Evaluation of the International Student Program
4. Findings: Program Management Outcomes
This section discusses findings of the evaluation related to the effectiveness of stakeholder engagement and the extent to which CIC facilitates work opportunities and transition to permanent residency.
4.1 Stakeholder Engagement and Coordination
One of the Program's expected immediate outcomes is to ensure effective stakeholder engagement and relationships and that there is a shared understanding among ISP stakeholders of the various roles, responsibilities, and policy and program objectives. In order to assess engagement of stakeholders, the evaluation examined the extent to which mechanisms that support engagement have been effective. As interviewees external to CIC were typically only able to comment on their own organization's interaction with the department, results on engagement were organized by stakeholder group (i.e. within CIC, between CIC and other federal government departments, between CIC and provinces and territories, and between CIC and Consortium members).
4.1.1 Coordination within CIC
Finding 4: There is a need to improve coordination and internal communications to address gaps relating to: information sharing on program integrity; referral protocols between processing offices; and departmental guidance on CIC's role in supporting promotional activities.
Within CIC, several mechanisms exist to support coordination and engagement related to the ISP. In terms of policy development and operational guidance, Immigration Branch and Operational Management and Coordination Branch work closely together to manage the Program through both formal working groups and informally through ad hoc communications. These branches also work together on Federal-Provincial-Territorial Working Groups to ensure the proper design and implementation of new and existing policies, such as to develop the 2014 regulatory changes to the ISP. Most CIC interviewees felt that these mechanisms have led to a strong and effective level of engagement and coordination within the department.
Gaps in engagement mechanisms and coordination
Many interviewees expressed that there are continuing gaps in effective engagement mechanisms and coordination issues between various CIC offices that deal with processing study permit applications. Primarily, there is a lack of formalized avenues (i.e. well-defined points of contact and standardized protocols) to share information concerning program integrity between inland and overseas application processing offices. This includes information on general trends in fraud and misuse in the Program, as well as mechanisms between local CIC offices and Canadian Visa Offices Abroad to direct inquiries on specific cases. Local CIC offices and Central Processing Staff also expressed the desire to have better communication between one another in terms of the referral process.Footnote 1
Furthermore, CIC interviewees felt there is a lack of proper coordination and cohesive departmental approach to support promotional activities. While promotion of international education falls under the responsibility of DFATD, CIC interviewees expressed that CIC's involvement in promotional activities targeting international students (e.g. international education events) is often requested due to the need for consistent, accurate, and up-to-date information on application procedures. Staff in Canadian Visa Offices Abroad and those in Central Processing Offices spoke about their participation in promotional activities led by DFATD. These interviewees felt that there were no clear direction and guidelines in place to define the specific roles and responsibilities with regards to CIC supporting promotional activities for international students. Many CIC interviewees felt that there is a need to have clear direction and guidelines on how the department should support promotional activities, which is currently not within the mandate of CIC.
4.1.2 CIC Engagement with Other Federal Government Departments
Finding 5: There is a lack of a whole-of-government approach between federal departments regarding international students.
From 2009 to 2013, CIC engaged with other federal government departments primarily on an ad-hoc basis, especially regarding the development of the 2014 ISP regulatory amendments. However, many CIC and other government department interviewees, as well as some interviewees from other groups (Consortium members, provinces and territories), expressed that there has been a lack of a coordinated approach to dealing with international students across the federal government.
In particular, many interviewees from CIC felt that there has been a lack of coordination between CIC and DFATD on the following aspects:
- DFATD's recent goal to double the number of international students in Canada by 2022, as set out in their International Education Strategy, does not align with CIC's operational resource planning.
- As well, it was mentioned that DFATD's promotional efforts in "key" emerging markets tend to emphasize higher risk locations, and such planning has not necessarily taken into consideration the full impact on CIC's program integrity and timeliness of processing study applications in these locations.
- Despite additional funding to DFATD to promote Canada to prospective international students, sufficient resources have not been earmarked within CIC to provide additional support to the ensuing demand on the processing of students.Footnote 2
- It is also expected that CIC participates actively in promotion activities overseas but with the centralization of many functions and reduction of its overseas network, the department's capacity to support DFATD promotional activities at Canadian Visa Offices Abroad has also reduced.
