from high unemployment that would be further exacerbated if refugees were allowed to enter the job market;
- Socio-political considerations – Key informants also noted that the large-scale integration of refugee populations could de-stabilize the host country. For example, it was noted that local integration of the large number of predominantly Muslim refugees in Northern Kenya could lead to political unrest with a predominantly Christian South. Similarly, key informants noted that Syria was seen to be unwilling to integrate large numbers of Iraqi refugees (including Christians and Shia Muslims) in a predominantly Sunni Muslim country.
The UNHCR reports that local integration is not an option as national laws in many countries do not permit refugees to be naturalized (United Nations High Commissioner for Refugees, 2009).
- Resettlement – While it is acknowledged that only a small proportion of refugees can be resettled, resettlement was seen as an important activity by key informants interviewed as part of the evaluation. In particular, key informants (CIC, UNHCR, IOM) cited several positive aspects of resettlement including:
- A demonstration to host countries that Canada was willing to share the responsibility of addressing the needs of refugees. This willingness to accept refugees was often seen as an important gesture to help ensure that host countries would continue to accept refugees;
- Improving the conditions of individuals most at risk, including single female head of households, and those with complex medical conditions. By resettling such individuals, it improves access to programs and services in the host country for refugees who are not resettled; and
- Encouraging other countries to follow Canada’s example. Stakeholders noted that Canada was the first country to resettle Rohingya refugees from Bangladesh. Following Canada’s lead, other countries then also accepted Rohingya refugees as part of resettlement initiatives.
2.1.2 Alignment with federal government objectives and priorities (international commitments)
The GAR program is closely aligned with Government of Canada objectives with respect to refugees and displaced persons. For example, in the 2007 Speech from the Throne, the Government of Canada reaffirmed the need to maintain leadership on the world stage:
Rebuilding our capabilities and standing up for our sovereignty have sent a clear message to the world: Canada is back as a credible player on the international stage. Our Government believes that focus and action, rather than rhetoric and posturing, are restoring our influence in global affairs. Guided by our shared values of democracy, freedom, human rights and the rule of law, our Government will continue Canada’s international leadership through concrete actions that bring results. (Government of Canada, 2007)
The GAR program is also consistent with CIC policy documents including the Annual Report to Parliament on Immigration, 2010, and aligns well with the objectives of the 2002 Immigration and Refugee Protection Act (IRPA) in that it assists the department to meet the following objectives, as detailed in IRPA, namely:
- 2(a) to recognize that the refugee program is in the first instance about saving lives and offering protection to the displaced and persecuted;
- 2(b) to fulfill Canada’s international legal obligations with respect to refugees and affirm Canada’s commitment to international efforts to provide assistance to those in need of resettlement.
It should be further noted that the GAR program is only one of several initiatives utilized by the Government of Canada to address protracted refugee situations. For example, in 2007, the Chair of the Interdepartmental Working Group on Protracted Refugee Situations noted CIC’s role with respect to protracted refugee situations.
CIC facilitates and manages legal migration to Canada and is also responsible for Canada’s domestic asylum system and related refugee protection issues, including resettlement. Canada has a long tradition of offering protection to refugees through asylum and resettlement and, with other states, has been exploring how resettlement can be used more strategically in the context of protracted refugee situations (Chair of Interdepartmental Working Group on Protracted Refugee Situations, DFAIT, internal communication, 2007).
The Government of Canada website also details CIC’s responsibilities with respect to the selection and processing of refugees:
CIC brings together a broad range of activities: the selection of immigrants and refugees and the issuance of temporary resident visas abroad; the facilitation and control of immigrants and foreign visitors in Canada; the settlement and integration of immigrants and refugees; and the processing of applications for Canadian citizenship and proof of citizenship (Info Source, 2009).
2.1.3 Consistency with respect to federal roles and responsibilities
Stakeholders interviewed as part of this evaluation noted that the GAR program should remain a federally-managed program, especially as the program was seen to be part of Canada’s foreign policy, with linkages to other federal departments including DFAIT, CBSA and CIDA. It was noted that the issue of refugees cut across a number of sectors – including development, humanitarian policy, peace building, diplomacy and immigration – all of which are the purview of the federal government (Chair of Interdepartmental Working Group on Protracted Refugee Situations, DFAIT, internal communication, 2007). This is not to say that GAR does not have implications for the provinces, as the relocation of refugees to Canada will have impacts for provincial economic and/or social program delivery. However, with the exception of Quebec, which has specific targets for GAR clients, provincial governments are not actively involved in the selection or processing of GAR clients. In this context, there is a defined federal responsibility to manage Canada’s refugee program given its relationship with issues associated with federal jurisdiction.
