Post-Graduation Work Permit Program Pilot Project: A ten-month mark pilot review

Table of Contents

• Executive Summary
• 1.0 CIC Statistics on Work Permits Issued Under the Pilot
• 2.0 Summary of Institution Survey Results
  • 2.1 Pilot Uptake
  • 2.2 Benefits of the Pilot
  • 2.3 Challenges and Concerns with the Pilot
• 3.0 Summary of Survey of CIC Staff
  • 3.1 Challenges and Concerns with the Pilot
  • 3.2 CIC Data Collection
• 4.0 Institutional Eligibility
• 5.0 Communications Between CIC and BC
• 6.0 Coherence Between Pilot and Changes to the International Student Program
• 7.0 Conclusion
• Appendix A
• Appendix B
• Appendix C

Executive Summary

As part of the “International Student Annex” of the Canada-British Columbia Immigration Agreement, Citizenship and Immigration Canada (CIC) and the Government of British Columbia (BC) committed to the development and implementation of a two-year pilot project (the Pilot) to expand eligibility for the Post-Graduation Work Permit Program (PGWPP) to international students in non-degree granting, career training programs of eight months or longer, graduating from select private post-secondary institutions in British Columbia.

This Pilot was designed to (a) increase the attractiveness and improve the experience of BC post-secondary education for international students, (b) increase temporary labour supply for key industries and occupations in the province, (c) facilitate transitions from temporary to permanent status for international students who require work experience in British Columbia/Canada in order to qualify for permanent residence. The objectives of this pilot are framed within the greater priority of strengthening the integrity and success of the international student program.

The pilot began on January 31, 2011 and is scheduled to end on January 31, 2013. At the time of implementation, international students in career training programs of eight months or longer at private institutions that had received their Education Quality Assurance (EQA) designation prior to January 31, 2011, were eligible to participate in the pilot. Nineteen non-degree granting educational institutions and seven degree-granting educational institutions were initially approved for the pilot (see Annex A for a full list of participating institutions).

CIC and BC agreed to undertake an initial review of the pilot at the ten-month mark in accordance with standards jointly developed by CIC and BC. Results of the review, which are outlined in the document below, will be used to determine whether or not participation in the project may be expanded to additional institutions beginning in early 2012. A second evaluation of the pilot will be carried out beginning in early 2013.

Pilot Review Methodology

CIC and BC officials collaborated on the development of the Pilot review, and included the following elements:

• Analysis of work permits issued under the Pilot;
• Analysis of data provided by institutions and compiled by BC;
• Qualitative survey of participating institutions and CIC staff in Case Processing Centre-Vegreville (CPC-Vegreville) and staff in the British Columbia/Yukon Regional Program Office;
• Analysis of the Pilot’s eligibility criteria
• Analysis of communications between CIC and BC; and
• Analysis of the coherence between the Pilot and the policy objectives of CIC

Key Results

Overall, results from this first review of the pilot are mixed. There are many positive outcomes reported, but there are also areas that have been identified that could be strengthened in order to improve the pilot’s integrity and success.

Feedback from participating educational institutions obtained through surveys administered by British Columbia was extremely positive. Participating institutions that tracked the number of international student applications to their institutions before and after the pilot reported a 21% growth in international student applications since the Pilot was launched. While it is unknown whether or not the growth is attributable to the pilot or how it compares to other non-participating EQA-designated private institutions, participating institutions have reported receiving positive feedback from students indicating that the pilot has had a positive impact on their education experience in Canada. Support for the pilot on the part of participating institutions and employers was also high with 100% of surveyed institutions reporting that they were either “highly supportive” or “supportive” of the pilot.

Additionally, while it is too early to determine the long-term impact of the pilot on BC’s labour supply in key industries, feedback from some participating institutions and employers indicates that the pilot is helping fill short-term labour market gaps, particularly in the IT and film industries.

CIC processing officers had no major concerns with the pilot. Surveyed staff reported that the applications received under the pilot were of “satisfactory” or “high” quality.

