Evaluation of the International Student Program

3. Findings

3.1 Relevance

3.1.1 Need for the International Student Program

Ninety-five percent of those interviewed (41 of 43) indicated a continued need for the program, and described this need in terms of the many benefits (social, cultural, and economic) it brings to international students, educational institutions and communities.

The document review found that educational institutions need international students to compete in the “global race for research talent”^{Footnote 26} and address student shortages.^{Footnote 27} The need to address student shortages was further highlighted in the interviews and confirmed by 48% of the educational institutions surveyed. Specifically, survey respondents indicated that international students bring benefits to their educational institution by addressing these shortages; of these, representatives from universities, colleges, and language schools were evenly distributed.

In addition, 49% of those interviewed (21 of 43) saw a role for the ISP in contributing to Canada’s economic needs through the potential future immigration and integration of international students in Canada. International students are recognized for their potential to integrate easily given their language skills and Canadian experience, and are thus desirable candidates for immigration.

3.1.2 Alignment with GoC, CIC, OGD and provincial priorities and objectives

Alignment with Government of Canada and CIC

The need for international students, as well as their labour force and immigration potential, was articulated in various Government of Canada (GoC) policy documents, including Advantage Canada 2006 and the 2008 Speech from the Throne. The 2008 Speech from the Throne indicated that the Government of Canada would “work with the provinces to attract top international students to Canada.”^{Footnote 28} Similarly, there was a strong consensus among key informants interviewed (13 of the 14 respondents who commented) that the ISP is consistent with GoC objectives, priorities and activities.

The ISP’s objective to attract and retain international students is articulated in CIC’s departmental documents, and supported by CIC’s strategic objective for the temporary resident program to “design, develop and implement policies and programs to facilitate the entry of temporary workers, students and visitors in a way which maximizes their contribution to Canada’s economic, social and cultural development while protecting the health, safety and security of Canadians.”^{Footnote 29} CIC and OGD key informants interviewed (8 of the 11 who commented) indicated that the ISP was aligned with other CIC programs, most often mentioning the Canadian Experience Class (CEC), the Provincial Nominee Program (PNP) and the Temporary Foreign Worker (TFW) program.

Alignment with other government departments

Although their mandates vary, other government departments have an interest in international students and international education. In particular, CIC works closely with DFAIT and CBSA in the implementation of the ISP.

Interviews with representatives from CIC and other government departments revealed some incongruence between the objectives of the lead departments – CIC, CBSA and DFAIT. A little over half of the 13 CIC respondents indicated that CIC objectives were not aligned with the objectives, priorities and activities of other federal departments. Four CIC respondents indicated that it was aligned, however, two of these respondents qualified their responses. Specifically, it was noted that CBSA’s priority related to enforcement can be at odds with CIC’s facilitation objective, and DFAIT’s focus on promotion does not take into account CIC service-delivery capacity. Many respondents highlighted a need for improved coordination among government departments.

Alignment with provinces

The majority of provincial government representatives interviewed (80%) reported that the ISP was consistent with their provincial program priorities and activities. However, processing times and communication and outreach were mentioned as areas requiring improvement.

3.1.3 Federal role

While education in Canada is a provincial/territorial jurisdiction, there is an appropriate role for the federal government with respect to international education. The federal government is responsible for Canada’s national security, international trade, and national economy, which together provide the backdrop for the provision of education to international students and their potential transition to permanent residence in Canada.

• The federal government supports Canada’s national security interests by ensuring the integrity of the study permit program and preventing the entry of non-genuine students. It is responsible for the implementation of IRPA. Section 3(1) of IRPA states that the objectives with respect to immigration are to “protect the health and safety of Canadians and to maintain the security of Canadian society”… and to deny “access to Canadian territory to persons who are criminals or security risks”.^{Footnote 30} CIC and CBSA share the responsibility for program integrity – CIC with a focus on the processing of applications, including admissibility, and CBSA primarily through enforcement.
• The federal government promotes Canada’s national trade interests in international fora. The main role of DFAIT is to promote education in Canada abroad. Through the Canada brand, DFAIT brings together provinces and territories to market Canada as a destination for international students. The objective is to “enhance Canada’s international profile for education excellence and encourage linkages between Canadian and foreign institutions, thereby creating opportunities for Canadian students to study abroad and to attract more international students to Canada.”^{Footnote 31}
• The federal government is responsible for Canada’s national economy. An important focus of the federal government is Canada’s continued economic growth. The Government of Canada views international students as a potential pool of candidates for labour force participation and permanent residence, contributing to a stronger economy in the long term.^{Footnote 32}

Bringing international students to Canada has significant implications for these national interests that can only be addressed at the federal level. As jurisdiction over education lies with the provinces and territories, the federal government must work with provincial and territorial governments to set the standards for quality assurance in education, and therefore, must work with them to protect Canada’s reputation and ensure that the ISP continues to benefit Canada.

3.2 Performance

3.2.1 Social, cultural and economic benefits

Benefits to educational institutions, communities and international students

Findings showed that partners and stakeholders recognize the many benefits (social, economic and cultural) that international students bring to Canada, and that these benefits are distributed regionally – in each province and in large and smaller communities.

Benefits to educational institutions: Respondents interviewed identified benefits to educational institutions, including economic benefits through student tuition, as well as benefits from enhanced diversity within learning environments.^{Footnote 33} Findings from the survey of educational institutions were consistent with these results. Most respondents indicated that international students enhance the diversity of the learning environment (internationalization) (95%), promote the reputation of the educational institution internationally (93%), and increase revenues (87%).

Benefits to communities: Those interviewed also identified many benefits, including economic benefits through the money spent while studying, the social/cultural diversity gained (primarily in smaller communities), the potential transition to permanent residence and resultant population growth, as well as labour market benefits.^{Footnote 34}

Administrative data for the reporting period showed the distribution of international students in each province (see Table 1-5), as well as in Canada’s major metropolitan areas of Montreal, Toronto and Vancouver (MTV) and the rest of Canada (ROC) (see Table 3-1). Of note, about 44-45% of international students were destined to communities in the ROC each year.

Benefits to international students: Though less of a focus, a number of benefits to international students were noted by respondents interviewed. Benefits included exposure to Canadian values/society and opportunities for personal/professional growth, quality education, work experience, and increased employability in one’s home country.^{Footnote 35} In addition, many respondents to the CBIE survey of international students indicated that their Canadian program of study had been valuable/beneficial in helping to make them a more educated person (good: 44%; excellent: 40%) and in preparing them for further study (good: 42%; excellent: 32%).

