Vol. 151, No. 14 — July 12, 2017

Registration
SOR/2017-126 June 20, 2017

CANADA STUDENT FINANCIAL ASSISTANCE ACT

Regulations Amending the Canada Student Financial Assistance Regulations

P.C. 2017-778 June 20, 2017

His Excellency the Governor General in Council, on the recommendation of the Minister of Labour, pursuant to subsection 15(1) (see footnote a) of the Canada Student Financial Assistance Act (see footnote b), makes the annexed Regulations Amending the Canada Student Financial Assistance Regulations.

Regulations Amending the Canada Student Financial Assistance Regulations

Amendments

1 The portion of subsection 23(1) of the Canada Student Financial Assistance Regulations (see footnote 1) before paragraph (a) is replaced by the following:

23 (1) The Minister shall, on the written request of the borrower and based on documentary evidence provided by the borrower, reconsider a borrower’s application for repayment assistance if

2 The heading before sections 40.02 and sections 40.02 and 40.021 of the Regulations are replaced by the following:

Grant for Full-time Students

40.02 (1) The Minister, an appropriate authority or a body authorized by the Minister for a province may make a grant to a qualifying student who

(2) The maximum amount of the grant for each month of study shall be the lesser of $375 and the amount determined by the following formula:

(3) Beginning in 2018, the threshold amounts in column 2 of Schedule 4 shall be adjusted annually on August 1 by the annual percentage increase to the Consumer Price Index for the previous calendar year. The resulting threshold amounts rounded to the nearest dollar apply during that loan year.

(4) If the amount determined in subsection (3) is less than the value applicable for the previous loan year, no adjustment is to be made to the thresholds applicable for that loan year and the thresholds applicable for the preceding loan year continue to apply for that loan year.

(5) For the purpose of subsection (3), the Consumer Price Index is the annual all-items Consumer Price Index for Canada published by Statistics Canada.

3 The Regulations are amended by adding, after Schedule 3, the Schedule 4 set out in the schedule to these Regulations.

Coming into Force

4 (1) Subject to subsection (2), these Regulations come into force on August 1, 2017, but if they are registered after that day, they come into force on the day on which they are registered.

(2) Section 1 comes into force on the day on which these Regulations are registered.

SCHEDULE

(Section 3)

SCHEDULE 4

(Section 40.02)

Eligibility Thresholds for the Grant for Full-Time Students

Column 1



Family size (number of persons)

Column 2



Previous year’s gross annual family income for maximum Grant for Full-Time Students ($)

Column 3



Monthly phase-out
rate

1

30,000

0.0119

2

42,426

0.0086

3

51,962

0.0074

4

60,000

0.0071

5

67,082

0.0068

6

73,485

0.0065

7 and over

79,373

0.0063

REGULATORY IMPACT ANALYSIS STATEMENT

(This statement is not part of the Regulations.)

Executive summary

Issues: Eligibility for the former Canada Student Grants for Students from Low- (CSG-LI) and Middle-Income (CSG-MI) Families was based on a complex set of calculations of various family incomes, as measured by several indices, and with provincial variations. Having separate income thresholds for CSG-LI and CSG-MI has caused slight increases of as little as one dollar in family income to result in less money being directed toward students. This approach made it difficult to predict how much non-repayable support students would be entitled to each year, and did not efficiently match grant awards with students’ financial need.

As part of Budget 2016, the Government of Canada (GoC) committed to working with provinces and territories (PTs) to expand eligibility for Canada Student Grants targeted to students from low- and middle-income families. This has led to the merging of the former CSG-LI and CSG-MI into a new Canada Student Grant for Full-Time Students (CSG-FT), with eligibility based on national progressive thresholds according to family income and family size. The new eligibility thresholds will ensure that more students will receive non-repayable grant assistance to help cover the cost of post-secondary education (PSE), and that no student receives less than they did in the previous loan year.

In addition, making changes to the eligibility thresholds provides the opportunity to address concerns raised by the Standing Joint Committee for the Scrutiny of Regulations (SJCSR) regarding a clarification to the Canada Student Financial Assistance Regulations (CSFAR).