Despite some of these reported positive outcomes, there are some elements that have been identified, both throughout the pilot’s implementation and as part of this review, as needing improvement. Firstly, pilot guidelines stated that participating institutions should maintain linkages with international students after graduation to gain feedback on their post-graduation work experience. While the majority of participating institutions (72%) reported that they tracked the number of international students that received post-graduation work permits, most institutions advised that they had limited capacity to monitor student outcomes post-graduation. As a result, there is a fundamental data gap preventing an accurate assessment regarding whether or not the pilot is meeting its objectives.

On another issue related to tracking of data, CIC had committed to implementing a special program code in order to track the number of graduates that received a work permit under the pilot. While a special program code was in fact developed, application of the code amongst officers was particularly low due to a number of factors (e.g., staff rotation across business lines, volume and resource pressures, and service standard goals). As a result, CIC was not able to obtain accurate data on the number of work permits issued under this pilot for this review.

Secondly, pilot guidelines identified non-degree “career-training” programs as eligible under the pilot, and excluded non-degree programs such as general interest courses or programs that consist primarily of English or French as a Second Language. Throughout the course of the pilot review, however, it became unclear in some cases as to whether or not some non-degree programs were considered to be career-training programs, for example, university preparatory programs.

Further, some stakeholders have raised and continue to raise issues around educational institution eligibility criteria. Original criteria for the pilot allowed for the inclusion of private post-secondary educational institutions that had received their EQA designation before the pilot’s January 31, 2011 start date and that enrolled students in career training programs of eight months or longer. The January 31 cut-off date appeared arbitrary to stakeholders and was reported to have negatively affected institutions that may have applied for their EQA designation sooner had they been aware of BC and CIC’s plans to launch the pilot in January as well as the criteria required to participate.

Finally, there were some issues related to the administration of the pilot that were identified that may be impeding both efficient work permit processing and delivery of the pilot. The International Student Sub-Committee for the Canada-BC Immigration Agreement has communicated and resolved a range of issues related to the pilot. In the absence of explicit information sharing guidelines in the pilot proposal, however, important issues were not always efficiently communicated and/or resolved between BC and CIC.

1.0 CIC Statistics on Work Permits Issued Under the Pilot

CIC data is not considered to be reliable with respect to how many work permits were issued under this pilot. This is largely because the program code assigned to this pilot for the purpose of tracking work permits issued was largely not recorded in processing systems by CIC staff. Consequently, CIC is unable to track the total number of work permits issued by the department in the first phase of this pilot.

2.0 Summary of institution survey results

BC conducted a survey of all participating institutions to gather quantitative and qualitative feedback to help determine whether the Pilot is meeting its objectives. Participating institutions received the survey on October 26 and were given 12 days (until November 7) to complete the survey questionnaire. Of the 19 participating institutions surveyed, 18 institutions completed the survey questionnaire, a response rate of 95%. One institution that did not have eligible programs or international students at the time of this survey did not complete the survey. The survey included a total of 12 questions, with a mixture of closed and open-ended questions. A copy of the survey can be found in Annex C.

2.1 Pilot Uptake

Of the 724 international students who graduated from participating institutions between January 31, 2011 and October 31, 2011, 216 (or 30%) participated in the post-graduation work permit pilot according to statistics gathered by BC from participating institutions. It is worth noting that in preparation for the launch of the pilot, BC had initially forecast higher numbers of graduating students and a pilot uptake in the 600-800 range in the first year of the pilot.

Pilot guidelines noted that institutions would be expected to share data collected on graduates in the pilot, to the extent possible. However, not all institutions tracked the number of international student applications to their institution for the same period last year. There is not, therefore, complete data to show how the pilot influenced international student enrolment at participating institutions. While most institutions (72%) were tracking students receiving work permits, many institutions did not track student outcomes post-graduation, in some cases because they lacked the capacity to do so or because they found it was too soon after their graduates had received their work permit to report on outcomes Institutions that were tracking indicated that it is a Private Career Training Institutions Agency [Note 1] (PCTIA) requirement to follow up with students after they graduate. Various methods were used to track including mail, telephone, email, and social media. Institutions that were not tracking students post-graduation either did not have international students to track or did not know that tracking was a pilot requirement. Implementing policy and/or regulation to compel institutions to comply with monitoring objectives may be necessary in the future as post-graduation outcomes tracking remains a priority for BC and CIC. Of the 15 (83%) participating institutions that collected applications data the previous year, there has been a 21% growth in international student applications since the Pilot was launched. It is not known if this growth is a direct result of the pilot; however, it is worth noting that CIC data for BC international student flows during this one year period indicate an overall international student population growth of 17%.