Moreover, many CIC and CBSA interviewees noted a need to improve engagement and coordination on compliance and enforcement issues within the ISP, especially in light of new regulatory changes which require students to be actively pursuing their studies. Despite this requirement, CBSA interviewees pointed out that the mechanisms for enforcing non-compliant students as per the 2014 regulatory changes are still under development.
Some CIC interviewees also felt that there is a lack of effective engagement mechanisms with ESDC. These interviewees noted that there has been a lack of guidance and coordination in regards to students who applied for a study permit prior to the 2014 ISP regulatory changes. While some of these students are able to work off campus without a work permit, their current study permit does not specify this ability. This has created difficulties among some international students attempting to obtain a Social Insurance Number and demonstrates that there was insufficient coordination between the two departments.
Overall, interviewees from all groups felt there was a lack of a whole-of government approach to the coordination of international students.
4.1.3 CIC Engagement with Educational Institutions
Finding 6: CIC's engagement with educational institutions is effective; however, there is a need to provide educational institutions with guidance on their reporting requirements as per the 2014 regulatory changes.
While on occasion local CIC offices provide information to Canadian educational institutions concerning the ISP, CIC does not typically engage directly with educational institutions regarding program management and policy development. Instead, CIC participates in quarterly meetings with the Consortium members that represent different sectors of education in Canada. CIC and Consortium interviewees noted that between 2009 and 2013 a large focus of these meetings was on developing the 2014 regulatory changes for the ISP. CIC interviewees who could comment on engagement with educational institutions, as well as interviewees representing Consortium members, all felt that the mechanism supporting engagement between CIC and educational institutions (via Consortium organizations) has been collaborative and effective.
Some Consortium interviewees indicated that CIC could engage better by providing more frequent and detailed information to stakeholders about the Program, which would allow both provinces/territories and Consortium members to better serve institutions and students. One outstanding issue noted by the Consortium interviewees was the need for more information to be provided directly to post-secondary educational institutions regarding the compliance reporting portal (which is still under development)Footnote 3 to ensure that international students are actively pursuing their studies.
4.1.4 CIC Engagement with Provinces and Territories
Finding 7: While it is sometimes difficult for provinces and territories to know where to direct complex questions regarding the ISP and their clients, the engagement with provinces and territories has been effective.
Between 2009 and 2013, CIC's primary means of engaging with provinces and territories on the ISP was through a Federal-Provincial-Territorial Working Group made up of representatives from CIC's and provincial/territorial ministries of education. Interviewees from the working group expressed that engagement mechanisms between CIC and the provinces are extremely effective, representing a model that Federal-Provincial-Territorial relations that other programs could follow. As well, many of these interviewees noted that the drafting of Memoranda of Understanding between CIC and provinces and territories as part of the 2014 regulatory amendment process has formalized the role of provinces and territories in contributing to program integrity and helped the provinces become active partners in the Program.
Similar to comments made by Consortium interviewees, a concern regarding engagement was raised by some provincial interviewees who indicated that they, as well as educational institutions in their jurisdictions, do not know who to contact within CIC to get answers to questions related to the ISP (e.g. visa-related issues, application procedures, policies concerning international students). Interviewees explained that questions related to the ISP used to be directed through the provincial government to local CIC offices. However, due to closures of local offices, some provincial governments and educational institutions found it difficult at times to obtain this type of information.
4.2 Facilitation of Work Opportunities and Transition to Permanent Residency
In order to assess the expected immediate outcome of the ISP: "responsive programs and policies that facilitate study and work opportunities for international students and transition to permanent residency", the evaluation examined the means by which international students can work and transition to permanent residency, and the usage and efficacy of these pathways.
Finding 8: CIC policies are in place to facilitate opportunities for international students to work in Canada and transition to permanent residency, and an increasing number of international students are making use of these opportunities.
4.2.1 Work Opportunities for International Students
As described in Section 1.2.1, there are several types of work streams available to international students depending on their level of study, educational status (part-time or full-time student), and the program of study.
Aside from eligibility criteria prohibiting some international students from working, both interviewees and documents reviewed did not reveal the presence of barriers for international students accessing work. In addition, when asked whether Canada's work opportunities are adequate, most interviewees noted it was difficult to comment without information on the type of work international students are doing and their impact on the Canadian labour market.