Economic benefits to Canada

Numerous studies have demonstrated the economic benefits of international education at the national and provincial levels.^{Footnote 36} A recent study commissioned by DFAIT estimated that “in 2008, international students in Canada spent in excess of $6.5 billion on tuition, accommodation and discretionary spending; created over 83,000 jobs; and generated more than $291 million in government revenue.”^{Footnote 37} This study also compared international education to lumber and coal, and suggested that it was one of Canada’s more lucrative exports.

At the provincial level, studies in British Columbia, Manitoba and Saskatchewan have shown similar economic benefits of international students in their jurisdictions.

• The BC study found that international students spend close to $511M for direct purchases of goods and services each year.
• The MB study estimated that that their total economic impact (including tuition, academic fees and non-academic spending) surpassed $74M during the 2006-2007 academic year.
• The SK study estimated the annual expenditures of international students at the University of Regina, the University of Saskatchewan and in the K to 12 sector to be over $71M in 2007.

There is also growing recognition in Canada of the longer-term benefits of international students as labour market contributors and potential immigrants with Canadian education and work experience (discussed in section 3.1 on Relevance). The CEC immigration stream was created in order to retain international students and realize the benefits.^{Footnote 38} Between September 17, 2008^{Footnote 39} and July 3, 2009,^{Footnote 40} CIC received 1,780 applications and issued a total of 606 permanent residence visas to international student applicants by way of the CEC.

CIC administrative data on transitions to work and permanent residence^{Footnote 41} showed that Canada’s retention^{Footnote 42} of international students increased over the reporting period, but was relatively small compared to the total stock of international students in Canada.

• In 2008, 11,760 international students transitioned to foreign worker status (compared to 3,454 in 2003); of which, 66% did so with a post-graduation work permit. The number of those transitioning to foreign worker status was about 8% of the total stock of international students in post-secondary^{Footnote 43} or other studies.
• In 2008, 10,357 international students transitioned to permanent resident status (compared to 5,486 in 2003). A little over half of those transitioning (55%) did so as a skilled worker (3,717) or as the spouse or dependant (1,939) of a skilled worker; 55% studied previously at the university level; and 11% studied previously at the trade level. The number of those transitioning to permanent resident status was about 7% of the total stock of international students in post-secondary^{Footnote 44} or other studies.

3.2.2 Global competitiveness

Canada’s performance

Market share of international students: As noted earlier, the number of international students coming to Canada is increasing. However, Canada’s market share of international students relative to other countries is declining. There are numerous measures to assess market share of the international education industry. Looking at market share as a simple proportion of the tertiary international student population world-wide, Canada had around 4.4% of the total market share of international students in 2007,^{Footnote 45} ranking 6th in the world after the US (19.7%), UK (11.6%), Germany (8.6%), France (8.2%) and Australia (7.0%). This was a decrease from the previous year in which Canada had 5.1% of this market.

Larger countries tend to have larger market shares, which can distort a country’s relative performance. Therefore, country size was considered in the measure of market share, and showed that Canada’s performance was consistent with its size. Nevertheless, it was still outperformed by its main competitors – the UK, Australia and New Zealand (see Figure 3-1).

Figure 3-1: Ratio of OECD student to OECD population shares (2007)

Source: OECD Factbook 2010 and Education at a Glance 2009: OECD Indicators

Text version: Ratio of OECD student to OECD population shares (2007)

Stakeholder perception of global competitiveness: Findings were mixed in terms of partner and stakeholder perceptions of Canada’s global competitiveness. A little over half of the partners and stakeholders interviewed (56%) generally viewed the ISP as globally competitive; however, more than half of these qualified their response, indicating that we could be doing better. Conversely, a little over a quarter of those interviewed (27%) indicated that the program is not globally competitive.

Similarly, findings were mixed among educational institutions surveyed. Forty-one percent of universities and colleges agreed that Canada’s study and work opportunities for international students are globally competitive, while 32% disagreed. Seventy-four percent of language schools disagreed; however, their students are typically not eligible for all the work opportunities.^{Footnote 46}

Canada’s ranking as a study destination: Findings from the CBIE survey showed that Canada was not the first choice for a number of respondents choosing Canada as a study destination. A little over half (52%) of respondents had Canada as their first choice, while 25% had the US, 7% had the UK and 2% had Australia. Due to study limitations, only international students in Canada could be surveyed, so the analysis considered the context of those applying for admission to institutions in more than one country. Of the 2,550 respondents who had applied to more than one country, 44% indicated that Canada was their first choice.

Competitiveness of Canada’s study/work package

Canada’s study/work package has evolved over the reporting period to incorporate opportunities believed to be attractive to international students. The comparative study, commissioned as part of the evaluation to examine Canada’s program relative to that of its competitor countries, found that Canada is generally on par or better in terms of its offerings for international students.

The study compared Canada’s program to those of the United States (US), the United Kingdom (UK), Australia, New Zealand and France. Canada’s policies regarding working on and off campus for international students were consistent with those of its competitors. Its provisions for the work of partners/spouses were as good as or better, particularly in comparison to the US and France, where partners/spouses are not permitted to work. The review also noted that Canada offers the most generous post-graduation work opportunity, allowing recently graduated international students to apply for up to a three-year work permit.^{Footnote 47}

Factors contributing to the appeal of Canada

Factors contributing to international student decision-making to study in Canada were examined by the CBIE survey. Quality of education was most commonly reported (74%) as very important by respondents (see Table 3-2). The BC survey found similar results, with 90% of students indicating that the quality of education was important or very important to their decision to study in BC.

Note: Percentages may not add up to 100%, as non-responses were not included in the table.

Opportunities for post-graduation work and permanent residence were also seen as important to a number of respondents, similar to the costs of studying in Canada. Approximately half of respondents identified these opportunities as very important. However, off-campus work was less of a driver. A little over a third of respondents indicated that it was not important.

Taking advantage of work opportunities

Employment opportunities are considered to be an important driver in the decision-making of international students,^{Footnote 48} and the off-campus and post-graduation work permit programs were cited in the interviews as contributing factors to Canada’s competitiveness. In particular, the OCWP program allows international students “to acquire work experience in the labour market, strengthen their ties to local communities and enhance their overall experience in Canada”, while the PGWP program “enhances employment opportunities for recently graduated foreign students, helping them to experience Canada and build relationships, with a view to encouraging immigration in a diversity of regions in Canada”.^{Footnote 49}

Off-campus employment: The number of students with off-campus work permits in Canada as of December 1st increased over the reporting period, from 652 in 2004 to 24,437 in 2008.^{Footnote 50} Seventy-nine percent of those with off-campus work permits in 2008 were studying at the university level.

