Evaluation of the International Student Program

5. Findings: Processing Outcomes

This section discusses findings of the evaluation related to the effectiveness of international student application processing and the impact of related modernization initiatives.

5.1 Student Entries

As illustrated in Table 5-1, both the numbers of student entries and those present in the country^{Footnote 1} have increased. Between 2009 and 2013, the number of foreign nationals with study permits entering Canada has increased by roughly 32% (from 84,869 to 111,865).^{Footnote 2} Over the same period, the number of foreign nationals with valid study permits in Canada on December 1 has increased by nearly 50% (from 195,760 to 293,503).^{Footnote 3} Data on short-term students (only from visa-required countries) shows that the number of study TRVs issued has remained relatively constant at around 37,000 per year.^{Footnote 4}

Source: GCMS and FOSS

Table 5-2 presents a demographic profile of international students entering with study permits between 2009 and 2013. Key trends include the following:

• Gender: The proportion of male and female students remained relatively constant (male students outnumbered female students by 10% to 12% depending on the year).
• Age: The largest age group was 18 to 25, accounting for just over 60% of all international student entries per year.
• Level of Study^{Footnote 5}: University level students accounted for between 40% to 46% of all international student entries. The proportion of students studying at secondary or lower level remained relatively constant and ranged between 21% and 23% of all student entries. Students designated at the "other post-secondary" level, who are within language institutions, private (non-public) educational institutions, and university qualifying programs increased significantly from 14% in 2009 to 23% in 2013. Conversely, trade students decreased as a share of student entries from 11% in 2009 to 3% in 2014.
• Source Country^{Footnote 6}: China has consistently been the top source country for international student entries into Canada and has seen its share rise from 19% in 2009 to 26% of all international student entries (in 2013) which is more than double that of India, which was the next highest source country in 2013 (12%). Following India, the next highest source countries were Korea (decreased its share from 13% in 2009 to 9% in 2013), France (remained constant at 6% from 2009 to 2013) and Saudi Arabia (decreased from 6% in 2009 to 5% in 2013).
• Province/Territory: In 2013, a total of 95,107 international students were located in Ontario, BC, and Quebec, representing 85% of all international student entries for that year. Between 2009 and 2013, Ontario saw its share of international students increase from 36% to 44%. Conversely, British Columbia saw its share of international students reduced from 31% in 2009 to 25%. The share of international students in other provinces and territories remained relatively constant and varied by 1% to 2% per year.
• Cities: Toronto, Montreal, and Vancouver represent by far the largest proportion of student entries when compared to other major Canadian cities (58% of all student entries in 2009 and 54% in 2013). Between 2009 and 2013, Toronto increased its share of international students from 21% to 27%, Montreal remained constant at 13% and Vancouver decreased from 24% to 14%.

Source: GCMS and FOSS

5.2 Timeliness of Application Processing

Data on processing times, from 2009 to 2013 displayed in Table 5-3 indicate that since 2011 CIC has been meeting its service standard for study permits but not for study TRVs. However, the average overall processing time for 80% of new study permit applications increased by 26% - from 38 days in 2009 to 48 days in 2013, while the average overall processing time for 80% of study TRVs has increased from 8 days in 2009 to 19 days in 2013.

It is important to note that the data presented in this section is the global average for study permits and study TRVs. The variability of processing times across CIC's network is discussed later in Section 5.2.2. In addition, between 2009 and 2013, processing times were affected by external factors such as the closure of several visa offices abroad (which meant transferring some files across CIC's processing network) as well as the 2013 Professional Association of Foreign Service Officers labour dispute which meant that the distribution of work between permanent and temporary resident lines of business (including study permits and study TRVs) shifted.

Source: GCMS

When asked to what extent interviewees felt student applications are processed in a timely manner, most CIC staff felt that it is currently timely, stating that CIC is generally meeting its processing standards for most applications. Overall, CIC interviewees noted that tools and systems, and procedures are in place (i.e. operational manuals, e-applications, and GCMS) to ensure timely decision-making.

While noting that the department is meeting its service standard for study permits, CIC interviewees mentioned several issues which can slow down application processing for international students:

• as noted in Section 4.1.1, referrals from CPC-V to local CIC offices do not specify the reason for referral, so local CIC offices must explore the whole application;
• peak periods can be unpredictable in intensity and make it difficult to staff appropriately; and,
• if documents submitted along with the application form are incomplete, processing of the application cannot be initiated and officers will return the application and documents to the client with a written request for the missing information. Hence, delays from institutions in issuing their letters of acceptance or applicants and/or applicants not submitting necessary documents or medicals contribute to delays in processing.

