So, what did the bad actors do? Break federal law? No. Violate student financial aid? No. Were they out of compliance? No. Did they do anything illegal? No.

The “bad actors” are being blamed for the housing crisis; they’re being blamed for all kinds of distortions in the economy and in education. In short, they’re being blamed for being greedy.

Admitting too many students to maximise profits at the expense of Canada and Canadians. None of that is true, mind you.

The government of Canada (though slow on getting data) knew the scale of the issue. VFS Global, for instance, provides the government with significant information on visa processing.

All colleges, including private ones, report numbers to the ministry, while most even maintain publicly available information on their website. They followed the letter of the law, so maybe it’s not the “actors” that is the problem, but the rules and regulations?

Public-Private Partnerships: A primer

The Public-Private Partnership in Higher Education model came to Canada from the UK, where it has been common practice since the early 1990s. The general model is that private institutes develop agreements to deliver programs on the behalf of public institutions.

Private colleges have more robust marketing and recruitment capabilities, they have different incentive schemes for recruiters and have created roles in marketing and strategy not commonly found in the public HEI sector; moreover, they have strong international recruitment networks that reach well beyond a country’s primary city.

In the Canadian context, these partnerships began cropping up in the mid-2000s and by 2012 there was enough activity for the then-MTCU to take notice. David Truck wrote a report (see Alex Usher’s article linked here) outlining the guidelines for these sorts of partnerships. In short, public colleges (mostly non-GTA) partner with private organisations (Private Career Colleges and their holdings companies) to set-up a GTA campus to deliver public-college curriculum.

Public college receives cash per enrolment and the PCC does the rest. Because both organisations operate under the Ministry of Colleges and Universities umbrella, they all have approval to operate. Now, are there some schools offering a substandard service? Absolutely, but that doesn’t mean the PPP model is the problem. For “bad actors”, they’re staying on the right side of the law.

Most of these PPPs are in operation because public colleges lack the robust infrastructure needed to really recruit students.

They also lack the ISSS infrastructure that the private groups have successfully developed. Most of the private colleges have student service units tailored to the unique needs of international students. They have IRCC-approved consultants and often provide services in a multitude of languages to ensure clear communication.

One of the big reasons why students choose these opportunities is because of the services they receive. They know they could get support in their native language and could ask relevant questions and get relevant information. More importantly, many of these PPP programs include an internship, which is highly coveted. Canadian work experience is highly sought after and it’s something that most public colleges only offer in more general terms.

So, remind me: How are these “bad actors” again?

One of the big issues has been the use of recruiters and agents that can use high-pressure tactics and use misleading statements. There’s no doubt in my mind that happens – I’ve experienced it firsthand. But again, I have to raise issue. The Canadian government has run recruitment events for more than a decade.

It’s the government that set the $10k maintenance funds limit back in the early 2000s and then didn’t move that for 20 years.

They’re the ones setting approval standards for visas. They’re also the ones who should be taking enforcement action against violators. They saw the situation unfolding with emerging residential geography patterns of international students.

The government is blaming the colleges who, for the most part, are compliant with both federal and provincial regulation. While there are certainly bad agents and some do use deceptive tactics, it doesn’t necessitate attacking the entire industry. Much of what the government is saying about piggish behaviour is not only condoned by the government, but they’re actively supporting it.

What’s Next?

It’s clear to me that the minister is doing this now in anticipation of an election. The rules don’t target housing issues or economic distortion. It doesn’t reform the visa regulations or improve regulatory enforcement. It kicks the can until the next government is formed.

In the meantime, it will impact colleges and create an ungainly provincial approval program that will be nothing but a mess. But, this isn’t over.

The government has identified it as a “problem” and in the eyes of the public something has to be done. Whether there’s a new PM or not come the next election, things will change.

“The cost of recruitment is going to jump; you’re going to need to discount and increase scholarships to protect yields”

It remains to be seen how it’ll change, but I think what’s next is the PPPs, public colleges and private colleges need to brace for impact and begin to pivot. I would make three key recommendations to ready your organization:

GYFHIO: Get your financial house in order. The cost of recruitment is going to jump; you’re going to need to discount and increase scholarships to protect yields. Now is the time to ensure that overhead and operating expenses fit a pared-down headcount for the next few years. The cost to recruit is going to jump and you may have fewer students for the next several years. Identify areas where costs can be restrained and begin to look for opportunities to find savings. Part of what I’d recommend is also some strategic investments, so it’s best to have a firm grip on the bottom line when the top line may be ambiguous, at least for a while.

Curricular Innovation: Invest in an LMS that gives you a truly global opportunity. Starting students in pre-diploma course work, flying-start programs or language upskilling programs will help you protect yield, prepare students for studying/living in Canada and give colleges a robust platform to work with students before they get on campus.

It’s also imperative to implement High Impact Practices. In Ontario, Canada the MCU sets standards for public curriculum, but they can go beyond. It’s no longer sufficient that students in a marketing program can do a SWOT analysis. They need to be building a portfolio (hence LMS), they need to partner with organisations like Parker Dewey, HubSpot and Riipen.

They need to embed industry-focused micro-credentials at all levels of the program (see below). Meeting the standard for public curriculum isn’t going to be sufficient to win under tight enrolment numbers. You need to offer an industry-leading educational experience and certificates, diplomas and work experience bundled into a single program willwin.

Career Model:Colleges, both public and private, need to develop partnerships with professional associations and credentialing bodies to develop and deliver content. Whether it’s business analysis, project management, accounting, or marketing, we need to tie the diplomas to outcomes and one of them has to be compliance with professional designations. That has often fallen by the wayside. Students are often unsure where they can go with a diploma and a diploma alone is not enough to cut through the sea of applicants. More industry-focused partnerships will be critical.

I didn’t talk about the Post-Graduate Work Permit because it’s still very murky. PGWP were never intended for private colleges, yet they were getting approved previously and the PPP model poses a unique situation. I think we need to really understand the situation more before we act. Right now the government is putting the blame on colleges, and vicariously the students, rather than admitting that the gaps have existed for years and only now are they acting after the public began to really take notice. It feels rushed and doesn’t come off as credible policy. If anything, it gives the appearance of desperation. For colleges caught in the now murky currents, it’s time to make strategic investments, review your business operations and most of all, support your students. They’re not to blame.

About the author: Phillip Gingras is a specialist in higher education, international education and edtech. He is currently Strategic Program Manager at D2L. This article first appeared on his LinkedIn page, follow Phillip here.