Since the OCWP program became national in 2006, most international students with off-campus work permits have been distributed across Ontario, British Columbia, Quebec and Alberta, where most of Canada’s eligible educational institutions are located (187 out of 223 participating educational institutions).^{Footnote 51} In 2008, 86% of all international students with off-campus work permits were located in these four provinces, with the largest percentage concentrated in Ontario (36%).

Post-graduation employment: The number of students with post-graduation work permits in Canada as of December 1st also increased over the reporting period, from 3,004 in 2003 to 12,671 in 2008.^{Footnote 52}

The regional distribution inside and outside of the urban centres of MTV – is of note (see Table 3-3). Between 2003 and 2006, there were more international students with post-graduation work permits in MTV than in the ROC. However, this difference decreased in 2006, and the trend was reversed by 2007, consistent with the timing of the enhancement to the PGWP program that allowed international students outside of MTV to work up to two years post graduation.

The largest increase experienced both inside and outside MTV, was between 2007 and 2008, corresponding to the lessening in the requirements for the program.^{Footnote 53} The number of international students working post graduation increased by 50% in MTV, and by 40% in the ROC, representing an overall increase of 45%.

Throughout the reporting period, approximately half of the international students with post-graduation work permits were in Ontario, many located in Toronto.^{Footnote 54} In 2008, 31% of all international students with post-graduation work permits were located in Toronto.

On-campus employment: CIC does not track the number of international students working on-campus, as there is no requirement for a permit to work on-campus. However, findings from the CBIE Survey of International Students suggest that a number of students are taking advantage of this opportunity, with a little over a third of student respondents (35% or 2,080 respondents) indicating that they had worked on campus for pay during their studies.

Of note, more student respondents indicated that they had worked on campus than off-campus (18% or 1,092 respondents) or in a co-op/internship (11% or 631 respondents). These findings are consistent with results from the BC Survey of International Students, showing that of the 2,056 respondents who reported working for pay or wages in BC, 46% worked on-campus, 36% worked off-campus and 14% participated in a co-op or internship program.

Extent and quality of work experience: With respect to the OCWP program, findings from the CBIE survey showed that 37% of the international student respondents reporting off-campus work indicated that this experience was related to their program of study or future career plans. However, a greater percentage of respondents reporting on-campus work (59%) indicated that their work was related.

With respect to the PGWP program, it can be inferred that international students applying before April 2008 did in fact work and gain experience related to their future career path, as a job offer in a field related to their program of study was a requirement. However, changes to the program subsequently eliminated these requirements, along with the ability to make these conclusions.

Limitations to Canada’s global competitiveness

Issues with promotion and processing were highlighted as limitations to Canada’s global competitiveness in the interviews. Most of the respondents who indicated that the program was not globally competitive (10 of 11 respondents) highlighted issues with processing, primarily in terms of the time it takes. Moreover, many (7 of 11 respondents) raised issues related to promotion/recruitment, with a number indicating that Canada is not marketing itself sufficiently.

According to a DFAIT report, Canada’s underperformance is related to a lack of branding of Canadian education and a coordinated approach to marketing, as well as limited support for promotion and a lack of policy direction in Canadian missions abroad.^{Footnote 55} Unlike its competitor countries, education is not governed at the national level in Canada, posing unique challenges for promoting international education in a coordinated way, and the Canada Education Brand, “Imagine”, which unifies Canada’s promotional efforts, was not developed until 2008.^{Footnote 56}

Languages Canada notes that international students are choosing other countries (e.g. Australia) over Canada because their visa processes are easier and quicker.^{Footnote 57} Findings from the survey of educational institutions showed that a little over a quarter (29%) of the 34 respondents who provided suggestions or recommendations for program improvements wanted to see improvements to processing times (faster). Also, about three-quarters of the international students surveyed indicated that the ease of getting a Canadian study permit factored into their decision-making (see Table 3-2).

3.2.3 Program integrity

Program integrity was examined in relation to fraud and monitoring of international students and educational institutions in Canada and quality of decision-making.

Fraud in the student application caseload

Fraud in the student application caseload is a significant concern for CIC – not only does it pose a risk to the integrity of the International Student Program, but it also compromises Canada’s reputation for quality education and raises serious issues related to national safety and security.^{Footnote 58} Not surprisingly, misuse and fraud (or the extent to which it is occurring) was the focus for many interview respondents reporting unexpected or unintended outcomes of the ISP. Specific areas mentioned included the creation of illegitimate schools (“visa mills”), fraudulent consultants and issues with individuals using the study permit to get into Canada with no intention of studying.

Vulnerability of the ISP design: The legislative and policy framework supporting the ISP leaves the program open to potential misuse.^{Footnote 59} In particular, there is no legislative requirement for international students to study once they are in Canada. Students must demonstrate only an intention to study in order to remain in Canada for the duration of their study permit. Moreover, recent changes to ISP policies intended to be responsive to stakeholder needs have weakened some of the controls in place to prevent misuse. For example, study permits are now typically issued for the full length of the student’s program of study, and international students, and the educational institutions at which they study, are not required to notify CIC of any changes to a program of study or institution.^{Footnote 60}

CIC does not have a complete list of educational institutions in Canada. Educational institutions are loosely defined by CIC and are not required to meet any minimum standards to host international students. Public and private educational institutions offering academic, professional or vocational training are eligible, but within the existing jurisdictional framework the federal government has no legislative authority to regulate them. Provinces and territories are responsible for education in Canada. All have mechanisms in place to ensure the quality for publicly funded institutions, but such is not the case for most privately funded institutions.

Nature of fraud: CIC defines fraud as “an intentional misrepresentation or false representation of truth or concealment of material fact” and suspected fraud as “physical evidence, conflicting information or behaviour of applicant that would suggest misrepresentation.”^{Footnote 61} A40 is the inadmissibility provision for misrepresentation. “Persons who misrepresent or withhold material facts, either directly or indirectly, relating to a relevant matter that induces or could induce an error in the administration of the Act [IRPA] are inadmissible to Canada pursuant to A40(1)(a).” A44 is a report on inadmissibility. An A44 report may be written in situations where an application is refused by virtue of the A40 clause.^{Footnote 62}

Visa offices abroad were surveyed for the evaluation regarding different issues typically encountered with respect to fraud (see Figure 3-2). The majority (88%) identified non-genuine students as an issue. Sixty-six percent indicated that this was the most frequently encountered type of fraud.

