CIP 185 - Episode 6 - Who gets in who gets locked out
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[00:00:00] If you've been watching any express entry coverage this month, you've heard the merger described the same way over and over. Three programs becoming one. Finally, some simplicity, easier to understand. And that's true, but here's what almost no one is adding. When you take three doors built to three different heights, replace them with one door, you have to pick a single height.
Somebody's door just got lower. Somebody else's just got higher. The simplification headline is real. The redistribution underneath it is the part that decides whether this helps you or hurts you. And that is what we're going to talk about today Yeah. What I want everybody to think about is that simpler is a relative term measured against the old system, and it's not a promise for what your odds are in the future under the new program.
So for example, I've got clients right [00:01:00] now who clear the trades eligibility under Federal Skilled Trades category, but they may not clear it when we have one program. Same person, same skills, same value to Canada, but now the merged door is going to be maybe inaccessible for them. Similar, I've got PhD students who thought they'd qualify for Express Entry, but now they may not because their work experience is older than three years old.
So before anybody celebrates all the sim-simplicity, let's find out which door you're standing in and whether you're still going to be able to open that door under the new program. Absolutely fair enough. Okay. So let's cover a little bit of history here. ~Um, ~and I think most of the coverage kind of skips through this.
The three programs are actually older than Express Entry itself. I remember, Alicia, back in twenty-fourteen when we saw the first notifications about this new program coming, this expression of interest, and they [00:02:00] had different terminology they were using. But really, it's something that was fashioned after what was originally piloted and implemented in Australia and New Zealand at the time.
And so when this came through, ~um,~ they were trying to solve this problem. So previously, each of these three programs were built in a first-come, first-serve era. So each one was, was designed specifically to catch a different population: the Federal Skilled Worker Program for skilled workers applying from abroad, the Canadian Experience Class to retain people already working in Canada, and the Federal Skilled Trades Program for tradespeople whose skills don't fit a degree-shaped box.
So three doors, three purposes. So then the brilliant plan, and, like, I don't fault them at all. Like, it made, it made sense, and it still does make sense. ~You know,~ but here's what Express Entry did. So in twenty fifteen when it was launched, it put a ranking system, the CRS, the Comprehensive Ranking System, in front of all three doors.
And here's the quiet shift. That changed everything. The program rules stopped [00:03:00] being the thing that decides who gets selected. They became the minimum to get into the pool. And then the CRS, of course, became the gatekeeper. So the three doors kept standing, but they were no longer doing the selecting.
They're just the way to get into the waiting room, I guess, if you want to use, ~uh,~ uh, an analogy. So now we ask, well, okay, why is IRCC pushing for this? What's their argument for actually moving to a merger? And I think generally it's pretty coherent, Alicia. ~You know,~ we steel man it before we push on it.
First, the doors overlap. In recent years, roughly half of all invitations went to people who qualified under at least two programs, so there's a lot of redundancy. And then second, the, the institution of categories-based selection, which arrived in about 2023, I think, ~um,~ well, then it started to put targets on specific occupations.
~You know,~ targeting physicians or French speakers or, ~you know,~ even trades to some extent were within those category-based draws. And now it has this precise [00:04:00] tool to do the actual selecting within side this pool and no longer needs three separate front doors to find a specific population that it's targeting.
And then third, the three rule books basically are confusing people. ~You know,~ people- normally, it was pretty straightforward to understand, am I eligible? Okay, I'm gonna get permanent residence. Well, routinely, ~you know,~ people would build profiles under the wrong programs, so they wouldn't understand, why am I not getting in the pool?
What is going on? What, what, ~you know,~ what am I entering improperly? Because at the front end, to get into the pool, there's no officer actually looking at it. It's ultimately just this algorithm, and based on what you insert, is gonna determine whether or not you meet the eligibility threshold, all designed for efficiency.
So the conclusion IRCC draws, and, ~you know,~ at the time and w- why they're moving forward, is, ~uh,~ the CRS and the categories do the real work, so the three doors are basically redundant. They're redundant complexity, so let's basically collapse them. So that's kind of [00:05:00] been what's driving the ship to, to a large extent.
And, ~um,~ if you look at, ~um You know, ~as far as these three, three, ~uh,~ the three doors here, ~um,~ the, the, excuse me, the why it matters, I guess, is it, it allows them to have more control over the intake of people. It allows them to really make sure that they're hitting the, the targets that they're actually trying to target.
