An independent audit report
bcauditor.com
November 2020
OVERSIGHT OF INTERNATIONAL
EDUCATION PROGRAMS IN
OFFSHORE AND GROUP  SCHOOLS
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AUDITOR GENERAL OF BRITISH COLUMBIA | NOVEMBER 2020 | OVERSIGHT OF INTERNATIONAL EDUCATION PROGRAMS IN OFFSHORE AND GROUP 4 SCHOOLS
TRANSMITTAL LETTER
e Honourable Raj Chouhan
Speaker of the Legislative Assembly
Province of British Columbia
Parliament Buildings
Victoria, British Columbia
V8V 1X4
Dear Mr. Speaker:
I have the honour to transmit to the Speaker of the Legislative Assembly of British Columbia
the report Oversight of International Education Programs in Oshore and Group4 Schools.
We conducted this audit under the authority of section 11(8) of the Auditor General Act. All
work in this audit was performed to a reasonable level of assurance in accordance with the
Canadian Standard on Assurance Engagements (CSAE) 3001—Direct Engagements, set out by
the Chartered Professional Accountants of Canada (CPA Canada) in the CPA Canada
Handbook—Assurance.
Michael A. Pickup, FCPA, FCA
Auditor General of British Columbia
Victoria, B.C.
January 2021
CONTENTS
Report highlights 4
Auditor General’s comments 5
Audits at a glance 7
Summary 9
Why we did these audits 10
What we found 11
Summary of recommendations 16
Oshore schools 16
Group 4 schools 17
Response from the auditee 18
About the audits 23
Background 23
International education in B.C. 23
Oshore schools 25
Group 4 schools 27
Why we did these audits 28
Audit scope 29
Audit method 30
Oshore schools—audit objective and conclusion 32
Audit objective 32
Audit conclusion 32
Oshore schools—key findings and recommendations 34
Certification 34
Certification requirements for oshore schools address key educational
areas of responsibility 35
Certification requirements address oshore school operator responsibilities,
but do not provide enough information to adequately assess business risks 36
The ministry confirms that oshore schools meet certification requirements 41
Compliance monitoring 41
The ministry monitors ongoing compliance with certification requirements 42
Monitoring processes do not always focus on key risks 43
Performance monitoring 45
The ministry monitors performance reporting by oshore schools 46
Group 4 schools—audit objective and conclusion 48
Audit objective 48
Audit conclusion 48
Group 4 schools—key findings and recommendations 49
Certification 49
Certification requirements for Group 4 schools address key educational
areas of responsibility 50
Certification requirements address Group 4 school operator responsibilities,
but do not provide enough information to adequately assess business risks 52
The ministry confirms that Group 4 schools meet certification requirements 54
Compliance monitoring 54
The ministry monitors ongoing compliance with certification requirements 55
Monitoring processes do not always focus on key risks 56
Performance monitoring 57
The ministry monitors performance reporting by Group 4 schools 58
Audit quality assurance 60
Appendix A: Complete audit criteria 61
CONTENTS
The Ofce of the Auditor General of British Columbia would like to acknowledge with respect that we conduct our
work on Coast Salish territories. Primarily, this is on the Lkwungen-speaking people’s (Esquimalt and Songhees)
traditional lands, now known as Victoria, and the W
̱
SÁNEĆ people’s (Pauquachin, Tsartlip, Tsawout, Tseycum)
traditional lands, now known as Saanich.
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AUDITOR GENERAL OF BRITISH COLUMBIA | NOVEMBER 2020 | OVERSIGHT OF INTERNATIONAL EDUCATION PROGRAMS IN OFFSHORE AND GROUP 4 SCHOOLS
Over
$
4.7 billion
contributed to the economy
Over
35,000 jobs
supported
Eective oversight is critical to ensuring schools meet ministry
expectations and maintain B.C.’s positive international education reputation.
MINISTRY OVERSIGHT
IS EFFECTIVE
with limitations:
e ministry does not get enough long-term
business planning information from operators
to assess their capacity to sustainably deliver B.C.
education programs
e ministry does not collect enough
information on foreign regulations to
understand how schools will demonstrate they are
meeting ministry expectations
e ministry does not get enough long-term
business planning information from operators
to assess their capacity to sustainably deliver B.C.
education programs
Oshore schools
Group 4 schools
Oshore and Group 4 schools are
important to international education
in B.C.