2.2 Identification and selection of GAR clients
Summary of Findings – Identification and Selection
- While UNHCR criteria for refugee determination is clear, the manner in which UNHCR selects those for resettlement among eligible refugees is not always transparent and varies by region. Notwithstanding the lack of “clarity” in UNHCR selection processes, GAR clients recommended for resettlement to Canada have high acceptance rates by CIC.
- Canada is positively viewed by UNHCR/IOM because of its willingness to accept urgent cases/medical cases.
With the exception of the Source Country referred program, CIC works closely with referral agencies (most commonly the UNHCR) to select individuals appropriate for resettlement to Canada. In general, the process includes CIC identifying the referral criteria for refugees to be considered for resettlement to Canada, and selection and approval of refugees referred to Canada by UNHCR/other organizations.
In some regions, Canada’s acceptance of the UNHCR’s Prima Facie Footnote 10 designation means that CVOAs can concentrate on the review of GARs on the basis of admissibility (i.e. does the GAR pose a security or health risk) rather than on the basis of eligibility (is the GAR an eligible refugee under Convention definitions) for this reason, regions that operate where the Prima Facie designation has been accepted tend to experience higher acceptance rates. Canada’s acceptance (or lack of acceptance) of UNHCR refugee determination also significantly affects the ease/speed at which refugees can be processed.
The international case studies yielded several key observations with respect to the identification and selection of refugees for the GAR program. Among these are the following:
- In general, regional or local discussions between UNHCR and CVOA staff are used to help determine the general criteria for referrals that are made to Canada. While in some instances, Canada has clearly defined the parameters regarding number of persons to be referred with medical conditions (CIC, internal communication, July 2008) Footnote 11, most of the time CIC staff noted that no such formal agreements existed.
- UNHCR staff utilized different processes to select individuals for potential resettlement to Canada. In some regions, the UNHCR reported using a lottery system (first in, first out via the lottery); this was reported by UNHCR for the processing of refugees in Thailand and UNHCR Dadaab (Kenya). In other regions (i.e., Damascus), the UNHCR reported that it considered whether the Iraqi refugee had family, relatives or friends in Canada. In cases where the UNHCR had moved to a “lottery system”, it was generally due to refugees questioning of the selection process and a greater desire for transparency in terms of how the selection process for resettlement functioned.
- A key observation found in the international case studies was the lack of information communicated back to CVOAs and/or UNHCR as to the appropriateness of referrals made to Canada. Both CIC and UNHCR staff felt that the identification and selection of GARs could be improved or modified if information was provided as to the extent to which GARs had successfully integrated in Canada. Although noted earlier that as a result of the introduction of IRPA, Canada does not screen on the ability of integration, UNHCR still noted that they could refer different types of refugees to different countries if they had a better understanding of the extent to which different types of refugees “integrated” in the various countries involved in refugee resettlement.
- In terms of selection of GARs to Canada, UNHCR representatives in Damascus and Nairobi noted that Canada was seen to have a very high acceptance rate (relative to other settlement countries), and Canada was also open to accepting individuals requiring urgent protection or those with high medical needs.
As noted previously, most refugees referred by the UNHCR to Canada for the purposes of the GAR program are accepted. Regions which benefited from acceptance of UNHCR Prima Facie designation (Damascus, Singapore) had slightly higher acceptance rates than did regions that did not necessarily accept UNHCR refugee Prima Facie designation (and, therefore, CIC staff had to establish eligibility), including Bogota and Nairobi.
CIC CVOA | CIC approval rates GARs (2009) |
GAR federal Visa issued (2009) |
Accept UNHCR prima facie designation of refugees |
Refugees processed under group processing directive from CIC |
---|---|---|---|---|
Bogota | 87% | 200 | No | No |
Nairobi | 93% | 1,251 | No | No |
Damascus | 96% | 1,096 | Yes | No |
Singapore | 98% | 1,382 | Yes | Yes |
Source: CIC CAIPS data
2.3 Screening and processing
Summary of Findings – Screening & Processing
- Having CVOA-based staff “on the ground” is seen by UNHCR/IOM as a best practice example to facilitate the efficient resettlement of refugees.