And we're not just talking about numbers here. We're also talking about the occupations where they feel like there's gonna be demands. And so, ~you know,~ as- if we look at this legal vehicle, and I'll just jump one more slide ahead, the way for doing it, ~um,~ it's basically... Here's the piece to, to file away, okay?
Because it controls the entire timeline, ~you know,~ merging the programs changes who's eligible to enter the pool, and then that eligibility l- still lives in the regulations. Schedule One of the Immigration and Refugee Protection Regulations, ~uh,~ changing regulations means that the full Canada Gazette process has to come into place.
~Um, ~they have to publish the proposal. There's a mandatory public comment period, a [00:06:00] final published rule, and a coming-into-force date. So as you can see from our, our slide deck here, this whole process, we're likely not expecting to see too many changes on the regulatory front, at least the initiation of it, until probably the end of twenty twenty-six, like we've talked about in previous episodes, with maybe the full regulatory changes not happening until twenty-- the end of twenty twenty-seven or maybe even the start of twenty twenty-eight.
So it's a slow process, right? It, it, it, it's gonna take time for it to roll through, ~um,~ and we'll come back in segment seven and talk a little bit about this, but, ~um,~ the one reform in this whole series where the law guarantees you a formal chance to be heard is not gonna happen until later All right, let's shift slightly and let's just take a look at this single floor line by line.
Mm-hmm. And so this is where it does really matter when we're talking about minimum eligibility criteria. So we used to have three doors or three ways that you could meet [00:07:00] minimum eligibility criteria so that you can get into the pool of candidates so that you might have a chance at an invitation to apply.
Immigration is looking at collapsing those three doors down to a single door. There is only one way in. There is only one new set of minimum eligibility criteria, and it's really important to take a look at this carefully. So we've lined up here. We've got what the current Federal Skilled Worker Program is for minimum eligibility, current CEC, and current Federal Skilled Trades.
And then in the furthest right-hand column, we've got this new single program that's being proposed, and we're looking at different factors. So immigration has always said there's a few minimum things that you must have before you can even show that you're eligible, and we're looking at education, we're looking at language, work experience, a job offer, and the entry grid, which really only applied to the Federal Skilled Worker category.
So when we look at who's currently [00:08:00] eligible, what are the hurdles that you have to pass to even hit that minimum eligibility? Just like you were talking about, Mark, some people under Federal Skilled Worker just cannot figure out why they're not eligible, and it's because of that 67-point selection pass mark, right?
You're not only dealing with a CRS score later. For specifically the Federal Skilled Worker Program, there's this 67-point pass mark, and if you don't hit it, you do not qualify. So that's what's currently holding a lot of people back under the Federal Skilled Worker Program. You don't have the same thing for CEC.
You don't have the fa- same thing for Federal Skilled Trades 'cause they have different program eligibility requirements that are related to work experience. So that's where on CEC we know that you currently have to have one year Canadian work experience, high skilled within the last 10, and you can have different combined work experiences and different NOCs.
It doesn't have to be continuous, and you can use, ~um,~ different part-time jobs to add up to a full-time job over a period of time. For [00:09:00] Federal Skilled Trades, we know that tradespeople need to have two years of work experience. ~Um, ~so this is something that is more difficult to obtain, ~um,~ or they need to have a job offer with that ~Um, ~within the trades.
So these are the eligibility criteria that are currently existing. The big one, the really big one is language. And for most people who are currently eligible under a high tier for CEC, they'll be okay, right? If you're looking at Canadian work experience and you already have your CLB levels seven, you're okay.
But if you are looking at this new program, here's where the minimum has increased for people under federal skilled trades, ~um,~ as well as some of the people under CEC who are in the lower tier occupations, and it's going up to a six. It's gonna go six across the board. And for foreign applicants under FSWP, they used to be at a seven.
So foreign workers, people who have foreign work experience [00:10:00] that's high skilled, they're gonna benefit a little bit because now more people will be eligible. But some people who are in lower tiers under CEC or especially our tradespeople, those are the people who are going to have a harder time because that language level, the floor has lifted, right?
~Um, ~or if you're walking through and you're trying to get through that door, you gotta, you gotta reach a little bit higher. Same thing with education, ~uh,~ especially for the trades and for CEC, it was not a minimum requirement to have that high school. And some people who are highly qualified tradespeople just don't have that high school certificate.