Of the 15 (83%) institutions that track international students who receive work permits post-graduation, four institutions recorded 30 international students having found employment related to their fields of study. The remaining 11 institutions that track students reported that students had not yet found employment (1); that students had not applied for a work permit yet (5); that they do not track details related to employment type (4); and that they have not reached the 6-month follow-up milestone (1). Three institutions noted that they do not track international students post-graduation.

2.2 Benefits of the Pilot

Support for Pilot
Participating institutions unanimously supported the Pilot.  Of the 18 institutions that completed the survey, 100% answered that they were either “highly supportive” or “supportive” of the pilot. 
Institutions felt that the Pilot has generated interest among international students attending their institutions.  Fifteen participating institutions, or 83%, indicated that their students were “very interested” in the Pilot while the remaining institutions answered “interested,” “neutral” and “not applicable.”    

Increased Attractiveness and Competitiveness of Institutions
Participating institutions commented on how the extension of the work permit program to private career colleges make them more attractive to international students who may have otherwise selected a public college.

Notwithstanding the positive anecdotal feedback from institutions participating in this pilot, it is worth noting that the low pilot uptake (216 actual compared to the 600-800 forecast) indicates that international students may not actually view participating institutions as more attractive.

Temporary Labour Supply in Key Sectors
Some institutions, particularly those whose programs relate to the Information & Technology sector, commented that their international student graduates are sought after by local companies who self identified as coping with a short supply of skilled labour. As some programs that are offered in the participating institutions are in areas where BC faces skill shortages, participating institutions commented on how the ability to stay and work post-graduation can alleviate labour shortages. Participating institutions also expressed a desire to extend the PGWPP permanently to BC private career colleges and to expand it to make Canada more competitive and to help employers fill temporary vacancies.

The desire for international students to gain practical Canadian work experience after graduation was also expressed by several participating institutions.  Some indicated that their students have been offered jobs after graduation, which would otherwise be more difficult to obtain in the absence of the Pilot.  Some students do not wish to go home immediately after completion of their program, but have a desire to apply their education credentials in the Canadian work environment.

2.3 Challenges and Concerns with the Pilot

While the Pilot has been well received by participating institutions, some challenges have been identified.

Communications
In light of the limited experience of visa offices with the Pilot – as the PGWPP in general is nearly always processed inside Canada – there was at times a lack of knowledge or familiarity with the Pilot parameters. As a result, on several occasions, Pilot graduates were refused work permits by certain visa officers on the basis that the institutions was incorrectly determined to be ineligible for the PGWPP.

Cases where applications were inappropriately refused were reviewed and corrected by either CPC-Vegreville or at the local CIC office and no further incidents involving erroneous refusals have come to the attention of CIC National Headquarters (NHQ) staff. CIC has sent a reminder to processing staff concerning the pilot and its list of participating institutions. 

Compliance
Compliance with pilot guidelines by participating institutions was high; however, there were a few recorded non-compliance issues mostly related to marketing of the pilot in advertising materials in the first several months after the pilot was launched. Some participating institutions indicated that other participants were using the pilot as a direct marketing tool, which does not comply with the pilot guidelines which prohibit participating institutions from developing “marketing material for the institution or its programs where the ability to work upon graduation is the main focus of the messaging.”

