Internal IRCC audit recommends the creation of clear guidelines for Pilot Programs

An internal memo from (IRCC) on July 18, 2022, recommends the implementation of clear guidelines for the establishment of pilot programs following an internal audit conducted last March by the Internal Audit and Accountability Branch of IRCC.

There have been 11 pilot programs established since April 2013. Of these programs, one has been made permanent, three are being transferred to permanent programs, three have been replaced or redesigned and four are active pilots.

All programs are established through Ministerial Instructions. Ministerial Instructions are a provision within the Immigration and Refugees Protection Act (IRPA) that allows the to issue special instructions to immigration officers that will help the government reach its immigration goals.

The audit included interviews with 27 key personnel including IRCC senior management, program employees and external stakeholders from the Atlantic Canada Opportunities Agency. Some interviewees expressed concern that the creation, or termination, of pilot programs is often determined by an urgent economic need or the shifting priorities of the government, rather than as programs to test innovative approaches to immigration.

Audit findings

The audit found that IRCC does not have a universal definition of pilot programs in terms of what they are meant to achieve and how they are developed.

As it currently stands, there is no set of guidelines that decides if a pilot program is worth developing. The establishment of pilot programs is only possible through a clause in IRPA that allows the immigration minister to issue ministerial instructions creating a new class of permanent residents that will support the government's economic immigration goals.

IRPA states that pilot programs are meant to be temporary in nature, up to five years, and can invite up to 2,750 applicants per new economic class pilot. Beyond that, there are no real guiding principles for the creation of pilot programs. The program concept is evaluated by several branches of IRCC, including senior management and relevant stakeholders.

Some pilot programs were not made permanent after the five-year timeline. Others, such as the (AIP), were found to be successful in their objectives of attracting and retaining skilled economic immigrants in the area or sector the program was designed for. When a program has this type of success, it is highly likely to become permanent.

However, without guidelines, it becomes difficult to measure a program’s success and if it is meeting Canada’s economic needs.

It was discovered through the audit that there is no consolidated list within IRCC that tracks key pilot program recommendations or metrics. This means there is no way of knowing if a program is over or underfunded, the key risks or performance results.

Interviewees feel that perceptions of pilot programs are not accurate

Throughout the interviews, there were concerns raised that there is a perception of overlap between pilot programs and existing pathways to permanent residency. For example, the audit cites the confusion surrounding overlapping criteria of some (PNP) streams and the (SUV), which began as a pilot program. There are multiple PNP streams designed for entrepreneurs and while the SUV was created with the intent of attracting innovative tech startup businesses, there is still overlap in the eligible occupations.an

The audit also found that while pilot programs are perceived to require additional funding and more human capacity, most pilot programs go unfunded. The AIP, one of the most successful pilot programs, did not receive any additional funding and instead relied solely on the existing departmental capacity, increasing the strain and workload of department employees. It was found there is no true costing of pilot programs.

Additionally, the deadline to implement pilot programs tends to be shorter than other programs to meet emerging economic needs. This means that while programs are being developed, there are more resources and staff needed to successfully establish the program, as well as an increased need for communication and coordination with outside stakeholders.

The audit said there was no analysis of the programs to measure their impact on the department's ability in terms of administering core programs. This means there is no way to tell how well departmental staff can complete their normal, daily tasks in addition to the pilot program. Training was found to be inconsistent and there was not necessarily a quality assurance review. Under these circumstances, it becomes difficult to get a clear picture of how the department manages its workload.

Recommendations

The audit recommends the establishment of guiding principles to better monitor, create risk analysis, and measure the impact of pilot programs. The report mentions this is especially important as the demands on IRCC continue to grow.

The department recently surpassed its yearly target of permanent resident admissions for 2022 and to Canada each year by 2025. Of these, 14,750 are expected to be admitted to Canada under economic class pilot programs. The Atlantic Immigration Program and the Start-Up Visa program will target14,500 and 6,000 respectively by 2025. Both programs began as pilot programs and are now permanent economic immigration pathways.