- Resource requirements for screening and processing vary on the basis of the “designation” of the refugees.
- There is a lack of consistent processing and quality control used across CIC offices.
- GAR processing efficiency is also affected by logistical constraints such as access to refugees (urban or camp-based refugees), security concerns, and communication challenges (email, internet access).
To aid in screening and processing of refugees, CVOAs work closely with the UNHCR and IOM. From the perspective of the international case studies, CVOAs have established effective lines of communication with these key agencies. In all international site visits, it was observed that “on the ground” refugee officers improve both communication with UNHCR/IOM and Canada’s understanding of the local screening and processing challenges. Additional benefits of having regionally-based CIC officers noted by international key informants include:
- Timely contact by UNHCR to arrange resettlement of urgent protection cases; and
- In-depth awareness of the key political/social issues facing refugees and/or host countries.
Stakeholders (UNHCR/IOM) who are uniquely positioned to compare Canada’s selection and processing of refugees to that of other resettlement countries noted several positive aspects of Canada’s process which they consider to be best practices. Among these include:
- Having “on the ground” Canadian staff with appropriate decision-making authority to approve and expedite urgent cases, high medical needs and other cases. Having CVOA staff located in host countries also supported close communication between the UNHCR, IOM and Canada.
- Canada generally has fewer restrictions as to the type of refugees that it will accept Footnote 12. Consequently, refugees referred by the UNHCR to Canada are generally accepted (acceptance rate above 90%).
- Canada continues to take high numbers of refugees (second only to the United States in 2009).
The information collected during the international case studies also highlighted the difficulties in screening and processing GAR clients on the basis of the refugee designation (i.e. acceptance or non-acceptance of Prima Facie designation) and CIC processing models. A discussion of the different processing models used in the CVOAs visited during this evaluation is detailed below.
CIC CVOA | Model | Description | Advantages | Disadvantages |
---|---|---|---|---|
Bogota | Mainly Source Country |
Allows individuals in the country to apply for refugee status without leaving the country Individuals from Colombia are not referred to Canada by UNHCR |
Individuals should have access to documentation (birth certificate, passports, etc.) | CIC staff have to make determinations on both eligibility and admissibility CIC staff feel that a portion of applications are inappropriate |
Nairobi | Mainly Convention refugees Single Processing No Prima Facie designation Some Group Processing done in the past under a pilot project |
UNHCR identifies and refers refugees to Canada for consideration under the GAR program | UNHCR does pre-screening, most are deemed to be eligible refugees | CIC staff still need to verify eligibility and admissibility, although few are rejected and eligibility is generally granted Processing is done on a case by case basis Matching centre attempts to send refugees to communities where there are existing co-ethics |
Damascus | Convention refugees Single Processing Accept Prima Facie designation |
UNHCR identifies and refers refugees to Canada for consideration under the GAR program | Higher approval rates, faster processing time Acceptance of Prima Facie designation means CIC only reviews client for admissibility criteria, as they are deemed to be refugees |
Files are still reviewed on a case-by-case basis Processing is done on a case by case basis |
Singapore | Convention refugees Mainly Group Processing Accept Prima Facie designation |
UNHCR identifies and refers refugees to Canada for consideration under the GAR program Individuals/families are selected from the same ethnic/cultural group |
Acceptance of Prima Facie designation means CIC only reviews clients for admissibility criteria, as they are deemed to be refugees Ability to quickly process related families as “groups” to come to Canada CIC can provide group/cultural profiles for the refugees processed SPOs in Canada can better plan for arrivals of defined ethnic/cultural groups Higher approval rates, more efficient processing |
In some instances, arrivals of a large group of refugees in a small community may tax the resources of the SPO/community organizations |
Source: International case studies
As highlighted in Table 2-3 there are considerable differences in terms of the refugee processing metrics for each CVOA. Overall, given the group processing model available in Singapore, it was able to process large numbers of GARs utilizing limited staff resources. The Damascus office was also able to process relatively large numbers of refugees per staff member due to the acceptance of Prima Facie designation for Iraqis in Syria, and close access to urban-based refugees (the majority of whom resided in Damascus). In contrast, the efficiency of refugee processing in the Bogota and Nairobi offices did not benefit from Prima Facie and/or group processing designations, and the Nairobi office had to also contend with difficult access to refugees residing primarily in camp-based locations. The large number of applications that do not meet the eligibility criteria and the absence of pre-screening, given that all applications must be assessed, has produced backlogs in Bogota that compromised the ability of the source country program to provide protection to refugees in a timely manner.