3.0 Summary of Survey of CIC Staff

CIC staff at CPC-Vegreville who had processed applications for the pilot had generally positive reviews on the first ten months of the pilot’s implementation. With one exception [Note 2], there were no major concerns raised by staff and a majority of those surveyed reported that the applications received under the pilot were of “satisfactory” or “high” quality. Despite this positive information, the majority of staff reported low levels of confidence in BC’s EQA designation, likely due to lack of knowledge, and low or neutral levels of confidence in the institutions participating in the pilot based on past experiences with these institutions. Some survey responses indicate that communication and guidance from CIC National Headquarters (NHQ) to processing staff could be improved. A copy of the survey questionnaire can be found in Annex B.

3.1 Challenges and Concerns with the Pilot

Compliance Issues
There were no major compliance issues identified by CIC employees in regional offices and at CPC-Vegreville. In a small number of cases CIC staff did note inconsistencies between information concerning programs of study detailed on Letters of Acceptance and program information found on the websites of both participating institutions and PCTIA. The compliance history of some participating institutions was also cited as an area of concern for CIC staff in the survey. For example, officers noted that some participating EQA designated institutions had raised concerns for the department in the past in relation to the Co-op/Internship programs offered to international students at these colleges.

Confidence in the EQA Designation
In some instances, officers’ past experience with some of the participating institutions contributed to lower levels of confidence in the EQA designation as a reflection of the quality of an educational institution. Roughly 12% of CIC staff members who answered this question were “Not confident at all” in the EQA designation while 61% were “Somewhat confident”, 23% were “Confident” and 4% were “Very Confident”. The level of confidence that surveyed staff placed in the institutions approved by BC for the pilot, however, was somewhat higher. Approximately 60% of respondents had neutral or confident views on the participating institutions. The remaining respondents were either “Somewhat confident” or “Not confident at all” in the institutions participating in the pilot. Staff did report, however, that they were unfamiliar with both the process used by the province to designate an institution and how the designation differed from the accreditation process in place through PCTIA.

Participating institutions’ knowledge of pilot guidelines
CIC staff noted that some institutions were not always well informed about the guidelines under the pilot. This made communication with institutions staff difficult as they were not always aware of, or understood the requirements of the pilot. Staff also noted that documents provided by institutions were often incomplete making it difficult for CIC staff to determine if the applicant met the eligibility criteria for the pilot. 

Information Dissemination
Given that a number of operational bulletins on all of CIC’s lines of business are issued each week, staff felt that it was difficult to remember the particularities for processing applications under each pilot or initiative. Generally CIC field staff felt that the operational bulletins concerning the pilot provided clear instructions while, others expressed frustration at the additional special reporting requirements for processing the applications. Some staff, however, also felt that information on the pilot was not disseminated in a clear way, partially due to the revision to the initial list of eligible institutions and other changes to the program which was transmitted through multiple documents. 

3.2 CIC Data Collection

The use of appropriate program coding in CIC’s electronic systems was a challenge for the department in the first half of the pilot. In February 2011, operational bulletin 262-b was placed on CIC’s website and transmitted to immigration officers. Through the instructions outlined in the bulletin, officers were required to use the new special program code “ISP” to identify applications received under the pilot when processing applications in CIC’s electronic systems. The use of the code for statistical research, evaluation, and policy development was highlighted in the operational bulletin. In August 2011, CIC performed its first statistical inquiry into the number of “ISP” coded applications entered into CIC systems. As a very low number of pilot applications were found to be in the system, NHQ sent out a reminder to case processors to apply the “ISP” code to applications under the pilot. Unfortunately, application of the code remained low resulting in inaccurate data concerning the pilot. 

4.0 Institutional Eligibility

Eligibility criteria for participation in the pilot allows for the inclusion of private post-secondary educational institutions that had received their EQA designation before the pilot’s January 31, 2011 start date and that enrolled students in career training programs of eight months or longer. A cut-off date for EQA designation, beyond which institutions would not be eligible for the Pilot, was used in order to allow BC and CIC to effectively manage the scope of the Pilot. It also helped CIC and BC to develop a reasonable estimate of the resources required to implement and administer the Pilot. The original cut-off date for participation in the pilot was in December of 2010 but was later extended to January 31st, 2011.

