An IRCC Audit Recommends Creating Clear Guidelines for Pilot Programs

Immigration, Refugees and Citizenship Canada (IRCC) released an internal memo on July 18, 2022, recommending implementing clear guidelines for the creation of pilot programs following an internal audit conducted by the Internal Audit and Accountability Branch of IRCC last March.

A total of 11 pilot programs have been established since April 2013. Of these, one program has become permanent, three are being transferred to permanent programs, three have been replaced by new programs or have been redesigned, and four have been active pilot programs.

In order for all programs to be established, Ministerial Instructions must be issued. In the Immigration and Refugee Protection Act (IRPA), a provision entitled Ministerial Instructions allows the Immigration Minister to issue special instructions to immigration officers in order to assist the government in achieving its immigration goals.

It was found that 27 key personnel, including senior management at IRCC, program employees, and external stakeholders at the Atlantic Canada Opportunity Agency, were interviewed during the audit process. Interviewees expressed concerns that the establishment and termination of pilot programs are often determined by the government’s urgent economic needs or shifting priorities, rather than by the desire to test innovative immigration approaches.

Results of the Audit

According to the audit, IRCC does not have a universal definition of what pilot programs are intended to achieve and how they are developed in terms of what they are meant to achieve and how they are developed.

It is not currently possible to determine whether a pilot program is worth developing based on a set of guidelines, as there is currently no such set of guidelines. There is a clause in IRPA that allows the immigration minister to issue ministerial instructions in order to create a more streamlined class of permanent residents so that the government’s economic immigration goals can be achieved. This clause allows for the establishment of pilot programs.

New economic class pilot programs are aimed at being temporary in nature, lasting up to five years, and can accommodate up to 2,750 applicants for each new economic class pilot program. In addition to that, there are no clear guiding principles as to how pilot programs should be designed. IRCC has a number of departments that evaluate the concept of the program, including senior management and stakeholders who have a say. The five-year timeline for some pilot programs hasn’t been met and some of them have not been made permanent.

Several other programs, including the Atlantic Immigration Program (AIP), have been found to be successful in their objectives of attracting and retaining skilled economic immigrants in the area or sector where they were intended to operate. It is highly likely that a program of this type will become permanent when it has such a high level of success.

A program’s success and the extent to which it is meeting the economic needs of the country are difficult to measure without guidelines in place.

As a result of the audit, it was discovered that there is no consolidated list within IRCC that tracks key pilot program recommendations or metrics, which means that it is virtually impossible to determine if a program is over-funded or under-funded, the key risks to the program, or the performance results for the program.

The interviewees felt that the perceptions of pilot programs weren’t accurate and that they needed to be adjusted

It was evident from the interviews that there was a perception that pilot programs overlapped with existing pathways to permanent residency, which has been raised by the interview participants. According to the audit, there is confusion surrounding the overlapping criteria of some Provincial Nominee Programs (PNPs) and the Start-Up Visa Programs (SUVs), which began as pilot programs in the past few years. There are different streams within the PNP that are geared toward entrepreneurs. In spite of the fact that the SUV was designed in an effort to attract innovative tech start-up businesses, there is still overlap in the occupations that are eligible for the program.

The audit also found that while pilot programs are perceived to require additional funding and more human capacity, most pilot programs remain unfunded, despite the fact that they are perceived to require additional funding and more human capacity. However, even though the AIP was one of the most successful pilot programs, it received no additional funding. Instead, it relied solely on existing departmental resources, which increased the strain and workload on department employees. Pilot programs have been found to be ineffective in terms of cost-effectiveness.

The implementation deadline for pilot programs tends to be shorter than other programs in order to meet the emerging economic needs of the country. As a result, there is a greater requirement for communication and coordination with outside stakeholders while programs are being developed. It also means that more resources and staff are required in order to successfully establish programs. Furthermore, more resources and staff are required.

A report by the auditing firm stated that no analysis had been conducted to measure the impact of the programs on the department’s ability to deliver core programs. As a result, the departmental staff cannot be expected to carry out their normal day-to-day tasks in addition to the pilot program in an adequate manner. The training was found to be inconsistent and there was not necessarily a quality assurance review. Consequently, it becomes difficult for the department to determine how it manages its workload in such circumstances.

Insights and Recommendations

It was recommended in the audit that guiding principles should be established in order to improve the monitoring, analyzing risks, and measuring the impact of pilot programs. It was noted in the report that this is particularly pertinent as IRCC continues to be burdened with increasing demands.

In the last few months, the department has exceeded its annual admissions target for permanent residents for 2022, and by 2025, it hopes to welcome up to 500,000 new Canadian citizens each year. It is expected that 14,750 of these people will be admitted to Canada under the economic class pilot program, while 14,500 and 6,000 will be admitted by the Atlantic Immigration Program and the Start-Up Visa programs respectively by 2025. The Atlantic Immigration Program and the Start-Up Visa program both began as pilot programs, but have now become permanent economic immigration pathways for the future.

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