So this is where your minimum eligibility criteria is fundamentally shifting
All right. Okay, so let's take a look as we continue forward on who the real winners and the losers are. So you can see here, basically, like Alicia talked about, the education, that's a big change. Language, we're s- we're gonna see a little bit of a, [00:11:00] a, an adjustment, at least... And remember, we're talking about the entry here, everyone.
And then work, this has been a real challenge for people. A, ~you know,~ achieving this accumulative, ~uh,~ kind of, ~uh, ~combination of one year and all of the, the hoops that we have to jump through. It's gonna be interesting, Alicia, when we ultimately see how these regulations are structured with that same issue we talked about before with trying to accumulate it all in three years versus the 10, and I just don't know.
Like, I'm just not sure if it... Like, they're gonna look at this. They have to look at this and realize that the problems it- it's causing. And you and I have talked about this it seems like every episode that we do, and the reality is, ~um,~ is it going to truly capture the people that they really think they are going to be capturing if they, if they do drop, ~you know,~ from 10 years to three?
So we will... So we'll, we'll see how that plays out. All right. Let's talk about who walks through easily. Well, maybe, maybe that's not an easy kind of thing to identify, but let's work off [00:12:00] of our people that everybody's familiar with. And, ~uh,~ we're gonna come back here to Eric and Amal, Ken, and Charlotte. Oh, poor Charlotte.
I, I always feel for Charlotte here. ~Uh, ~she had a good run, Charlotte did. Okay. So, so if we're looking at this, like we said, the, the- there's winners and losers. We know that the merger has genuine winners, and the most interesting thing is that two of them are people the old three-door system actively disadvantaged.
So I guess we could start with them Yeah. So I think this new system is designed to help people like Eric. Well, it's definitely designed for them all, but let's talk about Eric first. So Eric, if you remember, was a foreign, ~uh,~ skilled worker, so didn't have any Canadian work experience. Did have a job offer though, was a senior executive, had a high wage factor, ~um,~ but was older.
And so this is where under the current system, Eric does not have a good chance because can't qualify for CEC, has to qualify [00:13:00] for SW- FSW. Maybe they're not meeting the 67-point selection factor grid, so they're not even getting in the pool. ~Um, ~but if they are, because they have that job offer, remember that the job offer points were taken away.
So even if they could get past that 67-point threshold pass mark, their CRS score was just not high enough. And so under the new program with this new eligibility criteria, then the fact that Eric doesn't have Canadian work is no longer a barrier. And so Eric's able to use that foreign work, and especially because it doesn't have to be one year continuous within the same NOC, it's gonna open up the door for more foreign workers who are maybe a little bit older, but have high skilled work in different occupations, and maybe they do have that Canadian job offer So Eric's gonna be a winner.
Amal we know-- Amal's a physician, so she's set. She's, she's gonna be good under this new program. ~Um, ~she's good under the current program. She's gonna be a strong applicant no matter [00:14:00] what. She just needs to make sure that she has all of her documentation in order, and that she's not giving the wrong education credential assessment, for example.
Physicians need very particular documentation. So, ~um, ~Amal's good. Ken, Ken's where we have some concerns, right? Because Ken is our tradesperson, and so Ken's thirty-one, a crane operator, apprenticeship in progress, has one year Canadian experience. So theoretically, there's some good news and some bad news for Ken, right?
Because Ken doesn't have that full trade certification, and so it really depends on how they roll out this new Red Seal qualification. And if Ken can't get a Red Seal, it's definitely gonna be a problem. ~Uh, ~the other thing that Ken, that Ken's gonna have to worry about that he didn't have to worry about right now would be those language levels and the education.
Because we know there's many skilled tradespeople who have been masters of their craft for the [00:15:00] last thirty years, but they actually don't have a high school diploma. They don't have an education credential assessment because they did trade school, and some of the education credential assessment organizations will not assess trade school certifications.
And so it's not equivalent to high school, and so that's a big problem for people like Ken. Mm-hmm. And then Mark, Charlotte. ~Um, ~Charlotte, Charlotte's in a really sticky situation because this is where we know that Charlotte is going to be disadvantaged under the new system. So we talked about this a lot in the last episode, but really, Charlotte's the one or people like Charlotte who are younger, who are in NOC codes that may not be the ones that are, ~you know,~ getting high wage occupation factors, that probably are not the ones that are gonna be on the targeted list when we look at those category-specific draws.
The minimum eligibility criteria for Charlotte, she'll still meet them. She'll still clear the floor. But the problem is, if we're talking about a waiting room, she's got the [00:16:00] keys to get into the waiting room, but she may never get out of the waiting room. She may never actually get- Yeah ... a chance. Yeah. ~You know,~ what's interesting is you were talking about Ken.
I was thinking back to some of the messaging that we received in some of those initial meetings with IRCC when they were talking about the upcoming changes in some of their slide decks, which I have not seen circulated around a little bit. And that is, a- and you've been in, ~you know,~ you've been in those meetings.
You're on th- th- with our Canadian Bar Association in, in the, ~uh,~ in the working group for, for these re- express entry reforms. You've, you've been in those meetings. And there was a hint, at least some messaging about the, the licensing being licensed, ~you know,~ not just tradespeople but licensed professionals as well, which I think not many people are talking about that.
So can you imagine, ~you know,~ medical professionals who are already heavily favored, but engineers, architects, ~you know,~ how far does it stretch? How far could it stretch? Mm-hmm. Yeah, and that's one interesting thing that when we look at, there's just a tiny little mention of it in the [00:17:00] public consultation documents.
They're talking about looking at, and again, this is not minimum eligibility, but bonus points on the CRS for certificates of qualification for Canadian-licensed mandatory regulated occupations. And so when I think about those, I think about a lot of the mandatory medical licensed professions, so doctors, nurses, all the people who have to get mandatory trades or mandatory professional licensing with the province.
~Um, ~yeah, engineers, architects, all sorts of land surveying professions, lawyers. ~Um, ~a lot of people are able to get licensing if they jump through all those provincial hoops with their regulatory bodies. And so it does talk about recognizing Canadian-certified other professionals. Hmm. Let's talk about the quiet winner.
~Um, ~one word, cumulative, all right, is what's driving the ship. So beyond the four profiles, there's this whole quiet category of [00:18:00] winner created by one word. Picture someone with, say, eight months of Canadian experience and six months of foreign experience in the same skilled occupation. Today, that person falls into a gap.
Not enough Canadian time for the Canadian Experience Class, and not enough continuous em- employment over one year to meet the skilled, ~uh,~ um, Foreign Worker Program. So under the Skilled Worker Program. So under the merged floor, those months simply add up, at least based on what we're hearing right now.
So obviously, all this is kind of speculative, but one cumulative year, and then you're done. So I see these fragmented history files constantly, and current, ~you know,~ basically the current system punishes them for, as far as I'm concerned, no good reason. ~Um, ~the merger fixes that, clearly. I don't know what your thoughts are on, on this, Alicia, if it's actually gonna come to fruition.
But it, like, one example, I guess, from, from my perspective, especially with the foreign work experience, is people that are working in jobs that just don't lend [00:19:00] themselves nicely to one continuous year. I think of all of the, the ship captains and things like that who work on the ships, who I had so many clients like that in the early days, and then I think they just stopped calling because they all realized that they weren't gonna have a chance.
But effectively, they'd be on the ship for six months and then be, be home on leave, shore leave for six months, and they just never could accumulate the full one year. Well, maybe we'll have to see how it plays out. I don't know if that, those individuals are gonna be helped or, or they're gonna be harmed, if they're gonna still expect, ~you know,~ that somehow it's going to be cumulative or if they're gonna allow a combination.
Uh, like we've, there's a lot of information in there and, and we have some very clear indications. But until the, uh, the regulations are actually, um, released, it's-
~You know,~ it, we're, we'll just have to see, I guess. ~Um- ~Yeah. So one hand they're saying, "Okay, it's gonna be cumulative," which means it doesn't have to be continuous. So that ought to be a gift, right? That ought to be something they're giving. [00:20:00] Now you can combine different NOCs instead of having to have only one single National Occupation Classification code.
Same thing for teachers, Mark, or anybody who had, ~you know,~ shifts where they're working two weeks on and then, ~you know,~ four days off or something like that. Maybe it will be easier for certain groups to be able to prove that work experience. However, here is the caveat, and this is with the fine print, and this is where people who are students are going to be disproportionately negatively affected.
Yes. And if you are only looking at the last three years, it's not any three-year period, it is the most recent three years from when you're submitting your profile, then the people who are going to lose are the people who are doing a bachelor's degree of four years or doing a master's program or a PhD program where they've been working, but maybe they've only been working a few hours or research positions where it's not hitting that ability to combine within the last three years to have [00:21:00] one year.
'Cause normally when we look at combining 24 months of part-time work, it's gotta hit at least 15 hours per week in order, over a two-year period, to be the equivalent of one year, 30 hours per week. And so the difficulty is if you're a student and now you can't look back for the last 10 years, you can only look for the last three, then that means students need to start hustling to make sure that they are going to, as soon as they graduate, get that work experience high skilled or find some other way to use foreign work experience.
Yeah. Okay. Let's, let's talk about kind of an honest caveat, I guess. One guardrail so nobody mishears the good news: foreign experience getting you through the door is not the same as foreign experience getting you selected. So once again, the floor opens, that's great, but the CRS still decides, and the CRS continues to reward Canadian experience heavily, and the new high wage factor rewards Canadian experience like high wage experience specifically.
So [00:22:00] for Eric and others like him, the precise message is that the merger gets you into the room, your job offer and your occupation's wage tier may very well determine whether or not you win it. So Alicia, let's jump back and let's just take a look at who the door... Well, it sure looks like who the door locks out, the trades trap.
And we're still sorting through this, you guys, but here's kind of our take on it Mm-hmm. And this is where we will have to see what happens with the consultations. We'll have to see what happens when there's published feedback from the regulatory announcements and the regulatory impact statement, and when that's gets published in the Gazette, and then they refine it.
But the current concern that many immigration lawyers across the country have is that by raising this language level, it is going to affect the trades, the people who are currently eligible for federal skilled trades the most. Because going from a CLB 4 [00:23:00] to a CLB 6 is a significant jump, and maybe people will argue, "Oh, well, they wouldn't have gotten an invitation to apply anyways 'cause their CRS was too low."
But theoretically, you want to have that funnel, you want to have that eligibility funnel fairly wide so that you have a large pool of applicants who are qualified, and then IRCC can select amongst them by doing their category-based draws or by tweaking the CRS. But if you lock these people out at the very beginning, and those are precisely the people that we need to build our country at the moment and continue to, ~um,~ innovate, then there's a, there's a disconnect.
There's a misalignment. Yeah. All right. ~You know,~ if you think about Ken, let's revisit him just for a quick little second, ~um,~ from segment four. The merger helps him by removing the certificate gate, so at least allegedly it does. But Ken is also the cautionary tale because whether he clears the new floor depends entirely on his language [00:24:00] scores.
And if, like Alicia said, if Ken tested a, at a level, a CLB six, the merger is a net win for him, at least getting in. If he tests a CLB five, perfectly functional for crane operation, that same merger that opened one door could very well close another. And one person, and basically the proposal helps and hurts him at the same time.
So that's the trap kind of in a, in miniature. Yeah. And, and here's the, the second aspect of the trap, and that's the education. Because many skilled trades workers went to apprenticeship school. They did vocational school. They actually didn't- Yeah ... do a, ~um,~ academic high school, high school certificate. And because they don't have that, and they're currently working, and they've been working for the last 20 or 30 years- Mm
it's really difficult now as a mature learner to go back and try to get your high school education, especially when you're working a ton of hours to try to support your family in Canada. And we know that if you're in Canada working, [00:25:00] you have to get a study permit if you wanna go back to school- Yeah
unless you're doing 100% distance learning. And then if you are, and this is what we'll talk about f- in future episodes, if you are a full-time student under a study permit, you're not usually eligible to claim that high-skilled Canadian work. And so it's a catch-22 for people who don't have minimum high school education.
Yeah. And ~you know,~ when you think about all this, it's not just, Alicia, it's not just an equity argument. It's a labor market one. So Canada's stated infrastructure and housing agenda runs on exactly these trades. And just today I had a consultation with, ~um,~ like in the provinces sometimes don't even get this right too.
I had a consultation with a home builder who, it's a small home bu- builder, and traditionally, ~you know,~ residential construction operates with contract workers, and, ~uh,~ so a lot of them are just subtrades, and then the general contractor, and in this case there was a site supervisor that was an employee of the company.
And [00:26:00] and unfortunately fraud is a reality within everything that we're doing these days. There's high rates of fraud, people desperate, willing to do anything to try to stay. And so the PNPs are grappling with this, and the federal government's grappling with it, and, and so they're... Even with these changes now, they're trying to find a way forward.
~Um, ~but in the example of this client, they had their Alberta Advantage Immigration Program, the nomination application refused because of some very, very technical grounds, and arguably they are grounds that they'd set to, to exclude people. But sometimes when the government is trying to make good decisions, they, they kind of miss the, the forest for the trees, or miss the trees for the forest, whatever the analogy is you wanna, you wanna go with.
~You know,~ if we're, if we're housing is a crisis and building residential homes is a crisis, and this is a company who employs a lot of trades, and they're building homes, and this one guy that they're trying to keep, because they don't have a physical office premise, ~you know,~ which I've got [00:27:00] a brother who did residential construction, I've got a friend who owns a company right now, now that does it, his home is his office.
He doesn't meet with his clients in his house. Well, he probably does meet with them in his house when he's setting up ~You know,~ when they're working through the plans and the, the building, ~um, uh, you know,~ just, just how the, the whole build is gonna play out. ~Um, ~even getting new clients, ~uh, you know,~ new customers, all those things.
Y- rarely do you need an office. We're not like a big, ~you know,~ some of the big home builders, for example, in Calgary, who of course have offices. But the Alberta Advantage Immigration Program has set those, set those, uh, levels and those requirements for a reason. Sometimes they were pushed because of fraud and their desire to ca- ~you know,~ to deal with it.
In other cases, ~you know,~ in, in their attempts to do it, it catches people that they otherwise wouldn't catch. So, um, yeah. So they're... ~You know,~ for all these individuals, like they're trying to find this equitas approach to it, this where- this fairness, but often it doesn't, it doesn't equate. There's always gonna be winners and losers.
And so, ~um, ~[00:28:00] a floor calibrated for engineers and medical professionals applied uniformly to roofers and welders, well, it risks screening out the, the workers the economy is in shortest of, like that they really need. And that tension, I guess, is at the heart of where we'd push back a little bit, right, Alicia?
Which is exactly where we go next. So where do we kinda land? And I think largely, Alicia, we're pretty aligned with our fellow lawyers across the country. So, uh, some of our colleagues that are listening to this are probably gonna say, "Well, yeah, that's what we've all been saying. Yeah, we've all been saying this."
So let's take a peek at this and just see kinda where we support and where we'd probably push for some change, because within the regulatory process, we may actually have an opportunity to, to have change, or at least have an influence on it Mm-hmm. And to summarize these, a single program, okay, this is a simplification.
We want to make things more transparent. We want to make them more intelligible. We want to [00:29:00] simplify. Good. We have no concerns about getting rid of that sixty-seven point selection factor grid because it is confusing, and basically there's some redundancy. So all right, it makes sense to move to simplify.
It also makes sense to look at cumulative and foreign work experience instead of only looking at continuous one NOC, because people have different jobs. Increasingly now, they are working multiple different jobs in multiple different sectors. Here is where we have concerns, and it is largely for the tradespeople.
It is for the people who are now going to have to hit higher language levels. It is for the people who now are going to have to go back to high school or find some other way to prove that they have the minimum education eligibility so that they could even get in the pool. Here is my big beef. I've been talking about this the entire time, but with self-employment, when we look at under the CEC [00:30:00] program, it currently says you can't use self-employment unless you are a physician or very specific NOCs under, ~uh,~ medical categories.
Self-employment doesn't count if you are looking at Canadian self-employment. But here's the thing, it counts if you've got foreign work experience. Provided you can prove it, right? Provided you can prove it in this world, but you've got a shot, right? You've got a shot at it. Right. And here's the other problem with Canadian work experience, high-skilled work experience.
It doesn't count for CEC. If you are a full-time student on a Canadian study permit, you cannot count your high-skilled work experience for the purposes of minimum eligibility. And it looks like those strictures and even tightening those strictures are going to remain. And so the effect of this is going to be disproportionately negative for Canadian foreign worker students who are currently doing a longer program, so a [00:31:00] bachelor's or a master's or a PhD.
And those people, I want them to be listening because the good news is they can prepare, and they can understand that this change is probably coming. But hopefully the government will publish a transition protocol so that people will have notice. Because honestly, students have paid three times.
International tuition is three times that of a domestic student. They've given up everything in their life to come to Canada to study and then to work. And if they can't use their foreign work because now it's been three years since they had that foreign work, really understanding what's- what the minimum eligibility criteria for work experience is in the future program is essential.
Yeah. ~Uh, you know,~ you guys, we're not reform skeptics. Like, we're not. Like, we think these reforms are actually worthwhile and, and, ~uh, you know,~ we're advocates for a merger done with its eyes open, one that keeps the simplification and fixes the trades trap and the other things we've talked about before they actually become law.[00:32:00]
And here's the part that separates this reform from every other one in the series. So you can still influence it, and the merger rides this regulatory track. When the proposal hits the Canada Gazette, the law requires a public comment period, a real one, where arguably the government must read and respond to what it's, ~you know,~ what's been submitted.
The CRS changes, though, they don't give you any such window, but this one does. So if you're a tradesperson, especially an employer who hires them, or really anyone who sees the gaps, ~you know,~ that we've discussed in this episode, that comment period is where it guides the discussion. So, ~um, ~I recommend that people absolutely take time when we see those, ~uh,~ regulations being published that they do put input in.
And, ~um, you know,~ in fairness, Alicia, it's not often that they make changes after it's actually the regs are written and they're posted. ~Um, ~usually they try to iron those things out before they get to that stage. And I know as a [00:33:00] Canadian Bar Association, ~um, you know,~ our, our working groups have put together responses and, and just trying to highlight some of the unseen, ~um, you know,~ maybe problems that they, they sometimes the drafters just don't understand because they're not on the ground like we are.
But if you want to have a change in how everything is functioning here in the country, especially with respect, with respect to express entry, you have to take the time to respond when those windows open up. Okay. Two clocks, Alicia, and what to do before they start to move. Mm-hmm. So this is where, ~you know,~ CRS changes could happen right away.
We've talked about this in the previous episodes. So if you are counting on points that they just might wipe out, those ones at the bottom when you look at the CRS grid, and it's the additional factor points under Section D, ~you know,~ if those are going away instantly, they could be going away tomorrow, they could be going away within a month, then make sure that you have a game plan.
~Um, ~and then when we're talking about these [00:34:00] regulatory changes for minimum eligibility criteria, make sure that you are talking with your trade associations. Make sure you're talking with your union representatives. Make sure you're talking with the organizations that are there to represent the interests of various groups, ~um,~ so that hopefully the government will get some feedback, and we are looking at choosing from the pool of people that is going to make Canada a strong, resilient country into the future.
All right. You guys, this episode was fun, but episode seven is gonna be one that you definitely don't wanna miss. We're gonna talk about the high-wage occupation factor. This probably is the single most important thing that's gonna move your score, the one with the wage tiers at 1.3, 1.5, two times the national median, and the qualifying occupation question everyone's so anxious about.
If the merger sets the floor, then the high-wage factor rebuilds the scoreboard, so don't [00:35:00] miss it. And as always, if, ~you know,~ today the things that we've talked about have raised real questions for you, whether you're clear the current- about the current, ~uh,~ the current floor, whether you're clear about the proposed one, whether you're just not sure whether to file now or wait, well, generally speaking, we'd always encourage you to submit your application, ~uh,~ your profile in and keep it in 'cause you can't get a draw drawn unless it's in there.
Well, these are the things that we discuss all the time in our consultations, and, ~uh,~ holthelaw.com/consultation is how you find us, and you can book a strategy session with us before this slow clock runs out and the fast one kicks in. All right. Also, don't forget to subscribe to this if you're listening on the podcast feed or if you're watching on YouTube and you...
If you are listening, we definitely encourage you to slide over, and you can get the visuals that we've, ~uh,~ put together here that I think really help this, these episodes to level up a little bit. So we've kind of finally found a happy medium between the audio that we run in our podcast and then [00:36:00] making something meaningful, ~uh,~ for the Canadian Immigration Institute YouTube channel.
So thanks so much for joining us in this episode. Alicia, any final parting comments before we wrap up and drift off? I just wanna thank people for listening. I've had a, a few consultations where people said, "I was listening to your series, I was listening to the new changes, and I wanted to book a consult because I realized I might not qualify or maybe my game plan's wrong," and that's, that's great to hear.
It's all about education. Thanks everybody. We'll see you, ~uh,~ I guess in our next episode, episode seven. That's all about the high wage occupation factor. Take care
