Ontario Colleges’ Response to IRCC’s DLI Amendments
Date: July 25, 2024
Regarding: Canada Gazette, Part I, Volume 158, Number 26: Regulations Amending the Immigration and Refugee Protection Regulations (Designated Learning Institutions)
Overview
Colleges Ontario, the association representing the province’s 24 public colleges, has issued a detailed response to IRCC’s proposed amendments to the regulations governing Designated Learning Institutions (DLIs). This response underscores the critical role Ontario colleges play in supporting international students and their substantial economic contributions, while also addressing concerns about potential overlaps and jurisdictional issues in the proposed amendments.
Key Points and Recommendations
Economic and Educational Impact
International students are a vital part of Canada’s economy, contributing over $37 billion annually. Ontario’s public colleges are instrumental in this, with many international students choosing to remain in Canada post-graduation to fill essential roles in various sectors, such as healthcare, engineering, and hospitality. These students help alleviate critical labor shortages, making their presence invaluable.
Commitment to Quality and Integrity
Ontario’s public colleges have set a national standard for quality and integrity in international education. This commitment is evident through the implementation of the International Education Standards of Practice, which include:
- Accurate Marketing and Promotion: Ensuring transparent communication about programs.
- Agent Oversight: Requiring education agents to complete college-endorsed training and terminating contracts with agents involved in fraud.
- Comprehensive Student Orientation: Providing information on housing, mental health, academic support, employment opportunities, and community integration.
- Targeted Student Services: Offering academic support, medical insurance, and access to health services.
- Post-Graduate Support: Helping graduates who wish to stay in Canada with employment opportunities, alumni networks, and immigration pathways.
The Ontario College Quality Assurance Service (OCQAS), an internationally recognized quality-assurance agency, oversees the program quality, ensuring that colleges meet provincial standards and regularly auditing their practices.
Concerns Over New Regulations
Jurisdictional Overlap: The proposed IRCC regulations could duplicate existing provincial oversight mechanisms, particularly the role of the Ontario Ministry of Colleges and Universities (MCU) in regulating DLIs. This overlap could create confusion and inefficiencies.
Administrative Burden: Additional reporting requirements proposed by IRCC might impose unnecessary administrative burdens on colleges without providing additional value to students. Colleges Ontario emphasizes the need for streamlined processes to avoid redundancies.
Transfer Student Policies: The proposed regulations regarding transfer students could place them in precarious situations while awaiting new study permits. The lack of clarity on the consequences if a new study permit is not issued adds to the uncertainty for both students and institutions.
Specific Feedback
Conditions on DLIs: Ontario colleges recommend a response time of 10-15 business days for compliance requests. It is crucial to avoid duplicative reporting with provincial requirements to ensure efficiency and clarity.
DLI Suspension List: The decision-making process regarding DLI eligibility should respect provincial jurisdiction. IRCC should work closely with provinces through existing Memoranda of Understanding (MOUs) to implement regulatory changes that do not impose unnecessary burdens on institutions.
Transfer Students: Clear guidelines are needed on handling institutional transfers to avoid undue complexity and ensure consistent application across all DLIs.
Conclusion
Colleges Ontario calls on IRCC to collaborate with provincial authorities through the established MOUs to refine the International Student Program (ISP) regulations. This collaborative approach will ensure that the regulations respect provincial jurisdiction and do not add unnecessary administrative burdens to institutions. Ontario’s public colleges are dedicated to maintaining the integrity and success of the ISP and look forward to further engagement with IRCC.
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