The perspective of other government departments, provinces and territories, and Consortium interviewees concerning timeliness did not focus on CIC's ability to meet departmental business standards but rather compared Canada's processing time with other countries. Most of these interviewees felt that Canada is still lagging behind other competitor countries in terms of the length in processing time, which reduces the competitiveness of Canada's ISP. Moreover, a report produced from the Australian government in 2011 which examined surveys results from international education agents, suggested that Canada is among the slowest in terms of processing time.^{Footnote 7}

In addition, processing time data across different offices in the CIC network indicates that on average, offices which served clients requiring biometrics took longer to process study permit applications than offices which serve biometric-exempt clients (60 days versus 45 days in 2013).

5.2.1 Comparison of Processing Time with Competitor Countries

While a full assessment of the ISP in terms of global competitiveness was not within the scope of the evaluation, a review of published processing times from select competitor countries was conducted to substantiate interviewee perceptions on the timeliness of CIC application processing.^{Footnote 8} In comparing the publicly available student visa processing times for Canada, the United States, and the United Kingdom,^{Footnote 9} Canada has the longest processing time out of the three.

The United States specifies on their website both wait times before getting an interview and an additional wait time for processing. The United States' processing times (combined average appointment and processing wait time) were significantly faster than Canada and the United Kingdom, with an average of 5 working days.

The United Kingdom has longer processing times than the United States. However, as indicated through the United Kingdom's publicly available processing times, 80% of Points Based System Tier 4 (equivalent to Canada's Study Permit) applications take 15 days to process. This is in comparison to Canada's processing time for 80% of its applications, which takes an average of 38 working days.

As noted in the 2010 ISP evaluation, longer processing times can negatively impact Canada's competitiveness.

5.2.2 Variability of Processing Times

Similar to the finding in the 2010 ISP evaluation, there continues to be variability in processing times of study permits across the CIC network.

As demonstrated in Figure 5.1, the processing time for study permit applications varied significantly depending on Canadian Visa Office. The processing time ranged from 20 days to 144 days for the processing of 80% of all study permit applications.^{Footnote 10}

Figure 5-1: Processing Times for Study Permit Applications by CIC Office, 2013

When asked to comment on the variability of processing times across CIC's network, most CIC interviewees noted that variability is reasonable in light of regional and country-specific contexts which involve additional program integrity risks (e.g. background checks for applications from certain higher risk countries can take up a lot of time). A few CIC interviewees also suggested that there are sometimes misalignments between volumes and resources Canadian Visa Offices receive to process study permit applications, which can be another cause for variability. These interviewees felt this is the case more often in smaller offices.

5.3 Impact of Modernization Initiatives

Some data was available to measure the impact of two key modernization initiatives introduced to improve processing times for visa applications impacting ISP: e-applications and Visa Application Centres. The impacts of these two initiatives for ISP are described below. In addition to application method (paper, e-application, Visa Application Centre), it is important to note that there may be other factors which influence timeliness (e.g., if certain Canadian Visa Offices prioritize the processing of study permits over study TRVs or whether the processing of e-applications are prioritized over paper, etc.). In addition, as both e-applications and the use of Visa Application Centres are relatively new to the department, they may have taken time to implement fully and seamlessly across CIC's processing network.

Data on processing times by application method (e-application, Visa Application Centres, and paper) demonstrates mixed results. As outlined in Table 5-4, faster processing times are associated with e-applications and usage of Visa Application Centres for study permit applications. For example, for study permit applications processed in 2013, the average time for e-applications, Visa Application Centres, and paper was 43, 45, and 64 days, respectively. However, data on study TRVs from 2013 indicate that e-applications and Visa Application Centres represent slower processing times than paper. Another concern is that the timeliness of application processing for Visa Application Centres has increased for both study permits and study TRVs in each year.

