Submission to the Standing Committee on Finance and Economic Affairs

November 6, 2017

Re: Bill 148 – Expansion of Student Internship Exemption to Students of Private Career Colleges

Career Colleges Ontario represents just under 50% of private career college (PCC) campuses in Ontario and an estimated 65% of all PCC students enrolled in non-real estate vocational programs.

There are approximately 43,000 PCC students (excluding students enrolled in real estate programs) who are trained in hundreds of skills ranging from para legal to massage therapy.

All PCCs are subject to rigorous regulatory oversight by the Ministry of Advanced Education and Skills Development, including the requirements of annual re-approval of their registrations and reporting on Key Performance Indicators and Default Rates for OSAP designated PCCs.

Our students are typically older than those of public colleges, with more than half of PCC students being over the age of 30. About half of PCC students are first generation immigrants and there is a higher proportion of women in PCCs than in public colleges.

Our community is distinct and serves a particular need for students who want flexible and focused vocational training and do not fit the public college model.

It is estimated that roughly 60% of PCCs offer an internship/practicum program. Indeed, these are integral to vocational training.

We are very pleased to see that PCC students will now benefit from the expansion of the Internship exemption but are puzzled as to why the exemption has been qualified by the language “…and that meet such criteria as may be prescribed”. When Bill 148 was introduced there was no such qualification. It was only after the legislation was in committee that this qualification was introduced.

CCO has advocated for the equal treatment of PCC students, who as critical members of Ontario’s postsecondary educational sector should be treated equally to students attending public institutions.

We do not understand the limitation that has been placed on the extension of the exemption especially given the government’s regulatory system and sector audits, which have been instituted to maintain quality assurance. Moreover, it is unclear to us why PCC students should be treated differently from those at public institutions.

We therefore recommend that the extension of the internship exemption for PCC students be amended to reflect the original intention of Bill 148: amend the student internship exemption to include all of Ontario’s postsecondary students, including those who attend PCCs.

Respectfully submitted by,

Sharon E. Maloney, LL.B

Chief Executive Officer | Career Colleges Ontario