Figure 3-2: Types of issues encountered by visa offices surveyed with respect to fraud (suspected or confirmed) (n=50)

Number of visa offices.

Text version: Types of issues encountered by visa offices surveyed with respect to fraud

Strategic analysis reports, produced monthly by CPC-Vegreville, were also reviewed to examine cases involving fraud and possible misrepresentation discovered during inland processing in 2008. This review found a total of 1,028 referrals for questions related to educational institutions for the year, accounting for 25% of the referrals related to anti-fraud or quality assurance. It also found between one and four descriptions of “interesting cases” involving student-related fraudulent activity each month. Issues highlighted in these cases included: not paying tuition fees while in Canada; fraudulent letters of acceptance; not submitting transcripts; questions concerning education path given past experience; and possible misrepresentation in transcripts.^{Footnote 63}

Previous work to examine fraud: One of the first efforts to take a closer look at student-related integrity issues was the work conducted by CBSA BC Region in 2006. In this review, CBSA BC Region identified and investigated several hundred cases of suspected student-related fraud. Some of the investigations also found links to organized criminal activities, such as prostitution and drug trafficking. From this work, “it became apparent that the scope of student-related fraud was much larger than anyone had previously anticipated.”^{Footnote 64}

That same year, CIC’s International Region conducted an anti-fraud survey of visa offices and case processing centres, and found that “fraud is prevalent in every region and every program, but is especially concentrated in the Africa-Middle East and Asia-Pacific regions, which have the highest percentage of TRV applications and are major sources of legal and illegal migrants.” In this study, temporary resident programs were highlighted by visa offices as being the most susceptible to fraud due to short processing times and low cost recovery fees; and the student application caseload was identified as having a slightly higher incidence of fraud than the other temporary resident streams. In addition, CPC-Vegreville noted the issue of questionable educational institutions, and indicated that CIC’s policy to issue long-term generic permits to students contributed to the program’s vulnerability.^{Footnote 65}

Stakeholder perception of fraud: In 2007, consultations were conducted during the ACISI and FPCCERIA meetings, at which there was a general consensus that some level of fraud exists and recognition that more data was needed. The potential of this issue to affect Canada’s ability to attract international students was also noted.^{Footnote 66}

There was also wide agreement that misuse and fraud exist within the ISP among partners and stakeholders interviewed for the evaluation. However, reports on the extent to which it exists differed between respondent groups. Though still relatively low (approximately one third), a higher percentage of CIC respondents indicated that fraud and misuse is a significant concern. Many respondents were either unsure whether fraud actually exists or did not know the extent to which it exists due to a lack of available data and fraud tracking mechanisms. Questionable educational institutions (mainly privately funded), misuse of study permits and fraudulent documents were all mentioned during the interviews as issues related to fraud.

Findings from the survey of visa offices showed that the frequency of fraud (suspected or confirmed) encountered in the student application caseload tended to vary across missions. Thirty percent of visa offices surveyed reported that they often encounter fraud in the student application caseload, while 36% reported that they rarely or never encounter it. Consistent with the 2006 anti-fraud survey, two-thirds of those reporting that they often encounter fraud were located in the Asia and Pacific region or in Africa and the Middle East.

Detection and verification of fraud

Much of the fraud attributed to the ISP is “suspected”, with only a small number of cases actually confirmed. CIC processes do not support the identification of fraud and the department lacks the means to track suspected fraud.

The 2006 anti-fraud survey report observed that “there is little consistency amongst visa offices in how fraud challenges are understood, documented, investigated and resourced,”^{Footnote 67} and that “the means to track fraud… are mission-specific, but more often non-existent.”^{Footnote 68} The 2008 ISP Review noted that CIC’s “case management systems do not have the capability to measure fraud within the immigration program.” It also reported that a data mining exercise, conducted in October 2007, found only 470 instances of A44 reports in FOSS linked to international students since the introduction of IRPA.^{Footnote 69} Consistent with these findings, the 2006 CBSA report on student fraud in the Pacific Region noted that of the 639 investigations initiated, only 80 were closed, resulting in 48 A44 reports (including both reports of inadmissibility due to misrepresentation and non-compliance).

Following the anti-fraud survey, OMC Branch’s Fraud Deterrence and Verification Division began a tri-annual anti-fraud reporting process with CIC visa offices abroad. As part of this process, A40 refusals (for both temporary and permanent resident applications) were compared against the total number of cases processed for three reporting periods: October 2007 to January 2008; February to May 2008; and June to September 2008. It was concluded that the A40 refusal was used so infrequently that it was “impotent as a fraud deterrent” and that the “use of A40 [could] no longer be considered as an indicator of anti-fraud activity”. Furthermore, the quality and consistency of reporting by visa offices was identified as an issue.^{Footnote 70}

Similarly, the reasons for refusals and frequency of referrals to CBSA, reported in the survey of visa offices, did not reflect an abundance of fraud. Visa offices surveyed estimated an average of 58% of refusals based on bona fides, 29% for lack of adequate finances and only 6% for misrepresentation (A40). Moreover, 31 visa offices surveyed indicated that they rarely or never refer cases to CBSA for further investigation (i.e. second-level anti-fraud verification), even though more than half of these indicated that they sometimes (35%) or often (23%) encounter fraud (suspected or confirmed).

As a possible explanation, results from the tri-annual anti-fraud reporting suggest that some visa offices find the A40 procedures to be cumbersome and impractical.^{Footnote 71} Moreover, it has been noted that instead of verifying suspected fraud, many visa offices refuse suspicious temporary resident applications for non bona-fides, thereby limiting CIC’s ability to systematically track and report on fraud.^{Footnote 72} Instructions to the field seem to support this practice: operational guidelines (OP23) advise CIC officers to carefully consider whether they should request a CBSA fraud investigation if they have sufficient information to warrant a refusal.^{Footnote 73}

Strategies to mitigate fraud in the student application caseload

Anti-fraud is the term used to describe the “processes implemented to deter abuse of the immigration program (or measures taken to mitigate fraudulent activity).”^{Footnote 74} There are two levels of anti-fraud. The first level includes activities to verify client information and documentation that are carried out by CIC and CBSA officers as part of their regular work. These activities provide “the first point for detecting fraud and initiating investigations”. The second level includes intelligence and investigative activities to detect and take action to counter fraud. Second-level anti-fraud is the responsibility of CBSA, both in Canada and abroad.^{Footnote 75}

CIC’s anti-fraud efforts are varied, and have been described as “uneven” across the department.^{Footnote 76} More recently, however, additional resources have been put in place to mitigate fraud in the immigration program. The results of these efforts for the student application caseload are as yet unknown.

CIC: The most commonly reported strategies used by visa offices surveyed were telephone verification (92%), document verification (90%) and personal interviews with a fraud focus (88%) – all activities that are in line with their first-level anti-fraud responsibilities. CPC-Vegreville also plays a role with respect to anti-fraud and the student application caseload. Most notably, it monitors educational institutions and immigration consultants about which there are questions. Also, when case processing officers suspect fraud or misrepresentation in a case, they can refer it for further verification.^{Footnote 77}

The document review noted other developments within CIC to increase capacity to mitigate fraud in the immigration program: the expansion of anti-fraud field support; the creation of an anti-fraud coordinator network; the distribution of an anti-fraud bulletin; the development of an anti-fraud training course; and the provision of various data collection tools (to assist with the tri-annual anti-fraud reporting).^{Footnote 78} The introduction of the Electronic Notification System (ENS) in the OCWP program is also believed to improve monitoring and reporting related to international students.^{Footnote 79}

CBSA: Findings suggest that CBSA’s involvement in anti-fraud activities related to the student application caseload has been somewhat limited, but may be growing. A little over half of responding visa offices reported that CBSA officers (e.g. MIOs) are rarely (34%) or never (20%) involved. However, this level of involvement may be appropriate for many visa offices, as almost half (48%) of the 27 visa offices that indicated this lack of involvement also reported that they rarely or never encountered fraud in this caseload. The most commonly reported types of CBSA involvement were providing consultation on anti-fraud activities (54%), conducting some second-level anti-fraud activities/investigations (46%) and handling complex cases of fraud (40%) – all activities that are in line with their second-level anti-fraud responsibilities.

However, more recently, increases in CBSA anti-fraud support have been observed. Twelve new anti-fraud officer positions were created in various visa offices abroad, and CBSA regional offices increased inland investigative support to CPC Vegreville and CPC Mississauga (including support to address student-related fraud).^{Footnote 80} In addition, CBSA recently received funding in the amount of $103.3 million over 5 years ($26.2M ongoing) through the CEC for the expansion of enforcement activities to address fraud in the Temporary Foreign Worker and International Student Programs.^{Footnote 81}

The funds allocated through the CEC were to support incremental increases in workload as a result of expected growth in the two temporary resident programs due to the new immigration stream.^{Footnote 82} However, funds were not allocated to CIC for corresponding increases to their processing workload, which is understood to include first level anti-fraud activities.

Country comparisons: The comparative study examined different approaches that have been adopted by other countries to deter fraud and ensure program integrity. It found that warnings about fraud were posted on nearly all websites, and that all countries in the review had comparable immigration and security requirements for international students.

The comparative study highlighted the utility of interviews (though costly and time-consuming) to minimize the various types of fraud. Of the countries reviewed, only the US and France conduct interviews with first-time applicants. The US and the UK were recognized for their use of biometrics.^{Footnote 83} Canada conducts interviews only in certain circumstances, when there are questions concerning an application, or a need for clarification or more information.^{Footnote 84} Canada is also currently developing a biometric system to be introduced in the Temporary Resident Program.

Monitoring educational institutions and international students in Canada

As discussed earlier, the ISP legislative and policy framework leaves Canada vulnerable to non-genuine students and educational institutions. One of the key ways to mitigate this risk is through monitoring. Thus, the federal government must work in partnership with provincial/territorial governments. There are several initiatives currently underway (federal, provincial/territorial, education sector and international) that can serve as models for the ISP.

Federal initiatives: The OCWP program and the “Imagine” Brand are two key federal initiatives that are grounded in a quality assurance framework. Both represent partnerships between the federal and provincial/territorial governments and incorporate a quality assurance component that limits the participation of education institutions to those recognized by provincial/territorial governments. In addition, the OCWP program requires that international students, using the program, continue to study and remain in good academic standing at their educational institution.

The Canada in India Student Partners Program (SPP) is another quality assurance initiative at the federal level. Established in April 2009, this pilot project brings together Canadian visa offices in India (New Delhi and Chandigarh) and the Association of Canadian Community Colleges (ACCC) to address program integrity issues in this locale. The SPP combines a strategy to streamline and improve the quality of documents supporting student applications (more reliable and verifiable) with monitoring of international students in Canada and better communications. Preliminary results have shown an increased approval rate for cases meeting all SPP document requirements and streamlined processing times.^{Footnote 85}

Provinces and education sector: There is a gap in the ISP quality assurance framework with respect to educational institutions that are privately funded. This segment of the education sector is not as closely monitored by provincial/territorial governments for the quality of education provided and the federal government does not currently have the legislative and/or regulatory authorities to enforce quality control.

There are a few initiatives underway to address this gap. The Government of BC is developing an Education Quality Assurance (EQA) designation that will be voluntary and available to all public and private post- secondary institutions in BC. Languages Canada (LC) serves both public and private language schools, and has an accreditation requirement for all member schools. The National Association of Career Colleges (NACC) has a Quality Assurance Initiative to institute a new accreditation process for private career colleges.

Country comparisons: The comparative study noted that non-genuine educational institutions have been, and continue to be, issues for each country reviewed, and that Canada was the only country reviewed “without a government-maintained, centralized, exhaustive list of approved educational institutions.”^{Footnote 86}

The study recognized Australia and the US for their monitoring of educational institutions and international students. Australia has quality assurance built into its legislation.^{Footnote 87} Its educational institutions are controlled through a combination of government and industry regulations, and must be registered and meet certain quality standards in order to host international students. International students in Australia are monitored by the Provider Registration and International Student Management System (PRISMS), in which educational institutions notify the government about course enrolments and visa breaches.^{Footnote 88}

However, Australia has recently made changes to its program to address issues of fraud, which make it more difficult to obtain a student visa (namely imposing stricter assessments for applying to lower-level courses), which has resulted in a recent and notable decline in international student applications corresponding to these changes.^{Footnote 89}

Like Canada, the US has experienced all types of fraud. However, having an approved list of educational institutions was of particular concern in the mid-1990s. The US introduced the Student Exchange and Visitor Program (SEVP) to certify educational institutions, by a recognized accreditation agency. In addition, it created the Student and Exchange Visitors Information System (SEVIS) to monitor international students already in the country.^{Footnote 90}

Quality of decision-making

Quality assurance is complementary to anti-fraud, and involves both the quality of decision-making and the reliability of client information. CIC defines quality assurance (QA) as the “planned and systematic processes, usually involving random sampling (either one-time or ongoing), used to monitor and assess established procedures;” and sets as its goal “to ensure efficiency, accuracy and consistency in decision-making, and to ensure fairness and integrity in programs.”^{Footnote 91}

In the student application caseload, QA activities vary between domestic and international operations and between individual visa offices abroad. Given this uneven approach to QA, it is difficult to assess the overall quality of decision-making on study permits, and thus verify stakeholder perceptions of its consistency.