Educational institution eligibility has been an ongoing issue since the pilot’s implementation. Stakeholders have raised, and continue to raise issues around educational institution eligibility criteria. The January 31 cut-off date appeared arbitrary to stakeholders and was reported to have negatively affected institutions that may have applied for their EQA designation sooner had they been aware of BC and CIC’s plans to launch the pilot in January as well as the criteria required to participate. BC had made efforts prior to the Pilot’s announcement to inform institutions of the potential benefits of EQA designation. When initially establishing the EQA designation in BC, the Ministry of Advanced Education (the Ministry) identified and communicated the range of advantages and potential advantages for institutions in obtaining the EQA designation, one of which would be eligibility to participate in special programs offered by the federal and foreign governments. 

Some stakeholders have also raised the concern that access to the pilot gives some institutions an unfair market advantage merely because they received their EQA designation by a date chosen arbitrarily. However, the January 31st, 2011 cut-off date for participation in the pilot aligned with the start date of the pilot. Additional criteria over and above EQA designation could have been considered when initially designing the pilot project such as an institution’s history and experience dealing with international students, or an institution’s capacity to monitor and track student outcomes post-graduation.

Another issue that has been identified with respect to eligibility is that one eligible educational institution that was approved for the pilot does not currently offer any qualifying programs of eight months or longer. This institution was initially included in the pilot because it had already submitted a proposal to begin offering an eligible program. The program proposal is still under review by the Ministry. It is possible that their pilot eligibility may have resulted in confusion on behalf of both international students and CIC processing officers.

Further, eligibility of certain non-degree granting programs remains unclear. Currently, only “career training” programs within the participating institutions qualify for this pilot; general interest courses, or programs of study that consist primarily of English or French as a Second Language (ESL/EFL) are not eligible. There may, however, be other non-degree granting programs that do not further the objectives of the pilot. For example, some programs designed to prepare students for entrance into a College or University level programs are currently not clearly excluded under this pilot. As these programs do not train a student directly for a career, they may not be considered to be programs which contribute to the objectives of the pilot. 

5.0 Communications Between CIC and BC

The International Student Sub-Committee for the Canada-British Columbia Immigration Agreement has communicated and resolved a range of issues for BC and CIC, including the refusal of work permits for eligible international students under the Pilot. Other issues, including Pilot progress and compliance, have also been raised through this Committee. However, in the absence of explicit information sharing guidelines in the Pilot proposal, issues were not always efficiently communicated between BC and CIC. The importance of efficient communications, including better information sharing, between BC and CIC cannot be overstated. Efficient communications and efficient information sharing are crucial to supporting BC and CIC’s commitment to maintaining international student program integrity.

6.0 Coherence Between Pilot and Changes to the International Student Program

Since the negotiation of this pilot project over a year ago, new strategies and initiatives related to international education and the international student movement in Canada have begun to be developed at the federal level. CIC is currently reviewing its International Student Program with a view to strengthening program integrity and ensuring that Canada remains a destination of choice for international students seeking a quality education.

As work continues on this important initiative, it will be important to ensure alignment between the pilot and future policy directions at both federal and provincial levels regarding international students and immigration. The eventual outcome of this work may have an impact on the design of work permit programs for international students in the near future, as well as on the design and/or continuation of this pilot.

7.0 Conclusion

Overall, results from this first review of the pilot are mixed. There are many positive outcomes reported, but there are also a number of areas that could be strengthened in order to improve the pilot’s integrity and success.

Appendix A: List of Participating Institutions Between January 2011 and May 2012.

Appendix B: Post-Graduation Work Permit Pilot Project

Survey of Case Processing Centre- Vegreville and CIC Regional Office – British Columbia and Yukon Region

On January 31, 2010, CIC and BC launched a Pilot that expanded the post-graduation work permit program in BC for graduates of select private career colleges that had obtained BC’s Educational Quality Assurance (EQA) designation Per the Pilot guidelines, CIC and BC agreed to conduct an initial assessment at the ten-month mark. Results of the assessment will be used to determine future direction for the Pilot, including possibly extending it to additional schools that have received the EQA designation. For more information, please refer to OB262-B.