Graduation from a B.C. K–12
education program is a pathway
to post-secondary international
education in B.C.
Oshore and Group 4 schools
enrol over 40% of international
students learning B.C. K–12
education programs
Oshore and Group 4 schools
enrol over 40% of international
students learning B.C. K–12
education programs
40%
The delivery of international education
services is a top export area for B.C.
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REPORT HIGHLIGHTS
AUDITOR GENERAL OF BRITISH COLUMBIA K–12 INTERNATIONAL EDUCATION AUDIT | SEPTEMBER 2020 |
REPORT HIGHLIGHTS
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AUDITOR GENERAL OF BRITISH COLUMBIA | NOVEMBER 2020 | OVERSIGHT OF INTERNATIONAL EDUCATION PROGRAMS IN OFFSHORE AND GROUP 4 SCHOOLS
International education has become increasingly important to B.C.’s economy and
educational goals over the past 20 years. In 2017, more than 150,000 international students
studied in B.C. spending $4.7 billion on tuition and living expenses, directly supporting more
than 35,000 jobs in the province.
During the 2018/19 school year, more than 30,000 international students were enrolled in
Kindergarten to Grade 12 (K–12) education programs. Graduation from a K–12 education
program is a pathway to a post-secondary education in B.C.
ere are two types of B.C.-certified schools that cater almost exclusively to K–12 international
students: oshore and Group4.
Oshore schools provide B.C. education programs outside Canada
Group4 schools are independent schools operating in B.C.
About this report
Protecting the quality and reputation of B.C.’s education system is critical to preserving both
the flow of international students into B.C. and the continuation of economic benefits to
the province from international education. We chose to audit oshore and Group4 schools
at the same time because they are the only types of K–12 schools that operate with a for-
profit business model and because more than 40% of international students participating
in B.C. education programs at the K–12 level are enrolled in one of these types of schools. By
examining them together, there was an opportunity to review and learn from dierences in
the certification requirements for each type of school.
What we found
We found that the Ministry of Education’s oversight of both oshore and Group4 schools
was eective, except for identified limitations in certification requirements related to
obtaining business information from applicant school operators. is means that ministry
certification and monitoring processes are eective in ensuring that certified oshore and
Group4 schools are delivering B.C. education programs that meet ministry expectations.
AUDITOR GENERAL’S
COMMENTS
MICHAEL A. PICKUP, FCPA, FCA
Auditor General of British Columbia
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AUDITOR GENERAL OF BRITISH COLUMBIA | NOVEMBER 2020 | OVERSIGHT OF INTERNATIONAL EDUCATION PROGRAMS IN OFFSHORE AND GROUP 4 SCHOOLS
AUDITOR GENERAL'S COMMENTS
However, the ministry needs more business information to be able to assess whether
applicant school operators have the capacity to sustainably deliver quality B.C. education
programs in the competitive international education environment.
We made eight recommendations: four to improve oversight of oshore schools and four to
improve oversight of Group4 schools. Our recommendations include:
Requiring both oshore and Group4 school operators to provide more comprehensive
business plan information to demonstrate their ability to sustainably deliver B.C.
education programs over time
Reviewing and updating the compliance monitoring model for both oshore and
Group4 schools to focus on key risks
Monitoring and assessing the overall performance of oshore schools and Group4
schools to identify and compare performance trends
For more information, see Audits at a Glance.
Looking ahead
Aer reading this report, you may want to consider asking the following questions
of government:
1. Will the COVID-19 pandemic have long-term impacts on the delivery of B.C. education
programs to international students in oshore and Group4 schools?
2. Given their similar business models and risks, should the ministry work to beer align
the financial requirements for oshore and Group4 schools?
3. Are the bonding requirements for Group4 schools sucient to protect the interests of
international students and school sta in the event of a school closure?
Acknowledgements
I would like to thank the ministry sta for their assistance throughout the audit, and their
commitment to continuous improvement in their oversight processes. We are particularly
grateful for the patience and co-operation from the ministry as we worked through the
challenges posed by the pandemic.
Michael A. Pickup, FCPA, FCA
Auditor General of British Columbia
Victoria, B.C.
