Thank you.
Due to COVID-19, employees are working for long hours. Kids are off from school, thus the volume of work has increased and, in some cases, doubled. Many migrant caregivers are confined to employers' homes and have less time to study for the test. As a result, they are having difficulty preparing for and passing the language test. In this case, caregivers have been known to take the English language test as many as five to ten times, which is not only inconvenient but also costly.
We highly recommend that the federal government ease barriers to permanent resident status, eliminating the English language test and removing the requirement of one year of Canadian post-secondary education. Furthermore, we would like to endorse the Migrant Right Networks recommendations in “Behind Closed Doors: Exposing Migrant Care Worker Exploitation During COVID-19”. This is the modified interim program they recommend.
It should also reduce the work experience requirement to 12 months and allow for care work in either child care or high medical needs streams to count towards the one year requirement; remove the requirement for one year of Canadian post-secondary education; and remove the English language test prior to permanent residency. Starting in 2014, the new pathways program mandated that caregivers meet a higher official language proficiency benchmark to qualify for permanent immigration to Canada.
We also recommend the implementation of effective measures to reduce processing times for applications for caregivers, family reunifications and refugee eligibility assessments for citizenship. Data shows applications were moving slowly even before COVID-19 lockdowns reduced the immigration department's processing capacity last year. Due to the COVID-19 pandemic, the IRCC processing time has slowed to a concerning level. Most immigrant caregivers are concerned with their status, especially those with implied status. According to a recent article in the Toronto Star:
...there's a backlog of at least 9,100 applications for permanent residence. That matches the kind of numbers that government saw back in 2017, when processing time was known to be as long as five years.
Many workers who applied in 2020 are still waiting for notifications that their family application is completed. Applications could be returned for minor non-compliance, and clear instructions to officers to exercise flexible accommodation and process applications should be issued; otherwise, applications would be returned after many months, and caregivers who otherwise would benefit from implied status would become out of status.