Stakeholder perception of decision-making: When asked if decision-making is consistent on student applications, a little over a third of respondents (primarily provincial and NGO representatives) indicated that it is not consistent. About another third of respondents (primarily CIC) indicated that it is, although more than half of these qualified their response, identifying various issues. Regional differences, lack of clarity on IRPA guidelines, and dual intent were all mentioned during the interviews as issues affecting the consistency of decision-making.

Findings from the survey of educational institutions also highlighted a lack of consistency. A little over half (55%) of respondents disagreed that decision-making on study permit applications is consistent and appropriate. In contrast, only 20% agreed. Of the 33 respondents who disagreed, 14 were from universities, 8 from colleges and 10 from language schools. Eleven respondents highlighted various inconsistencies, such as differences between regions, offices, or students. Also, seven respondents noted that consistency in the study and work permit decision-making process could be improved.

Visa offices abroad: In 2003, CIC’s International Region introduced a QA framework in response to a recommendation from a 2001 Auditor General Report. However, “given the lack of additional resources to implement a quality assurance strategy and the diversity represented by the visa office network, International Region adopted a decentralized and phased approach to the quality assurance strategy”. The short-term goal of this strategy was to have quantifiable quality assurance activities undertaken at all visa offices, focussing on consistency and quality of decision-making and/or the fairness and integrity of the program. A reporting exercise was conducted in 2004 following the launch of the QA framework to develop a picture of the various QA and anti-fraud activities underway in visa offices abroad and identify operational needs and best practices that could be shared. During this exercise, 113 diverse activities were identified by 63 visa offices.^{Footnote 92}

Consistent with this decentralized approach, a number of visa offices surveyed for the evaluation reported conducting activities on an as needed basis, to assess:

• Quality and consistency of decision-making (40%);
• Reliability of client information (54%); and
• Reliability/consistency of process (50%).

Inland: In addition to the various activities abroad, CIC’s OMC Branch conducts an annual QA exercise on the student application caseload at CPC-Vegreville.^{Footnote 93} Two error rates are calculated as part of these exercises: the overall error rate, which represents the number of errors out of the total number of possible errors that could be made;^{Footnote 94} and the file error rate, which represents the percentage of files with one or more errors. A review of the reports resulting from these exercises over four fiscal years (FY 2005-06 to FY 2008-09) showed that while the overall error rate is low, the number of files with errors is high, with close to half of the files reviewed in each QA exercise demonstrating at least one error (see Table 3-4).

However, the scope of these exercises was limited, and on the decision-making process rather than on the accuracy of final decisions; and the types of errors tracked in these exercises were largely administrative (such as errors related to proof of sufficient and available financial resources, conditions imposed, valid until date, level of study and field of study, and name of educational institution).^{Footnote 95}

3.2.4 Program management and delivery

Understanding objectives, roles and responsibilities

Interview findings showed that partners and stakeholders had a similar understanding of ISP objectives. However, 29% of those interviewed reported a lack of consistent understanding of roles and responsibilities; representatives from provincial governments and other government departments accounted for more than half (58%) of this group.

A number of issues were mentioned regarding roles and responsibilities during the interviews. Of note, more than a third (37%) of those interviewed commented on a lack of understanding of either their role or the role of CIC, and approximately 17% noted a lack of communication and outreach by CIC.

Communications, information-sharing and coordination

Within CIC: Overall, the majority of CIC respondents interviewed expressed general satisfaction with communication and information-sharing within CIC. Those interviewed were primarily located at NHQ or in regional offices in Canada.

However, more than half of the visa offices surveyed reported that they rarely or never shared information related to student application processing with other CIC groups:

• With other visa offices: Rarely (54%) and Never (8%);
• With CIC-NHQ: Rarely (48%) and Never (8%); and
• With CPC-Vegreville: Rarely (42%) and Never (38%).

External partners and stakeholders: ACISI is CIC’s main conduit to consult and share information, and was identified by nearly 80% of those interviewed (32 respondents). Of those who mentioned ACISI in the interviews, 56% indicated that it was effective (though two-thirds qualified their response), 13% said that it was not effective, and the rest did not comment.

A number of other engagement mechanisms were also mentioned in the interviews. DFAIT’s working group/marketing strategy (NEMR/Canada Brand) (27%), outreach to educational institutions (24%) and provinces (17%) and FPCCERIA (15%) were the most frequently mentioned. Of note, half of the provincial representatives referred to DFAIT’s working group/marketing strategy and FPCCERIA; whereas CIC representatives primarily referred to outreach to educational institutions and provinces.

Educational institutions: Most educational institutions surveyed (92%) indicated that they had at least one means to participate in discussions and/or communicate with CIC regarding international student issues; 7% (4 respondents) indicated that they did not have or use a mechanism. Mechanisms included:

• National associations representing their interests (85%);
• Regional/local CIC representatives (one-third); and
• A provincial government representative (28%).

Most of those who identified regional/local CIC representatives (17 out of 20 respondents) or a provincial government representative (14 out of 17 respondents) were representatives from a university or college.

However, a number of institutional respondents (42%) indicated that they were dissatisfied with the mechanisms in place, while one-third indicated that they were satisfied. Of the 25 respondents who were dissatisfied, 11 were representatives from language schools, 8 from universities and 5 from colleges. Comments from the survey highlighted difficulties communicating directly with CIC and dissatisfaction with Call Centre service delivery (such as difficulty getting consistent answers to questions or difficulty getting through to a real person).

Employers: CIC has identified employers as a stakeholder group of the ISP in relation to the work permit programs.^{Footnote 96} It has been noted that the involvement and support of employers are critical to the success of these programs,^{Footnote 97} and that outreach will be needed to raise their awareness of the opportunity to hire international graduates.^{Footnote 98} However, in spite of an identified need to connect with them, the lack of representation on ACISI, as well as the low response rate to the survey for this evaluation, suggests that employers have not been very engaged in the ISP.

Functional guidance, information and support

Within CIC: Functional guidance and support related to student application processing is largely provided by way of the Overseas Processing Manual – Students (OP12). It explains the policies and procedures for processing study permit applications outside Canada, at ports of entry and inland. Operational Bulletins are issued periodically to disseminate current information on procedural changes related to student application processing.