Description: The amendments to the CSFAR (1) merge the current CSG-LI and CSG-MI provisions into a single Canada Student Grant for Full-Time Students (CSG-FT) and introduce new eligibility thresholds for the CSG-FT; and (2) contain a provision that allows for an annual adjustment to the eligibility thresholds to reflect growth in the Consumer Price Index (CPI) to allow the new eligibility thresholds to be adjusted annually by the growth in CPI.

Subsection 23(1) is also amended to remove the Minister’s discretion to reconsider repayment assistance applications if the prescribed conditions are met.

Cost-benefit statement: The amendments would lead to $1,386 (present value) million over 10 years in additional GoC funding for students pursuing PSE. The net benefit of these amendments, in terms of increased earnings for students that complete PSE would be approximately $94 million over 10 years, for a benefit-to-cost ratio of 1.07:1.

As a result of the amendments, students from low- and middle-income families will see an immediate increase in eligibility for non-repayable funding, which is expected to encourage students, particularly those under-represented in PSE — including students from lower income families, students with children, and those with disabilities — to access funding through the Canada Student Loans Program (CSLP).

“One-for-One” Rule and small business lens: The “One-for-One” Rule and small business lens do not apply to these proposals, as there are no impacts on administrative costs or on small business.

Background

Canadian students are taking on a greater share of the costs of higher education, as undergraduate tuition increases among other costs. For instance, since 2000, undergraduate tuition in Canada has increased at an annual rate of 5% to more than $5,700 per year in 2013; the figure is even higher, totalling approximately $7,700, when average ancillary fees and textbook costs are included.

The CSLP provides financial assistance to students in the form of Canada Student Loans (CSL) and Canada Student Grants (CSG) to supplement their resources and help them meet the costs of PSE. Up to 60% of calculated financial need is provided by the CSLP to eligible students in the form of loans and grants, while the PTs cover the rest. When students leave school, the CSLP also provides repayment assistance to those facing financial difficulty to ensure their student debt remains manageable as they transition into the labour force. Participating provinces and one territory (Yukon), as well as the private sector service provider D+H, administer CSLs and CSGs. Quebec, the Northwest Territories and Nunavut do not participate in the CSLP, and receive annual alternative payments from the GoC to administer their own student financial assistance (SFA) measures.

In 2009, the CSLP introduced CSGs to provide targeted, upfront non-repayable assistance to students underrepresented in PSE, including students from low- and middle-income families, students with dependents, and students with permanent disabilities. Currently, the vast majority of CSG recipients (approximately 79%) are awarded Canada Student Grants for Students from Low- (CSG-LI) and Middle-Income (CSG-MI) Families. CSG amounts are prescribed in Part VI of the CSFAR.

In Budget 2016, the GoC committed to creating more opportunities for young Canadians, especially those from low- and middle-income families, by working with PTs to make PSE more affordable and debt loads more manageable. As part of their commitment, the CSG-LI, CSG-MI, and Canada Student Grants for Part-Time Students were increased by 50%, and have been available to eligible students since August 1, 2016.

Budget 2016 also committed to work with PTs to expand eligibility for CSGs to provide access to non-repayable assistance to more students. The GoC worked with PTs over the course of spring and summer 2016 to design new national progressive thresholds that will be used to determine eligibility for CSG-FT (formerly, the CSG-LI and CSG-MI) on a sliding scale that is based on family income and family size. The new eligibility thresholds will be adjusted by inflation on an annual basis.

In addition to CSGs, the Repayment Assistance Plan (RAP) was introduced in 2009 to support borrowers who experience financial difficulties in repayment. The CSFAR used to provide the Minister with a discretionary authority to reconsider repayment assistance applications. However, it did not provide the criteria by which the Minister might exercise this discretion. In March 2016, the SJCSR raised a concern about the discretionary nature of the Minister’s authority to reconsider repayment assistance applications.

