Usual insightful analysis by Alex Usher on the planned changes to study permits announced by Minister Miller, particularly the risks associated with rating education institutions and "calibrating" the PGWP in line with labour market needs, given lack of IRCC expertise in these areas, not to mention the operational challenges:
Last Friday's, Marc Miller, the Minister of Immigration, Refugees and Canadian Citizenship (IRCC), announced three changes to the International Student Visa program (link here). You may have seen a small news alert about it (see here or here). But it seems that almost nobody caught the full import of the announcement.
The announcement started out ok, with Miller again swatting down rumours of a cap on international student visas and comparing the idea to "performing surgery with a hammer". Miller then announced – or re-announced, or semi-announced, depending on your point of view – three things.
First, starting December 1, 2023, every designated learning institution (DLI) will be required to confirm every applicant's letter of acceptance directly with IRCC. This is good. It's what pretty much every other country in the international student business has been doing for a couple of decades, and the only reason we haven't done it before is Ottawa's catastrophic inability to undertake IT projects (plus, you know, sheer bureaucratic inertia). Assuming they can launch on time – and I wouldn't bet the farm on it – top marks, 10/10
Second, the Government re-iterated its desire to launch its deeply under-theorized plan to rank and rate institutions, whose utter incoherence I outlined back here. The difference is that they've changed the language from "trusted institutions" to "recognized institutions" and the implementation date has been moved back to next fall, which gives us all a few extra months to convince the feds that this idea remains infeasible.
So far, so boring. But pay attention: the third element is a big one. I'll quote it verbatim, while adding emphasis where appropriate:
In the coming months, IRCC will complete an assessment of Post-Graduation Work Permit (PGWP) Program criteria and begin introducing reforms to better calibrate it to meet the needs of the Canadian labour market, as well as regional and Francophone immigration goals.
Well, now. Let's think about how this might work.
"Calibrating" the PGWP program with the labour market would require two things. First, it requires IRCC to decide what skills the labour market "needs" (or, more formally, which occupations will be "in demand" over the coming years. The feds sort of have this through ESDC's Canadian Occupational Projection System (COPS), although its worth remembering that this system has its limitations (remember when the system claimed that "university professors" was an occupation facing imminent shortages? Good times.) And of course, COPS was just one way of determining future skills shortages: other methodologies, like the one developed by the former Brookfield Institute (now TMU/Dais) can provide quite different answers.
But that's not really the hard part here. We have a lot of different projection systems, but the government of Canada has never used any for the purpose of policy implementation. In this case, the government would basically have to have enough faith in whatever methodology they pick to say "yes" or "no" to individuals or institutions over something as important as who gets into the country and who does not. It can model itself on some other countries – Australia's National Skills Commission maintains a list of in-demand skills for immigration and education purposes,– but it's a fundamentally new role for this ministry – or indeed anyone in the federal government. I have my doubts it will go smoothly. No, the hard part is working out how exactly to link labour market information to the PGWP program. And I am pretty sure it is going to be something along the lines of "occupation X, meet program Y": that is, PGWP will only be available for specific programs of study.
This ought to be…interesting.
I mean, the feds' logic is clear. What they really want to do is strike hard at rural/small-town Ontario colleges offering loads of "Global Business" diplomas through PPP arrangements with private colleges in the GTA. since the areas near these schools are the epicentre of the housing shortage that's currently affecting southern Ontario and tanking Liberal re-election projects. Nobody thinks the diplomas actually have much educational or social value – and the public perception of them is that they are a backdoor route to immigration (personally, I disagree, I think they are a front-door to immigration, but a back-door to a Temporary Foreign Worker Program, but that's as may be). So why not use federal immigration rules to wipe them out?
Well, for one, it's not 100% clear how the Government intends to link data on occupations to data on programs in a way which is defensible. At the more technical end of the spectrum, occupations and programs line-up reasonably well, but in humanities, social sciences, business and indeed a lot of the biological sciences, the line from program to employment is a lot looser, and it's not clear how a crosswalk can be driven. So, while it should be easy enough to "prove" that Global Business doesn't have many direct routes to the labour market, it's not obvious (to me at least) how you can do that in a way that doesn't sideswipe every faculty of arts and business in the country.
In brief, I foresee both a titanic amount of lobbying around what kinds of methodology will be used to determine "in-demand" skills and a titanic amount of chicanery as institutions re-classify their programming to meet whatever rules and standards the government eventually chooses to set for the PGWP program. In fact, I think you can guarantee that as of Friday, these two items right now are at the top of the to-do list of every non-GTA college in Ontario, because these new rules have the potential to disrupt their largest income source and drive them to the wall, financially.
And remember, all of this potential change and financial consequences is being driven by the feds, not the provinces. Specifically, it's being driven by the freaking Ministry of Immigration, whose understanding of the higher education system might charitably be described as "diddly-squat". And yet, despite this lack of institutional expertise, right now Marc Miller is the closest thing Canada has ever had to a National Minister of Higher Education. Through his unworkable ranking system, he's claiming the right to distinguish "good" from "bad" institutions, and through the PGWP revisions he's claiming the power of life and death over hundreds – maybe thousands – of university and college programs across the country. It's both unprecedented and absurd.
Provinces only have themselves to blame for this: whatever power over higher education the feds now have exists because of the provincial cheeseparing that drove institutions to seek international students in the first place. No international student boom, no terrifying leverage placed in IRCC's hands.
What a country.
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