While many interviewees and the previous ISP evaluation noted that providing work opportunities for international students acts as an important incentive to attract potential students, they were also not able to compare Canada's work opportunities for international students with competitor countries. Although an in-depth country comparison was not conducted as part of the current evaluation, a cursory review of publicly available information on competitor country websites (Australia, United States, and the United Kingdom) suggested that Canada's policies providing work opportunities for students compare favourably to the countries examined. For example, both AustraliaFootnote 4 and UKFootnote 5 allows international students to work 20 hours per week during the school term. USA does not allow international students to work off-campus until after their first academic year; however, when students do work off-campus, it must be in their field of studyFootnote 6.
While most interviewees were supportive of the 2014 regulatory changes enabling certain international students to work without a work permit, there were diverging opinions regarding whether international students at language schools should be authorized to work without a work permit while studying.
Number of international students using work programs
Administrative data shows that the number of international students with work permits in Canada during their studies has increasedFootnote 7. As shown in Table 4-1, between 2009 and 2013, the number of international students present in Canada on December 1 with both a study and work permit doubled from 40,703 in 2009 to 83,235 in 2013 (representing 21% of all international students present in 2009 and 28% of all international students present in 2013).
|2009||2010||2011||2012||2013||% increase from 2009 to 2013|
|International students holding a work permit||40,703||21%||47,772||22%||60,114||25%||70,209||26%||83,235||21%||104%|
|International students not holding a work permit||155,057||79%||170,110||78%||178,930||75%||195,205||74%||210,268||72%||36%|
Note: This figure includes international students at all study levels and data only includes foreign nationals with the primary status as students with a study permit (i.e. data does not include study-permit exempt or those with the primary status as a worker who also holds a study permit)
As shown in Table 4-2, in terms of obtaining work permits following their studies, between 2009 and 2013, there has been a doubling of the number of students who transition to foreign worker status (from 15,434 in 2009 to 31,177 in 2013). Between 2009 and 2013, nearly all (93% in 2009 and 97% in 2013) of these students took advantage of the Post-Graduation Work Program (which does not require a Labour Market Opinion/Labour Market Impact Assessment). The remaining few (7% in 2009 and 3% in 2013) transitioned to other streams within CIC's Temporary Foreign Worker Program.
|Program||2009||2010||2011||2012||2013||% increase from 2009 to 2013|
|Post-Graduation Work Program||14,314||93%||14,830||97%||18,062||97%||24,151||97%||30,118||97%||110%|
|Temporary Foreign Worker Program||1,120||7%||520||3%||583||3%||752||3%||1,059||3%||-5%|
Note: Data only includes previous students with a study permit (i.e. data does not include previous study-permit exempt students)
4.2.2 Transitioning to Permanent Residency
The ISP facilitates the transition to permanent residency by providing some international students with avenues to gain work experience (e.g., through the Post-Graduation Work Permit Program) and qualifications which can act as an advantage or is required for applying under several of CIC's immigration programs. International students can gain additional points as a Federal Skilled WorkerFootnote 8, can apply under a specific student streams within CIC's Provincial Nominee Program, and can apply for permanent residency through the Canadian Experience ClassFootnote 9.
Number of students transitioning to permanent residency
Administrative data presented in Table 4-3 indicates that the number of international students that transitioned to permanent residency has increased by 20.9% from 2009 to 2013 (from 18,544 to 22,421, respectively).Footnote 10
|Immigration Class||2009||2010||2011||2012||2013||% increase from 2009 to 2013|
|Economic Class||2009||2010||2011||2012||2013||% increase from 2009 to 2013|
|Skilled workers - principal applicants||5,976||5,560||3,206||4,252||4,669||-22%|
|Skilled workers - spouses/dependents||2,389||2,110||1,300||1,738||1,496||-37%|
|CEC - principal applicants||1,275||1,535||2,435||3,474||2,463||93%|
|CEC - spouses/dependents||297||344||572||845||656||121%|
|PT Nominees - principal applicants||1,578||1,173||1,340||2,910||5,480||247%|
|PT Nominees - spouses/dependents||1,779||1,743||1,567||1,779||2,197||23%|
|Total Economic Class||14,213||13,569||11,331||15,835||17,762||25%|
Note: Data from this table represents the number of foreign nationals who have ever held student status
In terms of the transitions to permanent residency, the majority came through economic immigration classes, with the Provincial Nominee Program and Federal Skilled Worker transitions accounting for almost 62% of former student transitions in 2013. The Canadian Experience Class, which was designed as an avenue for student transitions, accounted for roughly 14% of all former student transitions.
4.2.3 Program Issues, Data Gaps and Unintended Impacts
Finding 9: Some program issues and data gaps were identified through the evaluation.
As the policy context surrounding international students has evolved and given the recent changes to the ISP, several data and program issues emerged, as identified by some key informants and documents, suggesting there may be an opportunity for CIC review its program priorities and objectives.
Program and Policy Issues
Both interviewees and documents identified some inconsistencies with respect to program objectives regarding the selection and retention of international students, as well as application processing of minor students (including the vetting of custodians).
CIC's current policy objectives related to international students are formalized in IRPA and are focused on the facilitation of international students to Canada, contingent upon applicants meeting admissibility requirements. As international students are selected by educational institutions based on their own criteria and according to their policies, the ISP is demand-driven and the CIC role is limited to processing applications of those students who have been accepted to study in Canada, while ensuring admissibility requirements are met.
However, some reportsFootnote 11 and some interviewees noted that Canada is seeking to attract the 'best and brightest' international talent. As CIC's current policy objectives regarding international students are responsive in nature, they are geared towards facilitating entry into Canada for those foreign nationals who have a genuine interest in obtaining a Canadian education. Educational institutions are responsible for the attraction, recruitment, and selection of qualified international students, while DFATD also engages in recruitment and promotion. In addition to the desire to attract the best and brightest international students, Canada's International Education Strategy (DFATD-led) also has an objective of doubling the number of international students in Canada by 2022, for which CIC has the responsibility of processing applications submitted. Nevertheless, concerns were raised by some CIC interviewees who noted that continually increasing the number of foreign nationals applying to study in Canada could affect CIC's capacity to process applications, which may in turn affect processing times. Another point that was raised was the potential impact of doubling the number and providing some applicants with the ability to work off campus without a work permit may impact Canadians' access to employment and study opportunities.
A second point that was raised by a few interviewees from CIC in regard to the selection of ideal ISP candidates was that more could be done to actively promote and provide information to ideal international student candidates on ways to transition to permanent residency. Additionally, some interviewees (from CIC and Provinces), as well as a few reports, suggested that the number of international students actually transitioning to permanent residency has been lowFootnote 12. Despite these perceptions, CIC does not currently have targets for the number of international students it would like to transition to permanent resident status but rather sets targets for various permanent residence streams/programs. The Government of Canada recognizes the benefits both to having international students stay on in Canada permanently after their studies, as well as return home. Several interviewees noted that while Canada can and should continue to benefit from both cases, neither CIC nor DFATD have attempted to quantify the relative benefits gained when an international student decides to stay or decides to return home after their studies.
It is clear that various objectives exist in relation to international students - some that would support a facilitative role by CIC and others that highlight a perceived need for international student selection and the potential for CIC to identify the number and type of international students in Canada. The numerous players that inform the policy context for international students each have competing interests and objectives, some of which are supported by CIC's current facilitative approach, and some of which may require CIC to play a stronger role. In light of this, there may be a need to further examine the relative benefits of international students working and transitioning versus international students returning to their home country; and, review the policy alignment between the ISP and CIC's other temporary and permanent resident programs as well as DFATD's objectives under the International Education Strategy.
The evaluation also found potential gaps in current policies related to minorsFootnote 13, which in 2013 represented 25% of international studentsFootnote 14. Regarding minors, internal documents reviewed indicated that there have been inconsistencies between CIC and CBSA regarding their respective application of the IRPA and its regulations with respect to issuing study permits to minorsFootnote 15. In addition, a few interviewees from CIC noted that the appropriate duration of visas and study permits that should be issued to minor children (e.g. for one year or to the end of their secondary education) is unclear.
Regarding custodianshipFootnote 16, an internal CIC report produced as part of a Study Permit Network Exercise conducted in 2012-13 indicated, "custodians do not appear to be documented in a consistent manner in GCMS. In fact, some offices do not record custodians at all, as a common practice." In addition, a few interviewees from CIC indicated concern that officers are not in a position to properly vet custodians.