The efficiency of group processing can be demonstrated when examining the resource requirements of each office. CVOAs are typically organized such that there is a section dealing with refugee processing, and staff are typically involved with both GARs and Privately Sponsored Refugees (PSRs). As detailed below, CVOAs which benefit from the acceptance of the Prima Facie designation (Singapore, Damascus) have more “efficient” processing metrics. It should, however, be noted that other factors affect processing – such as access to refugees (Damascus – urban refugees, no access issues; Nairobi – camp-based refugees, considerable access challenges).
Office | Bogota | Singapore | Damascus | Nairobi |
---|---|---|---|---|
Refugee selection process | Mainly source country | UNHCR Referred | UNHCR Referred | UNHCR Referred |
Acceptance of Prima Facie designation | No | Yes | Yes | No |
Camp Based | No | Yes | No | Yes |
Group Processing | No | Yes | No | No |
Approximate Number of Refugee Staff (CBO & LES)Note * | 3.0 | 1.5 | 4.1 | 4.3 |
Refugee Visas Issued (Persons) Federal and Quebec | 1,128 | 1,933 | 3,866 | 2,617 |
GAR Visas Issued (Persons) Federal and Quebec | 853 | 1,818 | 1,399 | 1,445 |
GAR approval rate Federal and Quebec | 37% | 98% | 97% | 90% |
Processing time (70% of cases processed within x-months) Federal and Quebec | 32 months | 15 monthsNote ** | 8 months | 25 months |
Number of refugees processed/staff member (refugee visas/staff member), (GARs and PSR’s) | 376 | 1,289 | 943 | 616 |
Note: Refugees include GARs, PSR and refugee dependants
Other issues associated with GAR screening and processing are identified below.
Inconsistent quality control/processing approaches: The international case studies provided insight into the processes used within each CVOA to monitor GAR processing. While all CVOAs will enter data into CAIPS, several CVOAs (e.g., Singapore, Damascus) had developed Excel-based systems to better manage the administration and processing of GAR files. The development of Excel systems was often the result of CIC staff wishing to have access to better/more timely information than could be accessed through CAIPS. These systems also served to verify that the information in CAIPS was consistent with information maintained in these parallel Excel databases. The existence of such “parallel” systems suggests that CAIPS is not seen as a viable management information tool and is also seen as cumbersome with respect to generating statistics for use by CVOA staff/management. The international case studies also underscored the different quality control processes used in the various offices. Key informants noted that the level of training varied by office and there was only limited opportunity to provide training/orientation to new staff given little or no overlap of CBO staff during rotations.
Limited ability to integrate UNHCR information into Canadian systems: At the time of the international site visits, the evaluation team observed CVOA staff re-entering data from UNHCR Refugee Referral Forms (RRF) into CAIPS. Given the extensive information documented in the RRF, it would be advantageous for CIC to have some ability to electronically retrieve information from the RRF to populate CAIPS and/or other databases. The United States was reported to be developing the required systems to facilitate the download of selected data from the UNHCR system (PROGRESS) into their internal (US) systems.
Medical information: In most instances, the medical history of the refugee is limited to the information contained in Resettlement Needs Assessment Form (IMM5544-B). Information collected as part of the pre-departure medicals, such as blood tests and/or X-rays, do not typically accompany the GAR when travelling to Canada. In contrast, it was noted that other countries (e.g., the United States) provide refugees with more medical information that is provided to the refugee upon departure. Canadian CIC staff interviewed cited concerns with respect to confidentiality, potential loss of documents, and the difficulty of having the form provided to refugees as reasons why medical information was not generally shared with refugees. However, it could be possible to share medical information through the provision of copies, or providing a sealed envelope containing the medical record. Moving to electronic medical records (EMR) could further support enhanced information sharing of medical data.