As part of the assessment, NHQ is conducting a survey of CIC staff to gather quantitative and qualitative feedback to determine whether the Pilot is meeting its objectives. Your participation is required in order to inform next steps for this Pilot. Responses will be anonymous and reported in aggregate only.

If you have any questions about this survey please contact Jessica Gallienne at Jessica.Gallienne@cic.gc.ca or Liban Issa at Liban.Issa@cic.gc.ca Please compile and scan the completed surveys of your region (single package) and send it to Liban.Issa@cic.gc.ca by November 7,2011.

1. What is your current role within CIC?

2. On a scale 1 to 4, how informed of British Columbia's Education Quality Assurance (EQA) designation were you before the launch of this Pilot?

3. On a scale of 1 to 4, how confident are you in BC's EQA designation as a reflection of the quality of an educational insitution?

4. On a scale of 1 to 5, how confident are you in the institutions approved by BC for this pilot? For a full list of currently approved schools, please refer to OB262-B.

5. On a scale of 1 to 5, what was the general level of quality of the work permit applications you received for this pilot?

6. On a scale of 1 to 5, what was the general rate of referral required to inland offices for further review for applications under the Pilot in comparison to the regular Post-Graduation Work Permit Program (i.e., concerns related to genuineness, document integrity, etc.)?

7. On a scale of 1 to 5, how prepared did you feel following the operational bulletin and/or communication provided by CIC NHQ regarding this Pilot and its implementation?

8. On a scale of 1 to 5, how often do you use the special program code for work permit applications under this Pilot (i.e., code “ISP”- International Student Program)?

9. What challenges or concerns have you experienced with this pilot?

10. Is there operational capacity in your office to handle additional volume from expansion of the Pilot to additional EQA-designated schools?

11. Additional Comments

Thank you for your participation in this important survey.

Appendix C: Post-Graduation Work Permit Program Pilot Project

Survey of Participating Institutions

As per the Pilot Guidelines, BC and Citizenship and Immigration Canada (CIC) committed to conduct an initial assessment of the pilot at the ten-month mark. Results of the assessment will be used to determine future directions for the pilot.

As part of the assessment, BC is conducting a survey of all participating institutions to gather quantitative and qualitative feedback to determine whether the pilot project is meeting its objectives. Your participation is required per the guidelines of the pilot. We appreciate your commitment to this process.

We ask that you identify the contact for the PGWPP Pilot (see page 4) and recommend that a senior official from your institution complete the survey. Please email the completed survey questionnaire by November 1^st, 2011 to David.K.Chow@gov.bc.ca.

1. On a scale of 1 to 5, does your institution support (approve of) the Post-Graduation Work Permit Program Pilot (PGWPP Pilot)?

2. On a scale of 1 to 5, what has been the level of interest among international students at your institution in applying for the post-graduation work permit after the completion of their program?

3. From January 31, 2011 to September 30, 2011, how many international students applied to career training programs of 8 months or longer?  How many applications did your institution receive over the same period last year (Jan 31, 2010 to Sept 30, 2010)?

4. What are some of the specific benefits your institution and international students have experienced since the PGWPP Pilot was launched?

5. What are some of the challenges and concerns that your institution and international students have experienced since the PGWPP Pilot was launched?

6. From January 31, 2011 to September 30, 2011, how many international students have graduated from your institution? 

7. On average, how many international students and domestic students graduate from your institution each year?

8. Is your institution currently tracking the number of students receiving the post-graduation work permit?

9. If known, from January 31st 2011 to September 30, 2011, how many international students from your institution have received the post-graduation work permit? If unknown, please indicate approximation.

10. Is your institution currently tracking whether international students who have received the post-graduation work permit are :

• Finding employment post-graduation?
• Finding employment related to the students’ field of study?

11. How prepared did staff at your institution felt in administering the duties under the pilot based on training and/or communication of guidelines from BC and CIC staff?

12. Other Comments

Institution’s Contact for PGWPP Pilot: (Name, Title)

Survey completed by:  (Name, Title)