Many CIC respondents interviewed, primarily from NHQ or regional offices, indicated that the tools and support provided by NHQ to ensure appropriate decision-making on client applications are insufficient and/or inadequate.^{Footnote 99} However, findings were mixed with respect to timeliness, with equal numbers reporting that the tools and support were or were not distributed in a timely manner.

Visa offices surveyed were asked to report on the types of functional guidance and support used or received from CIC-NHQ (past 12 months). The most commonly reported types were program manuals (96%) and operational directives/guidelines/updates (90%). To a lesser extent, anti-fraud resources and tools (52%) and operational statistics and trends (44%) were also reported by some visa offices.

Visa offices were also asked to reflect on the quality of the functional guidance and support used or received from CIC-NHQ (see Table 3-5).

Many of the responding visa offices agreed that the information on the delivery of the ISP presented in OP12 is clear and easy to understand and that OP12 provides useful information for the delivery of the ISP at their mission. However, results were more mixed in terms of the timeliness of functional guidance and support, with almost equal numbers indicating that they agreed or neither agreed nor disagreed that it is timely to support efficient student application processing.

Seventeen of the visa offices surveyed reported a requirement for additional guidance and support. Of these, eight indicated that they would like more information/support related to genuine/non-genuine education institutions/ program of study.

International students and educational institutions: The information and support provided to educational institutions and international students contributes to the quality of the applications submitted and the efficiency of the decision-making process.

Survey findings showed that most international students and educational institutions found the information and/or support provided by CIC to be somewhat or very useful, and that most educational institutions understand the study permit application process and can provide assistance when needed to international students.

However, 53% of educational institutions surveyed indicated that they required additional information and/or support from CIC related to study permits, and more than a third (38%) disagreed that CIC responds in a timely manner to requests for information/support related to the study permit application process. Of the 23 respondents who disagreed, 9 were from universities, 7 from language schools and 5 from colleges.

Policy and program development

As discussed earlier, CIC has made a number of changes to the ISP and policy framework over the reporting period to facilitate study and work opportunities, and the transition to permanent residence, for international students.^{Footnote 100} Partners and stakeholders interviewed were asked to reflect on the changes (other than the OCWP and PGWP programs) that have been made in this regard, and noted many changes. The most frequently cited changes were the introduction of e-applications and the CEC.

The document review also revealed that stakeholders have been supportive of many of the changes to the ISP – in particular recent enhancements to the PGWP program,^{Footnote 101} and survey findings showed that 81% of universities and colleges surveyed agreed that recent changes (for example, the introduction of off-campus work permits, changes to post-graduation work permit requirements, introduction of the CEC) have been responsive to their needs.

Program delivery

Stakeholders have been positive about the changes to Canada’s study/work package. However, there is evidence that there are some issues with the study and work permit application processes.

Study permits: A number of educational institutions do not believe that CIC policies and programs facilitate the entry of international students. Survey findings showed that 38% of universities and colleges disagreed and 27% agreed that CIC policies and programs are facilitative. Fifty-eight percent of language schools disagreed and 11% agreed.

Although many international students surveyed did not experience a problem or difficulty with the CIC study permit process, findings highlighted challenges for some. Some respondents reported experiencing somewhat of a problem or a big problem with obtaining a study permit (31%), and some with providing proof of finances to the Canadian government (35%). In addition, 30% reported some or much difficulty with Canadian visa officers in their home country. A number of those reporting “much” difficulty described frequent delays (application process/port of entry), unfriendly/not very helpful immigration officials or the inaccessibility of immigration officials.

Work permits: Results for the work opportunities were more positive. Of the universities and colleges surveyed, 68% agreed that CIC policies and programs facilitate work opportunities for international students; very few disagreed (4 respondents).

Findings from the CBIE survey of international students showed that of the 2,308 respondents indicating an experience with the services of CPC-Vegreville, the CIC Call Centre and/or local offices when applying for a work permit, 35% reported some or much difficulty. Similarly, findings from the CBIE study of international students and the workforce showed that 13% of respondents, reporting labour market experience, indicated getting a work permit but having to wait a long time for it.^{Footnote 102}

3.2.5 Application processing

Most new applications for study permits are processed in CIC visa offices abroad. However, study permit extensions, off-campus and post-graduation work permits are largely processed in Canada at CPC-Vegreville. In 2008, 92% of the study permits issued in Canada were for extensions; and 97% of the applications processed in Canada were finalized at CPC Vegreville. The numbers for off-campus and post-graduation work permits issued are reported in Table 1-6. The rest of this section focuses on application processing conducted in CIC visa offices abroad.

Table 3-6 presents information on the number of study permits received and processed in visa offices abroad by year, as well as overall refusal rates and processing times (passed + failed) within 28 days.^{Footnote 103} Visa office intake of study permit applications increased by 21% over the reporting period.

Although refusal rates have remained fairly stable over the reporting period (ranging from 22 to 26%), there was a notable decrease between 2006 and 2008 in the percentage of applications finalized within 28 days. A review of departmental documents indicates that the same resources are used for processing both permanent and temporary resident streams. As a result, increased demand in one stream can put pressure on the other.^{Footnote 104} The rising backlog in the permanent resident stream during this period, coupled with the increasing intake of study permit applications (by 17%), may in part have been responsible for this decline.

CIC administrative data show that there is considerable variability in intake, processing times and refusal rates across visa offices (see Table 3-7). In 2008, the percentage of applications finalized within 28 days was considerably lower and the refusal rate considerably higher for Africa and the Middle East relative to these rates for other regions and across all visa offices.

Processing times

Temporary resident applications are demand-driven, requiring rapid processing to facilitate the timely entry of visitors, students and temporary foreign workers. Although there is a perception that processing times in Canadian visa offices abroad are slow relative to other countries, there is little comparative evidence to verify this view.

Findings from the survey of educational institutions showed that 60% of respondents disagreed that processing times for study permit applications are reasonable. Of these, 17 were from universities, 9 from colleges and 9 from language schools. These results are consistent with interview findings (discussed earlier) that highlighted processing times as an issue limiting Canada’s global competitiveness.