Issues

To date, the CSG eligibility system has been based on a complex set of calculations of various family incomes, as measured by several indices, with most varying by province. The result was to separate the income thresholds for CSG-LI and CSG-MI, which meant that slight increases in family income could result in less money being directed toward students. This made it difficult for students and their families to predict how much non-repayable support they would be entitled to each year, as a marginal increase in family income of even one dollar over the existing thresholds may have resulted in a CSG-MI instead of the CSG-LI, or no CSG at all. For example,

This creates a disincentive to work because additional earned family income over the CSG-LI thresholds could mean a decrease of as much as $1,800 in non-repayable support. Furthermore, the current “step” design does not adequately target federal funds to those students from lower income households. Within each “step” students are treated equally regardless of income. Students at the higher end of the income range of a “step” receive the same amount of non-repayable support as those at the lower end of the income range of the same “step,” even though those at the lower end of the income range have a greater need.

In March 2016, the SJCSR raised a concern regarding the discretionary nature of the authority of the Minister to reconsider repayment assistance applications. The SJCSR recommended amending the regulations to either (1) set out criteria used by the Minister in exercising discretion; or (2) remove the discretion if it is unnecessary. To address this issue, subsection 23(1) is amended to remove the Minister’s discretion to reconsider repayment assistance applications if the prescribed conditions in subsection 23(1) are met.

Objectives

The objective of the amendments to the CSFAR is to introduce the new national progressive eligibility thresholds for CSG-FT to ensure that more students benefit from upfront, non-repayable SFA each year. In addition to this, the amendments are intended to address issues with the income thresholds used to determine eligibility for the former CSG-LI and CSG-MI students. For example, an objective of the new eligibility thresholds is to remove disincentives to earning income, improve transparency and predictability for students and their families, as well as ensure that CSG-FT are targeted as closely as possible to students who need the assistance.

The objective of the additional amendment to the CSFAR is to clarify the Minister’s authority to reconsider repayment assistance applications when the prescribed conditions are met. The regulatory amendment will address a recommendation made by the SJCSR and resolve an issue that existed in the CSFAR since 2009.

Description

The amendments to the CSFAR to introduce the new CSG-FT eligibility thresholds are as follows:

  1. A new CSG-FT thresholds table will be introduced into the Regulations that would be based on the gradual phase-out model;
  2. Sections 40.02 and 40.021 of the Regulations will be replaced by a new provision for the CSG-FT; and
  3. A provision will be introduced to annually index the new CSG-FT thresholds to CPI, as per subsection 18.1(3) of the Statutory Instruments Act.

It should be noted that the current thresholds set out in Schedule 3 to the CSFAR will remain in place to determine eligibility for CSGs for Full-Time Students with Dependants (CSG-DEP), CSGs for Part-Time Students with Dependants (CSG-PTDEP), CSGs for Part-Time Students (CSG-PT) and Part-Time CSLs (PT-CSL).

Under the new eligibility thresholds, students are eligible for the maximum CSG-FT amount (i.e. $375/month) when their family income from the previous year is at or below the thresholds set out in the table below according to their family size.

Family size

Previous year’s
gross annual family income for maximum CSG-FT ($)

Monthly
Phase-out
rate

1

30,000

0.0119

2

42,426

0.0086

3

51,962

0.0074

4

60,000

0.0071

5

67,082

0.0068

6

73,485

0.0065

7+

79,373

0.0063

For students whose family income is greater than the applicable threshold, the amount of grant awarded decreases by the phase-out rate prescribed in the table above. These phase-out rates ensure that no previously eligible recipient will become ineligible under the new eligibility thresholds (even after accounting for annual updates to the thresholds for inflation, as per the original CSG design recommended in Budget 2008, in 2017–2018). On a go forward basis, the new eligibility thresholds will be adjusted according to the annual growth in the CPI to account for inflation.

The amendment to the CSFAR to address the SJCSR’s recommendation is as follows:

Moving forward, the Minister shall be required to reconsider repayment assistance applications, on written request and based on documentary evidence, if (a) a borrower’s application was rejected solely because he/she was not assessed as having a monthly affordable payment that was less than their monthly required payment; and (b) unforeseen and unavoidable circumstances beyond the control of the borrower or their spouse or common-law partner led to the borrower incurring extraordinary expenses.