A few interviewees suggested that, given the vulnerability of unaccompanied minors, CIC should consider tightening controls regarding the number of minors one custodian can oversee as well as regarding the nature of the relationship between a custodian and a minor.
4.3 Addressing Issues Identified in the Previous ISP Evaluation
The 2010 ISP Evaluation noted several issues affecting the ISP, which were regrouped into two themes: program integrity and application processingFootnote 17. While this section presents evidence on what has been done to assess these issues, performance related to the application processing and program integrity are addressed separately in Sections 5.2 and 5.5.
Finding 10: CIC has taken measures to address issues identified in the previous evaluation related to program integrity and application processing, primarily by creating lists of designated educational institutions, requiring international students to be actively pursuing their studies and through the implementation of initiatives to modernize its processing network.
4.3.1 Application Processing
Since the previous evaluation, in 2011 CIC introduced service standards to process 80% of study permit applications in 60 days and 80% of TRV applications within 14 days. In addition, in response to the finding from the 2010 ISP evaluation that 65% of study permit applications were completed within 28 days, CIC committed to review potential options for streamlining application procedures, and further reduce processing times, where feasible.
Between 2009 and 2013, CIC has implemented various initiatives to modernize its application processing network under the Managing the Workload Pillar of the C-50 Modernization Initiative. These initiatives, which have affected processing for both temporary (including study permit) and permanent applications include e-applications, e-medicals, risk triaging low risk files, centralization of application processing, distribution of work across offices, creation of Visa Application Centres (VAC), and utilizing Temporary Duty assignments during peak periodsFootnote 18.
Some of these initiatives were designed to make it easier for applicants to apply for study permits. These initiatives include e-applications and MyCIC accounts, which are self-serve online methods of applying for study permits and allow an applicant to monitor the progress of their applicationFootnote 19. In addition, Visa Application Centres were also created to allow for more points of service closer to the homes of applicants and to ensure that applications being submitted were complete.
From the CIC processing perspective, GCMS allowed for documents to be processed electronically at any Canadian Visa Office around the world. As a result, this allowed for the Centralized Processing Centres to triage files. For example, beginning in May 2011, student applicants from 14 designated countries were able to submit their application online through the Visa Exempt Study Permit Abroad Electronic Application Service. Online tools such as e-medicals were also introduced as a way for Immigration Medical Exam results to be electronically sent to CIC.Footnote 20
The impact of e-applications and Visa Application Centres and their effect on processing times for student applications are discussed further in Section 6.3.
4.3.2 Program Integrity
The 2010 ISP evaluation found that CIC's policy framework and gaps in program design left the ISP vulnerable to potential misuse (i.e. at that time there was no legislative requirement for international students to study once they were in Canada and CIC did not have a complete list of legitimate educational institutions in Canada). It was also noted that in the absence of data and consistent reporting on fraud and misuse, it was difficult to determine the extent of the problem and related implications for program integrity.
Between 2009 and 2014, CIC has implemented a number of changes to strengthen program integrity, most notably through the 2014 regulations for the ISPFootnote 21. The regulation changes were made with the intention of "protecting Canada's international reputation for high-quality education and improving services to genuine students."Footnote 22 As a result, the goal of these changes was to reduce potential fraud and misuse within the ISP.
The regulatory changes introduced three key changes to the ISP: 1) CIC to only issue study permits to applicants enrolled at designated learning institutions; 2) to require students to enrol and actively pursue their studies at a designated learning institution; 3) to streamline work programs available to international students.
As of June 1st 2014, all provinces and territories, with the exception of Nunavut, have implemented a designated learning institution list which contains the provincially/territorially approved post-secondary institutions allowed to host international students. In order for an international student to receive a study permit from CIC, they must have a letter of acceptance from a designated learning institution, a list of which is available on CIC's website.
Under the new ISP regulations, international students are required to be actively pursuing studies. Actively pursuing studies includes being enrolled and making reasonable and timely progress towards the completion of their study program. Reporting on this requirement will be done by educational institutions (outside of Quebec) directly to CIC.
An assessment of ISP performance associated with program integrity is discussed further in Section 5.5.
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