Study permit processing times in Canada were compared to those of its competitors. The US, the UK, Australia and New Zealand all have processing service standards posted on their websites. New Zealand is the most ambitious, setting a target of 100% of applications finalized within 30 days; and the US sets the longest processing time of 90 days.^{Footnote 105}

Statistical information on processing times was only found for the UK. Actual processing times were compared across visa offices for the UK and Canada in three countries with similar intake (Riyadh, New Delhi and Sao Paulo-Rio De Janeiro) from October 2008 to September 2009.^{Footnote 106} This analysis showed that the UK was able to assess a greater percentage of applications than Canada in a similar timeframe in all three cases.^{Footnote 107} For Riyadh and New Delhi, the difference was substantial (26% and 28% respectively); for Sao Paulo-Rio De Janeiro the difference was 15%.

Factors affecting application processing

Further analysis explored factors that potentially affect the efficiency of application processing in visa offices abroad.

Intake: Mean refusal rates were fairly stable across intake levels. However, small visa offices, on average, finalized a greater percentage of applications within 28 days than average-size and large visa offices (see Table 3-8). The processing times for average and large visa offices were more consistent with the processing time for all visa offices (65% within 28 days).

Perception of fraud: According to the 2006 anti-fraud survey report, “detection of fraud in applications is resource-intensive.” Visa offices surveyed for this study estimated that cases with suspected fraud can take 3 to 10 times the amount of work to process than cases without.^{Footnote 108}

Subsequent analysis of 2008 operational data and survey data from the evaluation found that mean refusal rates were higher and the percentage of cases finalized were lower for visa offices reporting that they often encountered fraud (suspected or confirmed) in the student application caseload (see Table 3-9).

Educational institutions: Type of institution may also play a role in the resources required to process study permit applications. Over a third (38%) of visa offices surveyed reported that applications for study at private language schools required the most effort to process, while 20% indicated that applications for study at community colleges and 16% indicated that applications for study at private career colleges required the most effort. Applications for study at universities were reported by almost two-thirds (66%) of responding visa offices as requiring the least effort to process.

Similarly, a review of operational statistics for 2008 showed that refusal rates were the highest among applicants in the “post secondary” (45%) and “other studies” (26%) levels of study, corresponding to levels of study typically used to classify language schools and career colleges. Conversely, refusal rates were lower for those in the university degree levels of study (doctorate: 7%; master’s: 15%; and bachelor’s: 15%). However, information on processing times (in or under 28 days) was less consistent, showing similar processing times for these levels of study, except in the “other studies” category, where the overall processing time was faster.

Medical and visa requirements: Designated countries with medical and visa requirements involve extra steps in the student application process that can add time to processing.^{Footnote 109} It was estimated that 41 of the visa offices surveyed had visa requirements and 39 had medical requirements, with 38 having both, and 8 having neither. Moreover, all 15 visa offices reporting that they often encountered fraud (suspected or confirmed) had both visa and medical requirements, possibly compounding the resources required for application processing.

Subsequent analysis showed that the mean refusal rate was higher for visa offices with visa or medical requirements than those without (see Table 3-10). For mean processing times, visa offices with visa or medical requirements finalized a lower percentage of applications within 28 days than those without. However, the percentage finalized was still consistent with the processing time for all visa offices (65% within 28 days).

Addressing factors affecting application processing

Findings revealed three different approaches that could be further developed to address the variability in application processing related to the various factors discussed above.

Assessment levels in Australia: Australia has developed an interesting model of service standards related to processing times that takes into consideration the different factors described above.

Australia has two processing standards based on Assessment Level: one targeting 100% of level 1 & 2 applicants in no more than 28 days; and the second targeting 100% of level 3 & 4 applicants in no more than 84 days. Assessment levels “align student visa requirements to the immigration risk posed by applicants from a particular country studying in a particular education sector.” There are five levels, with the first level corresponding to the lowest risk and the fifth level to the highest risk. The higher the level, the greater the evidence required to support the application. Assessment Levels are believed to “enable consistency in decisions across this diverse range of clients” and “streamline this process, allowing the department to deliver fast and efficient service…while maintaining the integrity of Australia’s immigration program.”^{Footnote 110}

Canada in India Student Partners Program (SPP): Described in more detail in section 3.2.3 on Program integrity, the SPP approach shows how working with educational institutions, developing standardized documentation/tools and monitoring international students in Canada can mitigate risks to program integrity, as well as contribute to processing efficiencies.^{Footnote 111}

Online applications: Online applications, though only used in in-Canada processing of study permit extensions and work permits, present an interesting opportunity to improve application processing, in particular where the immigration risk is minimal.

Findings indicated that the use of online applications is believed to improve application processing and service delivery in the study permit program. Almost three-quarters of respondents to the survey of educational institutions (73%) agreed that the use of online applications facilitates the application process for the study and work permit programs. This is consistent with earlier interview findings in which e-applications was one of the most frequently cited program changes to facilitate study and work opportunities for international students.

Online applications were first introduced in the OCWP program as a pilot and then later incorporated into the study permit renewal process and the PGWP program. A study was conducted on the OCWP program pilot and a report produced.^{Footnote 112} It noted that educational institutions were pleased with the ENS, indicating that it was user-friendly and that they had more control over their time. In addition, CIC staff appreciated the reduced data entry and related data entry errors, as well as the paperless process.^{Footnote 113}

Relative costs and use of resources for application processing

A comparative analysis was conducted looking at relative costs and resource utilization across the three temporary resident streams (see Table 3-11). Measures from several data sources were used, including cost per permit,^{Footnote 114} processing times and refusal rates for 2008, data from the survey of visa offices and findings from the 2006 anti-fraud survey. A review of the requirements for each application process was also conducted to better understand the different elements considered in the assessment of applications for each temporary resident stream. Subsequently, each program was ranked from highest to lowest according to its score for each measure.

Based on these measures, study permit applications fell between the TFW and Visitor programs in terms of costs to process and percentage of applications processed within 28 days. Visa office survey respondents also indicated that the overall effort required to process study permit applications was greater than that required to process visitor permits but less than work permits. The estimated level of fraud in the student caseload is higher than the other streams. This may contribute to the highest refusal rate of the three, which in turn affects the ability to process applications in a timely manner due to the effort required to process suspected or confirmed fraudulent cases.

*Note: Certain countries are exempt; their inhabitants do not require a visa to visit Canada.
**Note: Additional application processing may be conducted in-land to extend the study and work permits, or process work permits for students, and is understood to be part of the CMM costing for the study and work permit programs. This additional work is for existing students or workers that have been processed abroad, and is thus included in the level of effort associated with these temporary streams.

Subsequent analysis supported this conclusion. The mean refusal rate was higher and the mean percentage of applications finalized within 28 days was lower for visa offices reporting that the student application caseload required the most effort to process. Also, eight of the 11 visa offices reporting the most effort indicated that they often or sometimes encountered fraud in the student application caseload.

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