Regulatory and non-regulatory options considered

The issues identified with the former thresholds prescribed in the CSFAR and used to determine eligibility for CSGs for low- and middle-income students could not be addressed by means other than regulatory amendments. As a result, non-regulatory options were not considered.

Likewise, non-regulatory changes were not considered to address the recommendations made by the SJCSR, as a regulatory change was necessary to remove the Minister’s discretion to reconsider repayment assistance applications when all prescribed conditions are met.

Benefits and costs

Establishing new national progressive eligibility thresholds for students from low- and middle-income families will expand and simplify eligibility for CSG-FTs, and ensure existing low- and middle-income students continue to receive the assistance they need to pursue a PSE. The incremental impacts presented below reflect the difference between the outcomes of maintaining current grant amounts and the current repayment assistance thresholds under a baseline scenario (i.e. not implementing these Regulations) and the outcomes of implementing the proposed amendments to increasing grant amounts under a proposed scenario.

The parties that would be affected by implementing the regulatory amendments are the GoC, students, businesses, and Canadian society in general. The number of affected students was estimated by taking the annual difference between the estimated total number of students completing PSE and entering repayment if the amendments are implemented and the estimated total number under the baseline scenario. All monetized costs and benefits are estimated on an annual basis over a 10-year period from 2017–2018 (the expected first year of implementation) to 2026–2027. A discount rate of 7%, selected in accordance with Treasury Board Secretariat guidance on cost-benefit analysis has also been applied to all monetized impacts.

Costs

The net costs (i.e. the difference between program expenses and revenues) to the GoC of continuing to provide additional grants under the proposed amendments are based on estimates using CSLP administrative data. Incremental costs were determined by comparing the difference between the net costs under the baseline and the net costs under the proposed amendments. With respect to the implementation of the new eligibility thresholds for CSG-FTs, the net costs to Government is the difference between the cost and the cost savings related to the amount of the grant replacing a student’s CSL and takes into account the cost savings when not disbursing direct loans to eligible students.

Benefits

Quantitative

Low- and middle-income families will directly benefit from simplifying and expanding CSG eligibility, as nearly 145 000 students from these families are estimated to receive more non-repayable assistance, of which approximately 46 000 additional students will be newly eligible for non-repayable CSG-FT. The impact is even greater for low-income families, many of whom simply cannot afford to save for PSE, as this change also expands eligibility for the maximum CSG-FT amount. Benefits to this group were monetized by attributing dollar for dollar the net costs incurred by government related to the additional grant disbursed to students plus the cost of alternative payments paid to the non-participating jurisdictions on these additional grants dollars incurred by the government.

In addition, combined with the rising costs of education, the new progressive thresholds design will lead to greater grant amounts to more students, as eligibility will be expanded. This will benefit students from low- and middle-income families, including members of vulnerable populations, whose participation in PSE can be negatively affected by continued aversion to loan debt. The expansion of the eligibility thresholds or CSG-FTs will enable approximately 1 400 more students each year to complete their studies. Benefits to this group were monetized by examining the earning differentials between full-time employees with PSE and high school graduates. Earning differentials by level of study were estimated using data obtained from the 2006 Census, in particular, median earnings for full year, full-time employees between the ages of 25 to 34. The difference in median earnings relative to persons with high-school diplomas is $13,040 (in 2017 dollars). Based on this result, a modest $13,000 annual income gain in the first year after PSE completion was assumed and a 1.7% of annual growth of real income was applied for subsequent years, reflecting an increase in premiums due to experience and skills acquisition over time. Tuition costs that would be incurred by students who would not be able to pursue PSE without the additional grant amounts are subtracted from increased earnings accrued during the 10-year period under consideration; however, it should be noted that the income gain resulting from PSE attainment accrues for the duration of a student’s lifetime.