Note: Data on Visa Application Centres was only available starting in 2011 and data for e-applications was only available for 2013

Source: GCMS

While CIC interviewees reflected positively on the overall impact of modernization, they also provided observations regarding specific modernization initiatives:

• All interviewees were positive about GCMS and how it has facilitated the electronic movement of files across the CIC network.
• Most CIC interviewees explained that e-applications are good from a client service perspective in that they seem to be leading to overall reduced processing times. However, some officers noted that processing these applications can be more time consuming as a result of slow connection speeds or other technical issues.
• Most interviewees mentioned that e-medicals created savings and improved timeliness of application processing.
• Some interviewees mentioned centralization of low risk files as having a positive impact on timeliness allowing overseas officers to focus on higher risk files.
• All CIC interviewees agreed that Visa Application Centres were useful, noting that they ensure applications are complete and seem to be leading to reduced processing times.

5.4 Consistency of Decision-making

In order to assess the consistency of decision making, the evaluation examined the extent to which mechanisms and tools exist to support decision making and the approval and refusal rates for study permits over time.

In 2012-2013, CIC's Program Integrity Division conducted a Study Permit Network Exercise which found that independent monitors agreed with 96.4% of overseas decisions, 98.4% of CPC-V decisions and 91.4% of local CIC office decisions for study permit applications and concluded that decisions for study permits have been made in a consistent manner across the various CIC regions.

A review of documentation found that several mechanisms and tools for promoting consistency are in place including training programs for processing officers as well as manuals and other supports (e.g. templates, letters, systems, webcart, wiki, CIC website, Operational Bulletins).

The evaluation also examined the extent to which approval rates for study permits fluctuated between 2009 and 2013.^{Footnote 11} Table 5-5 indicates that approval rates for study permits have remained largely consistent and increased only slightly from 2009 to 2013 (73% to 75%).

Source: GCMS

When asked to what extent decision-making related to ISP applications is consistent, most of CIC interviewees felt it is very consistent due to the relatively straight-forward processing procedures in place as well as the existence of the aforementioned tools and supports which officers use. However, interviewees also pointed out that some inconsistency has been traditionally related to the assessment of the genuineness of particular schools. Some CIC interviewees also suggested that the designated institutions lists will allow for increased consistency in decision-making as the assessment of the educational institutions will already have been conducted.

5.5 Maintaining Program Integrity

Section 5.3.2 describes what has been done since the previous evaluation in terms of measures planned and underway to improve program integrity. This section provides information on the extent to which CIC has appropriate procedures in place for supporting program integrity.

5.5.1 Procedures in Place for Supporting Program Integrity

In addition to the regulatory requirement introduced on June 1, 2014 and the compliance reporting portal currently being developed for educational institutions to report to CIC on the enrolment status of their international students, CIC also has a number of mechanisms and tools in place to support program integrity including:

• Program integrity reports, such as the Study Permit Network-Wide Exercise 2012-2013, are conducted by the Program Integrity Division.
• Monthly reports are produced by the Centralized Processing Region and they highlight potential fraud trends, including issues that have been flagged to and from CBSA.
• Quality Management Reports are conducted by CPC-Vegreville on various lines of business, including a 2014 report on Temporary Study Permit Applications Refused in 2013.
• Strategic Analysis is also conducted by CPC-Vegreville, on specific elements of lines of business.
• Some Canadian Visa Offices have implemented special programs and have established unique criteria/procedures to better identify fraud and misuse (e.g. Student Partners Program in India and China).

Most CIC interviewees noted that these measures are helpful, but there could be better sharing of best practices and dissemination of program integrity reporting across CIC's network.

In particular, overseas staff highlighted innovative initiatives which have helped to create efficiencies in terms of screening study permit applications in certain Canadian Visa Offices, which could be implemented across the network. For example, the Student Partnerships Program in India and Beijing requires students to hold a Canadian Guaranteed Investment Certificate which has reduced the amount of time officers need to spend processing local banks' proof of funds.

In addition, when asked about procedures in place to support program integrity, all interviewees mentioned the 2014 regulatory changes. While all interviewees were positive regarding the new regulatory changes, some also noted limitations in the new regulations.

• Although the new regulatory changes target educational institutions (by requiring them to be designated by the province or a territory), it is often the education programs which are of concern (not just educational intuitions).
• Some CIC interviewees noted that there is some evidence that schools are beginning to design new vocational programs which attempt to circumvent CIC's new regulations. For example, language schools are creating "client service programs" which can allow students to have access to work opportunities.
• As well, a few interviewees noted as a concern that K-12 students fall outside of the new regulations.

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