Evaluation of the International Student Program
7. Conclusions and Recommendations
Based on the evaluation evidence presented in this report, the following conclusions and recommendations are put forward.
The ISP remains relevant as it responds to a continuing need, aligns with federal and departmental priorities, and is aligned with federal role and responsibilities.
As there continues to be demand for international students to study in Canada and that international students bring economic and socio-cultural benefits to Canada, the evaluation found a continuing need for the ISP. Moreover, international students have been articulated as a priority in both federal and provincial/territorial government strategic documents due to the economic benefit they provide.
Although there is a clear federal legislative framework through the IRPA for the federal role in the ISP, and the Program is consistent with overall federal government responsibilities for authorizing the entry of temporary residents, provinces and territories and educational institutions also have a strong role to play in supporting the integrity of the ISP. Provinces and territories are well positioned to ensure the legitimacy of institutions in their jurisdictions, and educational institutions are well placed to provide information pertaining to the enrolment status of international students.
7.2.1 ISP Policy and Governance
CIC should work with federal partners to:
- Increase OGD coordination around program delivery and to further clarify departmental roles and responsibilities regarding the ISP; and
- Ensure compliance and enforcement of the 2014 ISP regulatory changes.
Between 2009 and 2013, coordination with regard to the ISP with provinces/territories and educational institutions via the Canadian Consortium was effective, particularly in terms of developing the 2014 regulatory changes. Despite these successes, there is room for strengthened governance and improved coordination on the ISP across federal departments whose active cooperation is critical for achieving the Program's expected outcomes. As the DFATD International Education Strategy seeks to double the number of international students by 2022, more coordination between DFATD and CIC on target markets and program integrity risks in specific markets would allow for better operational planning, and better alignment of resources for processing study permit applications. This will in turn help Canada to remain globally competitive in the 'pursuit' of international students.
In addition, more work is needed to clarify the appropriate role and objectives for CIC (overseas and in-Canada) to support DFATD efforts to promote and provide ISP-related information to international students. While CIC staff are often asked to provide accurate and up-to-date information to prospective students, educational institutions and other parties seeking immigration-related information, there is no clear direction and guidelines for CIC on how to support these efforts. By formalizing its role, in conjunction with other partners, CIC can ensure that prospective applicants have the information they need to submit complete applications and CIC offices are able to properly plan for and resource this activity.
Since the last evaluation of the ISP in 2010, CIC has implemented major changes to the ISP which are expected to improve program integrity. Although it is too early to assess the outcomes of these changes, there is room for increased coordination with CBSA to with respect to compliance and enforcement of the 2014 ISP regulations.
While international students are required to actively pursue their studies, a robust reporting system, as well as policies and procedures for enforcing the regulations, needs to be developed.
In light of GOC priorities for international students and the evolving CIC policy context, CIC should review and clarify the program logic for the ISP and more particularly its expected outcomes, also taking into consideration relevant temporary and permanent resident programs.
The ISP is demand-driven in that international students decide to apply to Canada and can take advantage of opportunities to transition to permanent residency, therefore the Program is, by default, processing applications received rather than selecting ideal candidates. In addition, the number of international students transitioning may be viewed as low in comparison to the total number of international students coming to Canada. Although there is some evidence to show that Canada benefits when an international student returns home and develops linkages and ties to Canada, many stakeholders expressed that there is also a benefit and need for some international students to transition to permanent residency.
Given that Canada is seeking to attract the best and brightest international talent, and also as the number of international students entering is expected to continue to increase, there may be an opportunity for CIC to review its program logic in order to ensure alignment between the ISP and CIC's other temporary and permanent resident programs as well as DFATD's objectives under the International Education Strategy.
7.2.2 Minor Students and Custodianship Requirements
CIC should review its policies and operational guidance regarding minor students and custodianship.
The evaluation noted several gaps pertaining to the processing of applications from minor students as well as requirements for custodians of unaccompanied minors. Evidence suggests that there is some inconsistency in the ways in which some unaccompanied minors are processed across CIC and CBSA as well as for how long to issue visas. In addition, both documents and stakeholders consulted as part of the evaluation suggested that requirements around custodians should be reviewed to ensure they are strong enough to protect minor students, who represent a vulnerable population and account for a significant proportion of international students (25% in 2013).
7.2.3 Coordination and Information-Sharing within CIC
CIC should strengthen information sharing across its processing network regarding program integrity (tools, best practices and reporting) and case referrals.
Within CIC, there is a need for better information-sharing between different offices that deal with study permit applications to allow for more systematic dissemination of reporting information on program integrity and better communication regarding case referrals between Central Processing and local CIC offices. By improving coordination in these areas, CIC will be able to ensure that program integrity information is more widely available to be used by decision-makers and that the referrals between Central Processing Centre and local CIC offices are better informed.
The 2010 ISP evaluation found that "quality assurance activities are inconsistent across the department, making it difficult to assess the overall quality of decision-making on student applications and verify stakeholder perceptions of inconsistency". In 2012, CIC undertook a network-wide exercise which demonstrated that decisions on study permit applications are consistent, and although decision-making is consistent, a variety of program integrity activities exist across CIC's network. While flexibility for processing offices to develop program integrity tools, procedures and reporting tailored to regional contexts is important, there are opportunities for better sharing of best practices (e.g. elements from the Student Partners Program in India) across CIC's processing network.
7.2.4 Processing Times and Modernization Initiatives
CIC should monitor and report the impact of modernization initiatives on the ISP and identify opportunities to improve ISP processing times.
Between 2009 and 2013, processing times for study permits and study TRVs have increased. During this time period, CIC introduced a service standard as well as several modernization initiatives designed to improve client service and reduce processing times. While early results suggest that modernization initiatives (such as the use of electronic applications and Visa Application Centres, in comparison to paper applications), have had a positive impact on timeliness of application processing for study permits, this has not been the case for study TRVs, where data indicates they have had a negative impact. Especially as the numbers of international students are expected to grow given recent trends and as part of the International Education Strategy, CIC should continue to monitor the impact of modernization initiatives to ensure that they are improving efficiency which translates to a positive impact on processing times per application. Moreover, CIC should explore the extent to which clients are aware and making use of faster application methods, and if necessary, promote the use of these methods to prospective applicants. Evidence from the 2010 evaluation of the ISP suggests that further usage and uptake of the fastest methods to process applications would contribute to positively impact Canada's competitiveness, as processing times are perceived by applicants as a key factor in selecting a study destination.
7.2.5 Data Gaps
CIC should develop and implement a strategy to address ISP data quality issues.
There continue to be gaps, inconsistency and reliability issues in ISP data. This includes concerns with data on short-term students (SX-1 visas), distribution of students by level of study, data on the field of study, and last country of permanent residence. In addition to these issues, stakeholders outside of CIC expressed that the department could do more to communicate and provide better quality data to ISP partners. Given the new requirements for data sharing (as outlined in Memoranda of Understanding between CIC and provinces/territories as part of the 2014 regulatory changes), having more reliable program information will be critical to support future policy and program development. As part of this effort, CIC should develop a strategy or plan for ISP data to ensure that credible and reliable performance data are being collected and used.
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