Qualitative

A review of available literature suggests that those who attend PSE experience lower rates of unemployment and shorter unemployment spells. They also live longer, healthier lives and pass additional benefits on to their children in the form of better cognitive development, health, and future potential earnings. While many affected students would nonetheless find a way of attending PSE in the absence of the regulatory amendments, the strategies they would employ to do so could entail some costs. For instance, affected students may delay pursuing their studies in the absence of receiving CSG-FT amounts. Consequently, the increased earnings associated with PSE outlined above would also be delayed. Others might finance their studies through an increased reliance on student employment or private credit. However, students who seek employment as a result of not receiving any loans or grants, or increase the number of hours they already work, could be doing so to the detriment of their grades and ability to carry a full course load. Those who would rely on financial assistance from private lenders or credit cards would not benefit from the suite of repayment assistance measures currently offered by the CSLP, making reliance on private credit potentially more expensive. Consequently, the affected groups of students would benefit from being able to forgo these strategies.

Attending PSE creates positive externalities, meaning that the benefits of attaining PSE credentials accrue to others beyond the individual student. For example, businesses benefit from having a more skilled and productive workforce. Studies have also shown that increasing the level of PSE attainment in society can lead to greater innovation and economic growth, increase civic engagement, lower income inequality, and less reliance on public services, such as foster care and juvenile diversion programs.

Results

The results of this analysis are presented below in Table 1 — Cost-benefit statement. Overall, the net benefit of implementing the regulatory amendments is $94 million, with a benefit-cost ratio of 1.07:1, without accounting for quantitative benefits beyond a 10-year period or additional qualitative benefits to students, businesses, and Canadian society. As a result, the cost-benefit analysis concludes that the benefits of implementing the Regulations outweigh the costs to the GoC and students of further increasing CSG amounts and the RAP eligibility thresholds.

Table 1 — Cost-benefit statement

 

First Year: 2017–2018

Final Year: 2026–2027 (see footnote c)

Total
(PV)
(see footnote d)

Annualized Value

A. Quantified impacts (in million Can$, 2017 present value)

Benefits

Increase in transfers to individuals

Individuals

$114

 

$98

$1,386

$197

Future potential earnings over 10-year period, adjusted for tuition costs (see footnote 2)

Individuals

$0

 

$49

$94

$13

Costs

   

Increase in transfers to individuals

Government of Canada

$114

 

$98

$1,386

$197

Net benefits

$94

$13

B. Quantified impacts in non $ (counts)

Positive impacts — Greater availability of skilled workers (number of students who could not pursue studies without this amendment)

Business

0

 

1,454

12,623

Not applicable

C. Qualitative impacts

Individuals

Students who otherwise could not pursue post-secondary education without these Regulations

  • Lower rates of unemployment and shorter unemployment spells due to post-secondary credentials.
  • Greater health and longevity.
  • Intergenerational effects (improved health, effects of education on child development and future earnings of children).

Students who otherwise would delay post-secondary education without these Regulations

  • Can realize benefits of post-secondary education sooner (higher potential earnings and lower rates of unemployment/shorter periods of unemployment).

Students who otherwise would continue their post-secondary education regardless

  • Better academic achievement as they will be able to forgo seeking student employment.
  • Will not be required to rely on private sources of credit.
  • Will benefit from suite of CSLP measures designed to assist students experiencing difficulty with repayment.

Businesses

  • Gain productivity.

Canadian society

  • More innovation and economic growth.
  • Greater civic engagement (volunteerism and charitable contributions).
  • Reduced income inequality.
Gender-based analysis

Research was conducted to analyze the impact the progressive CSG thresholds may have on student grant recipients from various socio-economic backgrounds. The analysis determined that the change will have implications for students from different economic groups, but very little impact based on gender.

The CSLP is unable to provide an impact analysis on Indigenous students, as data is currently not collected on this population. However, this data will start to be collected in the 2017–2018 loan year.

Female and male students will receive similar benefits from the progressive grant thresholds. There will be negligible difference in the benefit to students by institution type, permanent disability status, province, or urban/rural status.

Full-time students, both female and male, aged 21 and under will benefit significantly from the grant increases while students aged 26 and over will benefit the least. While 55% of all student borrowers are 21 and under, 82% of borrowers that will benefit from the new thresholds are from this age group.

