Authorization to work without a work permit: Health care students [R186(p)]

This section contains policy, procedures and guidance used by Immigration, Refugees and Citizenship Canada staff. It is posted on the Department’s website as a courtesy to stakeholders.

Paragraph 186(p) of the Immigration and Refugee Protection Regulations authorizes foreign nationals to work without a work permit if they are foreign students in a health field whose proposed work in Canada is for the primary purpose of acquiring training for a limited period of time. This includes work dealing directly with patients, such as work as part of a medical elective program of study or work in a support role in a health care environment (like as a clinical clerk at a medical teaching institution in Canada). Where necessary, these students must provide a form of written approval from the body in Canada that regulates that field in order to ensure that Canadian and permanent resident health care students are placed for clinical practice first.

On this page

Eligibility considerations

Health care fields include the following:

  • medicine (including dental)
  • occupational and physical therapy
  • medical technology
  • nursing
  • other professions in human health care that are regulated by provincial or territorial governments

Note: Work not directly related to human health care (that of veterinarians, sociologists, etc.) is not covered by this regulation.

There is no requirement for wages to be paid. However, where the position is unpaid or of minimal recompense, foreign students must demonstrate that they have the means to support themselves while in Canada.

Foreign nationals entering under paragraph R186(p) must still be registered students, and it is expected that they will be returning to their home country to complete their studies after the training period. Therefore, it is expected that the work permit exemption training period will last about one term (that is, about four months).

The primary purpose of the work must be to acquire training in a field related to the foreign national’s studies, not to conduct research. Non-research training in a health research facility (such as a laboratory) is permitted.

Medical teaching institutions are identified in the regulation as employers for medical students under paragraph R186(p). However, workplaces such as private clinics are also permitted if they are providing human health care training.

Note: Foreign medical residents and medical fellows coming to work temporarily in Canadian clinical settings or research facilities for long-term (typically longer than four months) paid training or to conduct research are not work permit-exempt under this regulation. However, they may qualify for a Labour Market Impact Assessment exemption under Public policy, competitiveness and economy (exemption code C45).

Documentation requirements

The onus is on foreign nationals to provide evidence to the border services officer upon entry to Canada that they meet the requirements to perform the work being sought. Documentary evidence includes the following:

  • proof from the health care student’s home educational institution stating that the student is completing a clinical clerkship or short-term practicum that forms part of their educational program (the letter should include the expected duration of clerkship or practicum)
  • a letter of no objection from the body that regulates the particular health care field (note: specific provincial or territorial colleges of physicians and surgeons requirements for medical students are described below)
  • a letter or email from the Canadian medical institution confirming the student’s acceptance for the period of training

Those who are temporary resident visa (TRV)-exempt are encouraged to seek a facilitation letter (see note below) from the visa office stating that the applicant has completed an immigration medical examination with a designated panel physician, and the results can be accessed under the unique client identifier (UCI) provided in the letter. If foreign nationals can’t obtain a letter, they can provide proof that they completed their medical examination to the border services officer.

Required medical examination

For guidance on medical requirements, please consult Immigration medical examination: Healthcare students who are work permit-exempt.

Role of the Canadian POE

The final decision to allow entry into Canada rests with Canadian border services officers. TRV-exempt students should be prepared to present all necessary documents at the POE to support their reason for entry to Canada, including evidence of having passed the immigration medical examination and other required documentation.

Note: If the foreign national is required to report for medical surveillance, the “Medical Surveillance Undertaking” form [IMM 0535] must be part of the other required documents.

No objection from provincial and territorial colleges of physicians and surgeons

Through consultations, provincial and territorial colleges of physicians and surgeons have identified distinct requirements related to work performed by foreign national health care students. Border services officers should consult the requirements below and, according to the stated province or territory of destination, ensure that the health care student demonstrates that the requirements have been met.

Ontario does not require a letter from the college of physicians and surgeons.

The College of Physicians and Surgeons of Ontario has informed Immigration, Refugees and Citizenship Canada (IRCC) that it does not need to be involved in individual applications and that it does not object to foreign health students working in medical teaching institutions in Ontario. This non-involvement can be interpreted as approval from the regulatory body for visa officers to process applications without written approval for each one.

British Columbia does not require a letter from the college of physicians and surgeons. A letter of acceptance from a university in British Columbia suffices.

The College of Physicians and Surgeons of British Columbia has advised IRCC that it licenses all foreign medical students who arrive under paragraph R186(p) for short-term practicums, whether they are at the undergraduate or postgraduate level. The college and the universities have special procedures in place that are strictly adhered to. Acceptance by the university is, thus, sufficient proof that the college has given approval.

Alberta does not require a letter from the college of physicians and surgeons. A letter of acceptance from a university in Alberta suffices.

The College of Physicians & Surgeons of Alberta has advised that it treats undergraduate medical students doing electives in Alberta the same way it treats out-of-province undergraduates. They must first register with the undergraduate elective office at either the University of Alberta or the University of Calgary, which then provides applicants with all the information the university requires and also provides them with the college's undergraduate elective application for registration.

The entire process is handled through the university, which then notifies the College of Physicians & Surgeons of Alberta to finalize the registration. In essence, proof of acceptance by a university in Alberta (Edmonton or Calgary) is sufficient evidence of approval by the regulatory body, that is, the College of Physicians & Surgeons of Alberta.

Quebec requires a letter from the college of physicians and surgeons.

The Collège des médecins du Québec has advised that a foreign student coming to Canada for a short clinical internship must obtain a “lettre d'admissibilité” (admissibility letter) from the Collège des médecins du Québec. The issuance of a letter from a university is not sufficient to authorize the student to perform a short internship. Medical students coming to Canada for observation or research internships are not required to obtain this admissibility letter.

Saskatchewan does not require a letter from the college of physicians and surgeons. A letter of acceptance from a university in Saskatchewan suffices.

For other provinces and territories, if the college of physicians and surgeons for the province or territory has not provided the student with written approval, the visa office should contact the Immigration Program Guidance Branch for assistance in determining whether the province or territory has elected to be involved in health care student practicums for international students.

Date Modified: