A December 2021 report by the Auditor General of Ontario on its audit of public colleges in the province found “limited college oversight of international student recruitment agencies”.
The audit examined the 24 publicly assisted colleges of applied arts and technology established under the Ontario Colleges of Applied Arts and Technology Act, 2002 (Act), namely:
- George Brown
- La Cite
- St Clair
- St. Lawrence
The audit selected four colleges – Loyalist, Sault, Seneca and St. Clair – for close examination based on factors including the size of the college by enrolment, the number and percentage of international students, board governance practices, geographic location and other observations we made during the audit that prompted further examination.
The report noted that public colleges typically use numerous education agencies to recruit international students and that each college is responsible for overseeing its recruitment of international students. For the four public colleges noted above, the number of contracted recruitment agencies varied from about 40 to 400.
The key findings of the audit on the use of education agents broadly related to issues around initial and ongoing due diligence. The relevant extracts are set out below.
Education agent policies
“Based on our review of the four colleges we reviewed in-depth, we found that while they have internal processes for their review of recruitment agencies, none of them have formal policies in place that outline specific criteria for the selection and removal of these recruitment agencies. Without a formal policy, it will be at the discretion of college staff or management to determine which agency to contract with or not. For example, we noted that one college requires two references to contract a recruitment agency, while the other three colleges generally perform reference checks, but are not required to do so. According to Manitoba’s International Education Act and best practices, education providers should obtain at least three references before they sign a contract with these agencies.“
Advertising and marketing by eduation agents
“In addition, our audit found misleading advertisements posted on some of the recruitment agencies’ websites, which in themselves, can create a reputational risk for the public college sector as a whole and also highlights the need for further scrutiny of these agencies. For the four public colleges we reviewed in-depth, we reviewed a sample of 100 international recruitment agency websites (25 for each college). Most (93) of them presented accurate information; however, seven made misleading claims. Examples of misleading claims were related to the visa approval process, such as ensuring 100% success, providing “visa assurance,” and guaranteeing positive scores on the International English Language Testing.
We found that the four colleges monitor agency advertising and/or approve marketing materials only when they relate to their college branding. However, the instances of misleading claims we found were related to general statements made about the application process by the agencies. These misleading claims, while not specific to a college, still do not accurately reflect the application process to students and should be monitored by the colleges on a regular basis.
We noted that one college (Sault) included a clause in its contract that “agencies cannot make claims about visas”; however, contracts we reviewed for the other three colleges did not include this specific clause.“
Commissions and performance evaluation
“The recruitment agencies are remunerated based on commissions paid by the public college. Since these commissions are calculated as a percentage of tuition paid by international students, recruitment agencies are incentivized to enrol as many students as they can in the programs that charge the highest tuition fees. We noted that commissions paid to recruiters at the four colleges varied, ranging from 15% to 32% of first-year tuition fees…However, this remuneration structure does not consider qualitative factors such as students’ satisfaction of the recruitment processes and whether they were provided with accurate and complete information at the time of recruitment.“
Based on the findings above, the audit report made the following recommendation:
So that international students who are recruited to attend public colleges in Ontario are provided with accurate information to make informed decisions, we recommend that the Ministry of Colleges and Universities:
- expand the Ministry’s directive requirements to include the advertising of college admissions processes, such as visa and language testing;
- confirm that public colleges have a formal policy for the selection and removal of international student recruitment agencies;
- require public colleges to monitor the agencies’ advertisements at a regular interval (between three and six months) to confirm they are factually correct, and that any errors or other misleading advertisements found are corrected in a timely manner; and
- collect data related to fees paid to recruitment agencies, and assess the reasonableness of the fees paid on a per student basis.“
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