Limited technology capabilities: It was noted that Canada did not have an effective platform to link field staff with central data systems (CAIPS). For example, when conducting refugee interviews, CBO’s did not have the ability to access CAIPS remotely, to either retrieve information and/or to populate the database. This necessitated that the data be re-entered when the CBO’s returned to the CVOA. CBO staff noted that the “mobile CAIPS” system was not practical nor used in the field.
Transportation/medical loans: A further issue identified in the international case studies was the Canadian practice of having refugees reimburse the Government of Canada for the cost of the pre-departure medical and cost associated with transportation to Canada. Given the financial challenges faced by GARs in Canada (see section 4.6), such loans represent an additional hardship for most refugees. It was noted by IOM officials that among resettlement countries, only Canada and the US recover funds from refugees, and, for the US, it is for travel costs only. IOM staff noted challenges with the administration of the Canadian system, which required direct actual costs (not estimates as per the US model) and utilizes a paper-based system (loans are manually completed), rather than an electronic or online system.
2.4 Pre-departure information
Summary of Findings – Pre-Departure Information
- Considerable delays in refugee processing often result in changes in family composition prior to departure; CIC/IOM report the number of undocumented family members increases as the length of time between approval and processing increases. Undocumented family members typically result in GARs not resettled in Canada until family composition is resolved.
- There is some scope to enhance “two-way” communication between CIC CVOA staff, Canada-based Service Provider Organizations and other stakeholders (IOM, UNHCR).
- The Canadian Orientation Abroad (COA) program is seen as an effective tool for preparing GARs for their arrival in Canada.
2.4.1 Pre-departure administration issues – GAR disclosure
In general, CIC and IOM staff noted that a common problem was changes in family composition from the time of the initial interview with CIC staff and the time that the refugees present themselves for their pre-departure medical and/or departure for Canada. While not seen as an issue of fraud, it was noted that many refugees would arrive at their pre-departure medical and/or departure with undocumented family members (these family members could include newborns but also other non-documented family members). In these situations, the family would typically not travel to Canada and resources would be required to document and/or process these undocumented family members. Given the length of time between the initial CIC interview and actual issue of a visa (in some offices, there can be up to a two-to-three-year delay between the initial interview and the completion of pre-departure medicals), it could be expected that refugee families will gain additional members through new marriages and/or new births. It was noted that information provided to refugees at the time of the application/determination could be improved to clarify the necessity of reporting all family members and/or to provide other information as to the processes associated with their resettlement to Canada.
2.4.2 Pre-departure communication – IOM/other stakeholders
A common theme that emerged through the international case studies was the limited “information sharing” between the key stakeholders associated with the processing of GARS, namely CVOA-based CIC staff, regional UNHCR and IOM staff, and Service Provider Organizations based in Canada. For example, CIC staff noted that they received very little feedback from CIC NHQ as to the appropriateness of referrals and/or other challenges faced by GARs in Canada. Similarly, IOM staff noted that they would prefer to have more advance information as to likely GAR movements to Canada (to help secure cost-efficient transportation, as well as to arrange medicals, as required), and Canadian SPOs also requested that they receive additional information as to likely GAR movements and specific needs of the GARs destined to Canada.
2.4.3 Canadian Orientation Abroad services
In general, service providers agreed that the Canadian Orientation Abroad (COA) Footnote 13 pre-departure information sessions adequately prepared GARs for their arrival in Canada. In focus groups conducted with SPOs, it was noted that the COA:
- Provided accurate information to counteract inaccurate information received from other refugees; and
- Helped create the correct mindset for GARs by preparing GARs for what they need to learn to live in Canada. For example, in contrast to camp-based situations where necessities are provided, GARs are provided with the knowledge that they will be required to assume responsibility to secure housing, food and other services.
It should be noted that some SPOs felt that the COA was “too generic” and should be tailored for the specific region of Canada for which the GAR was destined. While this would seem to be a plausible modification, it assumes that GARs are travelling at the same time to the same province or region. In reality, COA sessions are established based on demand and, in most cases, the GARs attending the sessions are travelling to multiple regions in Canada. This is not to say, however, that if opportunities are available (e.g., a group of GARs all travelling to the same region), that the COA should not be modified to incorporate “region-specific” panel panel-defaults.
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