Since the lower-income groups in all student categories already receive CSGs, it is the middle-income groups that benefit most from the new CSG thresholds. Also, because income is the critical component of needs assessment, higher income groups receive no benefit from the change.

“One-for-One” Rule

The “One-for-One” Rule does not apply, as there is no change in administrative costs for businesses.

Small business lens

The small business lens does not apply, as there are no costs for small businesses.

Consultation

Employment and Social Development Canada (ESDC) consulted with PT partners throughout spring and summer 2016 to develop the new national progressive thresholds for CSG-LI and CSG-MI, as committed to in Budget 2016. PTs and stakeholder groups, such as the Intergovernmental Consultative Committee on Student Financial Assistance (ICCSFA) and the National Advisory Group on Student Financial Assistance (NAGSFA) were also consulted over the course of 2016. ICCSFA is comprised of federal and PT student aid officials and NAGSFA is comprised of stakeholders, such as PSE student associations, educational organizations, student financial aid administrators and members of the academic community.

PTs, stakeholders, PSE institutions and students have showed overwhelming support for Budget 2016 proposals, including the expansion of CSG eligibility. Only two minor concerns were raised by PTs during consultations and have since been addressed. The first was about the national nature of the new CSG-FT eligibility thresholds. The second was about whether there would be confusion between the new CSG-FT eligibility thresholds and the continuation of the low- and middle-income thresholds set out in Schedule 3 to the CSFAR that would continue to be used to determine eligibility for the CSG-DEP, CSG-PTDEP, CSG-PT and PT-CSL. The first concern was addressed as PTs were satisfied the new eligibility thresholds will treat students more generously and that more students will receive the full CSG-FT amount under the new eligibility thresholds. PTs were also satisfied that there would only be a small risk for confusion as a result of the application of the new and current thresholds given that the majority of CSG recipients (approximately 79%) receive low- and middle-income grants.

The amendment to subsection 23(1) of the CSFAR was made to clarify the Minister’s authority to reconsider repayment assistance applications. As a result of this and the administrative nature of the amendment, no public consultations were required.

Rationale

The new CSG-FT eligibility thresholds will build on a previously implemented commitment made pursuant to Budget 2016 to increase CSG amounts by 50% for low- and middle-income, and part-time students. These amendments will further ensure that students from low- and middle-income families receive help that reflects the rising costs of PSE, while making debt loads more manageable. The introduction of the new CSG-FT eligibility thresholds will improve predictability of non-repayable grant funding and increase transparency. They will also introduce a more equitable approach to the administration of the new CSG-FT by removing the barrier that existed with the former CSG eligibility thresholds where as little as a dollar more in family income could result in a lower grant award or none at all.

It is estimated that the regulatory amendments will give more low- and middle-income students access to upfront, non-repayable assistance, making PSE more affordable for a greater number of these students; approximately 99 000 middle-income students and an estimated 46 000 additional students annually. Students from low- and middle-income families currently represent the vast majority of CSG recipients, and thus increasing this group’s eligibility would broaden the range of individuals including underrepresented groups (e.g. low-income families, Indigenous students, rural youth) who could benefit from CSG funding. Although the implementation of the new eligibility thresholds for CSG-FTs would not have the same real value across the country because of expanded eligibility, it is expected that no students will receive less than they currently do.

In addition, these amendments will address some of the limitations of the two-step thresholds model set out in Schedule 3 to the CSFAR, and thus choosing a new, higher income thresholds offers an opportunity to both enhance and simplify CSG-FT eligibility and disbursement. Finally, the new eligibility thresholds will be more in line with the design of other federal income-tested benefits, such as the new Canada Child Benefit, which does not vary benefit rates by province. Eligibility under the new thresholds is based on a gradual phase-out (or “slope”), adjusted only by family income and family size rather than by family size and province. This, in effect, eliminates the former model’s use of set cut-offs that were used to determine CSG-LI and CSG-MI eligibility and makes SFA more predictable and transparent to students and their families, as they plan for PSE.

