Evaluation of Ministerial Instructions (Implementation)
4. Conclusions and recommendations
This chapter of the report focuses on the major conclusions of the study, and offers suggestions for areas, that continue under MI2 and centralized processing, where further investigation is warranted.
1. There is a continued need for CIC to be able to manage the intake and processing of immigration applications in a timely, efficient and responsive manner.
The legislative amendments included in the 2008 Budget Bill (C-50) allow the Minister to make changes to the way in which immigration applications are processed in order to be more responsive to changing external conditions. The fact that, when limitations to MI1 were identified, the Minister was able to issue a second set of Instructions, that have had better results, supports this conclusion. Further, many of the conditions that precipitated the implementation of MI — high numbers of immigration applications, growing backlogs and slow processing times — are still concerns in CIC immigration programs.
2. The design of MI is both flexible and responsive, which is the key to its success as a policy tool.
The MI authorities not only gave the Minister the power to limit the number of applications processed and to accelerate some applications or groups of applications, they gave him the authority to return applications without processing them to a decision if they do not meet the requirements of the Ministerial Instructions.
Moreover, the language of the legislation makes it relatively easy to initiate new Ministerial Instructions to meet the emerging immigration needs of the country, or, as it happens, to rectify problems with earlier instructions. When the department discovered that MI1 was not controlling intake, the minister was able to quickly authorize new instructions that have controlled intake, without the time-consuming and arduous process of crafting and passing new legislation.
3. Although the number of applications received under MI1 was initially quite low, it rose fairly quickly to pre-MI1 levels. However, the data systems established as part of MI1 allowed for the early identification of problems, and led to MI2, which has been much more successful in reducing the intake of applications.
The department established excellent monitoring systems in support of the implementation of the first set of Ministerial Instructions. This allowed them to quickly identify the escalating number of applications under MI1, and to identify the main reasons for the problem. This enabled CIC to design the new instructions to overcome these problems. Key provisions in MI2 — particularly the overall cap and sub-caps, the language requirement, and the removal of problematic NOCs — have been successful in controlling intake.
4. While MI2 has been more successful than MI1 in limiting applications, the transfer of the eligibility decision to the CIO under MI2 was viewed as potentially problematic, particularly by staff in the missions. The scope of this evaluation did not allow for an assessment of the impact of this change.
Although most key informants asserted that MI2 is superior to MI1 in almost every respect, there were some concerns regarding the transfer of the final eligibility decision from the missions to the CIO. This was primarily due to the fact that CIO staff do not have the local knowledge necessary to detect misrepresentation in applications, which will increase the risk of fraud. Allowing missions to reverse positive eligibility decisions is one way in which this issue could be addressed; providing additional mission-specific training to staff at the CIO could also contribute to alleviating concerns.
Recommendation 1: CIC should conduct a more formal assessment of the impact of further centralization of the processes historically undertaken in missions. Specifically, this assessment should examine the risks associated with centralizing decision-making, particularly in relation to the potential of not detecting fraud. This study should also include the identification of mitigation strategies, as required.
5. The implementation of MI1 contributed to a substantial reduction in the backlog, although there was a subsequent, and unanticipated, development of an MI1 backlog.
The government set the goal of reducing the FSW application backlog by 50% by 2013 and actually achieved this goal by April 2011. However, because MI1 did not ultimately reduce the volume of applications being received, a substantial backlog of MI1 applications accumulated during this time. The inclusion of the MI1 backlog in this assessment reduces the overall reduction of backlog to 23%.
While the overall backlog is decreasing and is expected to continue decreasing, a ministerial directive stipulated that MI2 applications be processed before those submitted under MI1, and MI1 files be processed before addressing the pre-existing backlog. This means that the time required for a final decision for the group in the pre-C50 backlog — almost 300,000 persons — will likely increase by several years.
6. While it was not possible to conclude that CIC costs were reduced as a result of centralizing the front-end processing of FSW applications, the CIO did achieve a number of objectives that contribute to improving the efficiency of the overall process.
In order to conduct a proper cost-effectiveness analysis of a program or initiative, it is necessary to have very detailed cost data related to the activities under study, and a baseline against which to compare current costs. While CIC has a well-established activity-based costing model, the data related to processing overseas applications was not sufficiently detailed to support an analysis of these costs before and following the introduction of MI.
Recommendation 2: As part of its overall approach to program performance measurement, CIC should ensure that there is financial data that is sufficiently robust and detailed to support the on-going analysis, and periodic evaluation, of program costs.
Although it was not possible to assess cost-effectiveness, the evaluation did find that centralization has reduced the time required to process applications, improved the consistency of the implementation of MI, and on-going decision-making and record-keeping, and reduced the clerical workload in missions. These impacts, by improving performance or reducing the resources required to process applications, contribute to the efficiency of the overall process.
The research for the evaluation identified a number of findings that were not, by themselves, sufficient to support a recommendation, but were suggestive of particular actions or further considerations by the department. These are presented below.
Recommendation 3: The department should consider each of the following observations, investigate further, as required, and decide on how best to proceed:
Communications
CIC should permit and facilitate direct communications between missions and the CIO. The implementation of a feedback loop could help to identify any systematic errors and improve decision-making. Lessons learned through interaction with individual missions should be shared across the network.
Electronic application
The department should expedite the move to an e-application for the FSW Program, particularly now that GCMS has been fully implemented.
Fee payment
The electronic application platform should facilitate fee payment through such means as PayPal, etc. Also, consideration should be given to charging a fee for processing applications that are determined to be ineligible. This will help to cover some of the associated costs and deter applicants who know they are unlikely to be successful.
CIO pilot status
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