International Student Program (ISP) Evaluation – Management Response Action Plan
Recommendation #1:
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
Response 1a:
CIC agrees with this recommendation and preliminary work for this recommendation is already underway.
Several federal departments have a role related to international students in Canada. The previous evaluation identified challenges that this can create, as the lead departments (CIC, CBSA and DFATD) have their own mandates that sometimes work at cross-purposes. This has continued to be the case since the last evaluation, despite efforts taken by CIC since that time.
Action 1a:
CIC will develop a Stakeholder Engagement Plan in order to put in place a more regular process for working with partners, including other federal departments, on ISP issues. (Accountability: Immigration Branch, Support: OMC; Completion date: Q1 2015-16)
CIC will ensure that International Student Program issues are raised to senior levels by ensuring that the International Student Program is a standing agenda item at existing governance mechanisms and meetings. (Accountability: Immigration Branch; Completion date: Q1 2015-16)
Response 1b:
While there are existing fora that facilitate coordination between CIC and CBSA and CIC and DFATD, both at the working and senior management levels, there is an opportunity to better leverage these fora in order to better work towards a whole-of-government approach to international students, and to identify inconsistencies that may arise due to the implementation of each department’s unique mandate.
Action 1b:
CIC, in collaboration with partners, will develop operational guidelines for assessing whether international students in Canada are complying with their study permit conditions. (Accountability: OMC; Completion date: Q3 2015-16)
Response 1c:
CIC aims to improve program and policy coherence across departments, through increased communications and collaboration with other federal departments, both at the working level and at senior management levels. CIC works with federal partners on an ad hoc basis, as necessary, in order to manage different priorities as they arise.
In order to support compliance monitoring in light of the 2014 ISP regulatory changes, CIC is implementing a Designated Learning Institution Portal for the ISP. However, on-going monitoring will require additional funding, thus CIC will continue to seek investment to support this activity.
Action 1c:
CIC, in collaboration with partners, will also develop administrative and operational processes to proactively use the information collected through the Designated Learning Institution Portal for ISP compliance reporting, to systematically assess compliance of international students. [Contingent on spending authority]. (Accountability: OMC; Completion date: Q3 2015-16)
Recommendation #2:
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.
Response 2a:
CIC agrees with this recommendation.
The evaluation revealed that the current ISP logic requires clarification, and in particular, those outcomes that relate to permanent residency. For example, transition to permanent residence is listed as an immediate outcome; whereas, if it were to happen, it would happen in the intermediate timeframe. The logic model also includes an immediate outcome of “selection processes are timely and consistent while supporting program integrity”. The use of the term “selection” is confusing in this context as it refers to decision making around permanent residents not temporary residents - this outcome will need to be revised.
The logic model review will also take into consideration relevant temporary and permanent resident programs, as well as OGD priorities.
Action 2a:
CIC will review the current ISP logic model and in particular its expected outcomes, and will make revisions as necessary. (Accountability: Immigration Branch; Completion date: Q2 2015-16)
Recommendation #3:
CIC should review its policies and operational guidance regarding minor students and custodianship.
Response 3a:
CIC agrees with this recommendation and preliminary work for this recommendation is already underway.
Taking into account CIC’s role in the application of Paragraph 30(2) of the Immigration and Refugee Protection Act, and Paragraph 215(1)(f)(i) of the Regulations which came into force on June 1, 2014, CIC is committed to review the implications that these provisions have on minors who are studying in Canada without a study permit, and their eligibility to apply for a study permit from within Canada. Operational instructions concerning the application of these provisions are outlined in the Program Delivery Instructions.
Action 3a:
CIC will identify and assess the gaps that exist in current processing guidelines. (Accountability: OMC; Completion date: Q1 2015-16)
CIC will consult provinces and territories, as well as the K-12 sector, to clarify each department and agency’s roles and responsibilities with respect to foreign minor children in Canada. (Accountability: OMC, Support: Immigration Branch; Completion date: Q3 2015-16)
Response 3b:
With respect to CIC’s custodianship requirement for minor study permit applicants, CIC is further committed to review the implications of this requirement, including the validity of the custodianship once the minor enters Canada, and clarify the Department’s objectives for requiring custodianship as well as its role in retaining the information.
Action 3b:
CIC will revise its operational guidelines (i.e., the Program Delivery Instructions), and the application forms, as well as update information on CIC’s website to ensure clarity. (Accountability: OMC, Support: Immigration Branch; Completion date: Q4 2015-16)
Recommendation #4:
CIC should strengthen information sharing across its processing network regarding program integrity (tools, best practices and reporting) and case referrals.
Response 4a:
CIC agrees with this recommendation. OMC Branch continues to promote staff awareness and understanding of existing program integrity tools.
Training to staff includes the Program Integrity (PI) Tool, which is a web-based application to conduct program integrity exercises, as well as the 5-Step Approach on Conducting Program Integrity Exercises. Since December 2012, a total of 35 webinars have been conducted, as well as 6 international and 9 domestic in-person training sessions.