The new CSG-FT eligibility thresholds will also be indexed to the CPI and adjusted annually. Prior to the introduction of the new thresholds, an annual regulatory amendment to the thresholds set out in Schedule 3 to the CSFAR was necessary to ensure borrowers remained eligible for CSGs targeted to low- and middle-income students on a yearly basis. Under the new model, regulatory amendments will no longer be required to ensure students remain eligible for CSG-FT as annual adjustments based on the growth in CPI will occur automatically. Since this would have been done via another means, there is no additional benefit to students. However, it will save the GoC time and resources that will no longer need to be allocated to making these annual adjustments to the Regulations.

ESDC’s Evaluation Directorate completed a five-year summative evaluation of the CSLP covering the period from 2006–2007 to 2010–2011, which included the period in which CSGs were introduced. The effect of these changes was included in a report released in May 2016. With respect to CSGs, the report recommended that grants should continue to target disadvantaged groups and that eligibility should be expanded for lower income students to help reduce overall debt loans. In addition to this, the report recommended promoting further awareness of CSGs on the canlearn.ca website, and to enhance understanding of grants to prospective students. The regulatory amendments to the CSFAR address these recommendations by targeting low- and middle-income students and expanding eligibility so that more students benefit from non-repayable SFA. Action to promote CSG awareness has been taken over the course of 2016. For example, the Minister undertook a “Back to School” campaign to promote awareness of Budget 2016 changes, including the announcement to increase CSGs for low- and middle-income and part-time students by 50% that were implemented in August 2016.

The regulatory amendment to subsection 23(1) of the CSFAR will clarify the authority of the Minister to reconsider repayment assistance applications when the prescribed conditions are met. While it is not expected to impact the number of RAP applicants, it will provide clarity for borrowers who would like to have their RAP application reconsidered.

Implementation, enforcement and service standards

The new CSG-FT eligibility thresholds are expected to be in place on August 1, 2017, which marks the commencement of the 2017–2018 loan year.

Grant assessment will continue to be carried out as part of the needs assessment process that is administered on behalf of the CSLP by the participating PTs. Specifically, PTs determine eligibility, maintain necessary records regarding eligibility, and include assessed grant amounts on each applicable student’s certificate of eligibility/ student loan agreement. This information is then transmitted to the National Student Loans Service Centre (NSLSC).

The NSLSC has the responsibility of inputting the information received from the PTs into the loan servicing system. They also apply the appropriate business edits before sending the grant amount information to the CSLP. The grants are disbursed upon confirmation of enrolment prior to the course fees coming due. The full-time and part-time federal disbursement file is then transmitted to the CSLP via Government Telecommunications and Informatics Services (GTIS). The NSLSC must also maintain all necessary records in order to address recipients’ questions. GTIS is a secure electronic data transfer system used to transfer files between the CSLP and the NSLSC.

Service standards will not be affected by the changes, reflecting existing PT need assessment timelines and pre-established commitments on the part of CSLPs service provider.

Costs resulting from PT systems changes needed to implement the new CSG-FT eligibility thresholds are expected to be covered by the administrative fees paid by the GoC to the PTs. These fees are paid to PTs to facilitate the administration or enforcement of the CSLP.

The amendment to subsection 23(1) of the CSFAR is expected to take effect upon registration.

Performance measurement and evaluation

To ensure effective management and accountability to Canadians, federal SFA programs will continue to be monitored to ensure effective program performance and integrity. The resulting data will continue to be included in the CSLP’s Actuarial Report and Annual Report, both of which are tabled in Parliament as per the Canada Student Financial Assistance Act. These reports can also be accessed online by the general public.

The effect of expanding CSG eligibility thresholds for low- and middle-income students will be incorporated into existing performance measurement and evaluation mechanisms. Likewise, the impact of RAP would also be included in performance measurements and evaluations.

Contact

Steven Coté
Director
Policy and Research
Canada Student Loans Program
Employment and Social Development Canada
200 Montcalm Street, Tower II, 1st Floor
Gatineau, Quebec
K1A 0J9
Telephone: 819-654-8775
Fax: 819-654-8397
Email: steven.f.cote@hrsdc-rhdcc.gc.ca