46
As mentioned, the electronic nature of the system introduces complexities, and one challenge
with respect to ATIP is that no dedicated resources were identified for the system’s
implementation. Possibly as a consequence, interviewees involved in ATIP revealed that some
efficiency was lost because of the significant increase in page counts and volumes. As noted
above, trends with ATIP change over time; with respect to volumes, EE made up 11% of all
ATIP requests to the department in FY 2017–18. Another issue is that the system generates a new
set of client information each time a client updates their EE profile, which results in a large
increase in the page count (i.e., volume) of ATIP requests. It may be worth noting that three
quarters of ATIP requests enquire on the status of an application, and most of these requests are
placed when the Department does not meet the standard 6 month processing. Moreover there is
an inability to track incoming/outgoing correspondence and provide evidence of what is kept in
GCMS.
6.3.2. Flexibility
Finding: Express Entry has demonstrated flexibility as an application management system through its
ability to make adjustments quickly and to monitor the impact of these adjustments in a timely way.
As mentioned in section 1.2, IRPA provides the legislative authority for Canada’s immigration
program. IRPA contains various provisions that allow the Minister to issue MIs based on the
government’s overall immigration goals. With respect to EE, the Minister has issued MIs for EE
as an application management system,
30
and MIs respecting invitations to apply (ITA) for
permanent residency. MIs as a tool for EE were implemented in response to a desire to shorten
the interval between decisions that shift policy directions and the outcomes resulting from those
shifts. Prior to MIs, regulatory processes took longer to implement which resulted in having to
wait for many years to observe changes to the characteristics of economic PAs.
By virtue of having an "expression of interest system"
31
where candidates are assessed based on a
CRS that may change over time,
32
as well as the relative quickness of MIs, the impact of policy
and program changes can be observed and monitored quickly. For example, in November 2016,
IRCC was able to reduce CRS points assigned for valid offers of arranged employment from 600
points for all candidates to 200 points for candidates with valid offers of arranged employment in
National Occupational Classification occupations beginning with 00 (i.e., senior managers), and
to 50 points for candidates with valid offers of arranged employment in all other valid NOC
occupations. Subsequent to the reduction in job offer points, IRCC was able to see immediate
impacts on the NOC mix of invited candidates. Furthermore, there is some evidence that the
reduction in job offer points encouraged some candidates to present evidence of all of their
qualifications, as prior to this a job offer was a virtual guarantee of selection. Since EE was
implemented, adjustments are able to be made relatively quickly via MIs compared to when
regulatory changes were required.
30
EE Ministerial Instructions include: the economic immigration programs included in EE and associated eligibility criteria; the
electronic submission process a candidate must complete in order to submit an EE profile, and any associated exemptions; how
candidates will be ranked in the EE pool; information on invitation-to-apply draws; time limits for the maximum amount of time a
candidate can be in the EE pool, and if invited, how long they have to submit an application for permanent residence; candidate
information that can be shared with third parties including other government departments; and, how candidates will be notified
about any matter relating to their expression of interest.
31
In an "expression of interest" system, IRCC is able to choose which candidates from the EE pool will receive an invitation to
apply. In a "first-in-first-out" system, all applications are processed based on date of application.
32
For example, prospective applicants are assessed against existing CRS criteria, and if changes are made to the CRS, these
changes are retroactively applied to prospective applicants who are already in the pool.