QUESTIONS FOR IRCC
i. Can IRCC provide specific criteria to DLIs regarding the letters of support (for PGWP application) for current international students who experience changes to their study plans as a result of COVID-19; that is, will a general letter outlining an institution’s actions in this time suffice? Or does each student need a personal letter outlining how COVID-19 impacted their individual study plan and how this new plan was supported by the institution?
Due to travel restrictions, IRCC acknowledges that students may be unable to travel to Canada and wish to start their program through online/distance learning in their home country. These instructions apply for the cohort starting their program of study in May/June 2020. Students will remain eligible for the post-graduation work permit if:
· At least 50% of their program of study must be completed within Canada. This means that there is an expectation that the student will travel back to Canada within a reasonable time after the travel restrictions have been lifted.
If the above requirement is met, the duration of time spent in distance learning abroadwill not be excluded from the time accumulated toward the length of the post-graduation work permit.
2. Online learning/alternate program delivery methods and study permit/PGWP eligibility
There are several scenarios for current/prospective international students potentially pursuing online studies. Clear policy direction is required on these matters.
International students currently in Canada who are now pursuing studies online. [Note: IRCC has confirmed this will not affect PGWP eligibility. Is there/will there be a time limit for this exemption?]
Current facilitation extends to students whose study permits were approved prior to March 18, 2020, either currently studying or beginning studies in May or June 2020.
International students who have been studying in Canada for a period of time on a study permit, and may want or need to return to their home countries during the COVID-19 pandemic situation for an undefined period before returning to continue their studies in Canada (e.g. pause in studies and/or continuation online from home country).
Facilitation would also extend to students currently enrolled,who are outside of Canada, and pursuing their studies through distance learning from abroad. For these students, their eligibility for the Post-Graduation Work Permit (PGWP) Program won’t be affectedprovided they complete at least 50% of their program from inside Canada. The duration of time spent in distance learning abroad while the travel restrictions are in place will not be excluded from the time accumulated toward the length of the post-graduation work permit.
International students that may or may not have been approved for study permits already, but have received a letter of acceptance from a Canadian post-secondary institution (DLI) and wish to begin studies online.
For those who begin studying online but who don’t have either a study permit or approval on their study permit application, those online studies will not count towards their eligibility for a post-graduation work permit.
Without lived experience from within Canada, students will not be eligible for the Post-Graduation Work Permit Program, which recognizes that international students’ experience in Canada is essential to facilitating their integration within the Canadian labour market.
ii. What is the current thinking on how online learning could impact study permit and PGWP eligibility and conditions? For instance, if an international student enrolled and began a program online from their home country, could they be eligible for a PGWP? Would these students need study permits approved in order to begin studies, even if not currently studying in Canada?
Students continue to require a study permit to be eligible for student-related benefits.
Study Permits are the Department’s means of not only establishing a foreign national’s eligibility and admissibility to Canada for the purpose of studies, but also to monitor compliance and evaluate one’s eligibility for student-related benefits (i.e. PGWP).
IRCC is continuing to assess the requirements associated with the International Student Program and the Post-Graduation Work Permit Program as the situation with respect to COVID-19 evolves
iii. What input from PTs would be helpful in determining a comprehensive policy position? Is there scope for different approaches among PTs?What is your timeline for making a determination on this issue?
IRCC provided a preliminary list of questions for ministries of education input on April 22, in order to inform ongoing policy development. IRCC looks forward to receiving responses to these questions and our ongoing dialogue as we work through our shared challenges.
Creating PT-specific approaches could be considered, for instance if consideration were given to facilitative measures that respond to PT-identified priorities related to programs of study linked to labour market needs However, further discussion would be required to assess the viability of such an approach.
IRCC is currently working on solutions for the fall intake and will continue to provide information as it becomes available.
iv. Many BC institutions are turning to Duolingo as a language testing tool. Will IRCC consider allowing Duolingo assessments for study permits and SDS applications (even just as a temporary/pilot measure).
There are many service disruptions and closures which are currently impacting the International Student Program. Our focus at this time is on critical services and travel restrictions in place for all international students who are approved for study permits after March 18. Expedited processing, such as that enabled by the Student Direct Stream,is not currently a priority for the Department. IRCC is developing guidance regarding the Student Direct Stream that will be shared once it is available
3. Port of Entry Letters
i. Can IRCC provide instructions for students who have Port of Entry Letters of Introduction that expire either because of COVID-19 travel restrictions or an unwillingness to travel during this uncertain time; will future study permit applications be impacted?
Foreign nationals who received a positive decision letter (letter of introduction) that may expire because they are unable or unwilling to travel to Canada must notify IRCC using the web form.
ii. Can IRCC provide instructions to students who do not receive a Port of Entry Letter of Introduction when they can enter Canada and when their ability to do so expires?
Unless you are an international student who has a valid study permit,or were approved for a study permit (and received your letter of introduction) on or before March 18, 2020,you cannot travel to Canada at this time.
iii. Can IRCC clarify what documents will be required for students entering Canada: are expired LOAs and ‘old’ POE Letters of Introduction acceptable (if students enter mid-program after starting online)? Will students need new confirmation of enrolment letters from DLIs? Will the length of study permits be reduced, if students have completed some of their program online back home?
Expired LOIs will not be accepted in order to enter Canada. Foreign nationals who received a positive decision letter (letter of introduction) on their study permit application, and whose letter is about to expire within a month, but who are unable or unwilling to travel to Canada must notify IRCC using the web form.
IRCC is assessing the impact ofexpired LOAs and how the length of study permits will be affected if students have completed some of their program online from abroad.
4. Self-quarantine logistics and practicalities for new students
ii. Will CBSA be providing clear instructions to newly arrived study-permit holders on what is expected in 14-day isolation? Does IRCC/GAC have advice as to where newly arrived study-permit holders should self-isolate: at POE or at final destination?
The Public Health Agency of Canada (PHAC) has provided guidelines on-line for travellers, and a list of requirements for those arriving by air or by land. This information is available here.
5. ISP Compliance Reporting and other data
Some institutions may need to close operations permanently as a result of impacts from the COVID-19 pandemic.In these cases, we will need to determine how best to transition students (including international students) to new institutions, and/or facilitate tuition refunds, etc.
Students holding valid study permits are able to transition to new schoolswithout applying for a new permit, however, they are required to contact IRCC andinform us of the new DLI they are attendingto ensure that IRCC is able to continue monitoring compliance with the conditions of their study permit.
iv. Is IRCC able to provide detailed data to PTs, broken down by institution (DLI), as per most recent ISP Compliance Reporting period (Fall 2019) as per usual process? This information will assist us to support students during any transitions and/or closures.
This data was shared on April 9, 2020.
v. Will compliance reporting requirements of this reporting cycle be postponed?
As announced during our April 9, 2020 call, the compliance reporting period has been extended to May 31, 2020.