Action 4a:
As part of the upcoming interim Program Integrity Strategy for the Integrated Network Project, and pending overall approval of the Strategy, CIC will make the use of the PI Tool mandatory. This interim Strategy will be implemented in a phased approach, starting in Summer 2015-16. (Accountability: OMC; Completion date: Q2 2015-16)
Response 4b:
CIC has the primary responsibility for screening, detecting and preventing first-level fraud and for assessing eligibility for benefits under Canada’s immigration and citizenship programs. The Program Integrity Framework is available to guide CIC staff on how to best incorporate risk management, quality assurance and fraud detection and deterrence principles into their daily work. CIC aims to achieve greater consistency with respect to the usage of existing tools across the network.
Action 4b:
CIC will continue to provide ongoing training either in-person (whenever possible) or by webinar. Additional webinars and training will take place over 2015-16.
CIC will ensure that PI final reports are systematically reviewed for fraud trend analysis. (Accountability: OMC; Completion date: Q3 2015-16)
Response 4c:
OMC also provides functional guidance and support to all offices (in-Canada or abroad) on the development of program integrity exercises to ensure the objective and methodology are sound and questions are targeted to the scope.
Action 4c:
CIC will identify the gaps in how information concerning program integrity issues and case referral information is shared across the network. OMC will raise staff awareness of available standardized protocols and points of contact to ensure information sharing on program integrity issues happens in a systematic way. (Accountability: OMC; Completion date: Q3 and on-going)
Response 4d:
Additionally, the Department is also implementing a Designated Learning Institution Portal to monitor the status of international students once a study permit is issued. The objective of this initiative is to strength the integrity of the ISP – information obtained from institutions will be available in GCMS and will allow officers to assess whether international students are complying with their study permit conditions.
Action 4d:
CIC will continue to add Program Integrity exercise reports to the Program Integrity Exercise Repository, which will be made available on CIC Connexion.
With respect to the Designated Learning Institution Portal for compliance reporting, CIC will develop and issue operational guidelines to ensure that study permit compliance will be assessed consistently. [Contingent on spending authority] (Accountability: OMC; Completion date: Q3 2015-16)
Recommendation #5:
CIC should monitor and report the impact of modernization initiatives on the ISP and identify opportunities to improve ISP processing times.
Response 5a:
CIC agrees with this recommendation.
CIC is committed to its modernization agenda and ensuring a more responsive system of doing business, offering better client service, more efficient and effective application processing, stronger program integrity, reduced fraud, and optimal use of technology.
Action 5a:
CIC will produce weekly processing reports on temporary resident applications, including study permit applications, that outline the processing times by application submission channel (i.e., e-App, VAC, other). (Accountability: OPMB, Support: CPR, IR; Completion date: Q4 2015-16 and ongoing)
Response 5b:
There are a variety of modernization initiatives that CIC has implemented over the past several years, and more initiatives are planned. Many of these initiatives are designed to have a positive impact on the processing of study permits and study TRVs, including e-Application, e-Medical, GCMS, workload distribution (e.g. VESPA), VACs and other facilitation measures for international students such as the Student Partner Program (SPP). It is difficult to isolate the impact of particular modernization initiatives and report on these distinctly in relation to processing times.
Action 5b:
CIC will improve processing times by promoting the submission of e-Applications and finding processing efficiencies (e.g. identifying low-risk cases to be centralized).
CIC will develop facilitative measures in order to accelerate study permit processing times, including the expansion of initiatives to Brazil for Students without Borders and Saudi Arabia for government sponsored students. (Accountability: OPMB, Support: CPR, IR; Completion date: Q4 2015-16 and ongoing)
Response 5c:
CIC recognizes the importance of monitoring and reporting on all modernization initiatives and currently undertakes this activity on a weekly basis through the TR Weekly Reports. These reports are reviewed by the appropriate branches and any necessary operational adjustments are made in order to meet departmental and program objectives. CIC continues to engage in this activity and to use the information in support of modernization and other departmental objectives.
Action 5c:
CIC will track ISP operational commitments made to Treasury Board Secretariat as a component of a suite of Temporary Resident commitments. (Accountability: OPMB, Support: CPR, IR; Completion date: Q4 2015-16 and ongoing)
Recommendation #6:
CIC should develop and implement a strategy to address ISP data quality issues.
Response 6a:
CIC agrees with this recommendation.
As the evaluation highlighted, there are continuing inconsistency and reliability issues with certain ISP data, including 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.
Action 6a:
CIC will develop and implement a data strategy to address the ISP data quality issues.
CIC will develop an issue analysis and determine steps for resolution in a ISP Data Plan through the Data Governance Council (DGC) and the Data Executive Steering Committee (DESC). (Accountability: Research and Evaluation Branch, Support: OPMB, SIMB Completion date: Q3 2015-16)
Response 6b:
In order to effectively address the data integrity issues, a whole-of-CIC approach needs to be taken, using the departmental data governance mechanisms, as there are implications across sectors. Developing and implementing a comprehensive data strategy for ISP will require close collaboration of R&E, OPMB, SIMB, and OMC.
Action 6b:
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