November 2020
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AUDITOR GENERAL OF BRITISH COLUMBIA | NOVEMBER 2020 | OVERSIGHT OF INTERNATIONAL EDUCATION PROGRAMS IN OFFSHORE AND GROUP 4 SCHOOLS
AUDITS AT A GLANCE
Why we did these audits
K–12 schools are a pathway for international students to B.C. post-secondary institutions
e quality of this education can impact the reputation of the B.C. education system
Oshore and Group4 schools enrol over 40% of all K–12 international students
During the period of our audit, there were 45 oshore schools with 11,650 students and 24
Group4 schools with 2,622 students
Purpose of the audits
To determine whether the Ministry of Education provides eective oversight of the
delivery of education programs by oshore schools
To determine whether the Ministry of Education provides eective oversight of the
delivery of education programs by Group4 schools
Overall audit conclusions
e Ministry of Education’s oversight of oshore and Group4 schools is eective
e audits identified minor shortcomings and incomplete oversight of business risks for
both types of schools
We made eight recommendations: four to improve oversight of oshore schools
and four to improve oversight of Group4 schools. e ministry has accepted all
recommendations.
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AUDITOR GENERAL OF BRITISH COLUMBIA | NOVEMBER 2020 | OVERSIGHT OF INTERNATIONAL EDUCATION PROGRAMS IN OFFSHORE AND GROUP 4 SCHOOLS
AUDITS AT A GLANCE
RECOMMENDATIONS 5, 6 RECOMMENDATION 7 RECOMMENDATION 8
Group 4 schools
Certification requirements cover school
educational responsibilities and school
operator responsibilities
School operators provide information on
municipal compliance, financial surety bonds
School operators are not required to submit
business plans or longer-term financial
information
Schools are not required to assess English
language proficiency of new students
3-step annual monitoring completed: schools
report, on-site inspection, ministry follow-up of
compliance issues needing correction
Schools inspected as required by qualified
Inspection Chair
School corrections followed up and confirmed
before certificate renewed
High volume of documents makes critical
review of school responses to inspection issues
challenging
Ministry tells schools the annual performance
reporting requirements
Schools provide information on student
achievement, graduation and transition rates
5-year trend data shared with schools to
support beer delivery of education programs
Data used to evaluate individual schools
Ministry does not regularly evaluate the
collective performance of Group4 schools
Certification
Ministry confirms new schools meet
certification requirements before being
certified, but does not adequately assess
business capacity of school operators
Compliance monitoring
Ministry monitors schools for ongoing
compliance with requirements
Performance monitoring
Ministry monitors school performance
RECOMMENDATIONS 1, 2 RECOMMENDATION 3 RECOMMENDATION 4
What we found
Oshore schools
Certification requirements cover school
educational responsibilities and operator
responsibilities
School operators are not required to submit
enough long-term business information
School operators are not required to provide
enough information on local regulatory
processes
School operators do not always fully translate
compliance documents
3-step annual monitoring completed: schools
report, on-site inspection, ministry follow-up of
compliance issues needing correction
Schools inspected as required by qualified
Inspection Chair
School corrections followed up and confirmed
before certificate renewed
Pending teacher certifications and priority
suggestions not identified for follow-up
Growth in number of schools impacting time
for review
Ministry tells schools the annual performance
reporting requirements
Schools provide information on student
achievement, graduation and transition rates
5-year trend data shared with schools to
support beer delivery of education programs
Data used to evaluate individual schools
Ministry not assessing progress on goals of B.C.
Global Education Program
Certification Compliance monitoring Performance monitoring
Ministry confirms new schools meet
certification requirements before being
certified, but does not adequately assess
business capacity of school operators
Ministry monitors schools for ongoing
compliance with requirements
Ministry monitors school performance
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AUDITOR GENERAL OF BRITISH COLUMBIA | NOVEMBER 2020 | OVERSIGHT OF INTERNATIONAL EDUCATION PROGRAMS IN OFFSHORE AND GROUP 4 SCHOOLS
SUMMARY
In the past 20 years, the market for international education has grown significantly and become
increasingly profitable and competitive. e reported benefits of international education—for
students, host countries and countries of origin—are many, including economic benefits for
host countries, cultural exchange, establishing relationships and furthering knowledge and skill
development. However, the social and economic opportunities of international education are
also susceptible to external shocks from changes in the global landscape.
To succeed in such a market, schools that deliver international education must both earn
and maintain an international reputation for high educational standards. British Columbia
has proven itself to be a top competitor in aracting international students. Approximately
one-quarter of all international students, at all levels of study across Canada, study in
B.C. In 2017, according to the most current data available, more than 150,000 international
students studied in B.C. and spent $4.7 billion on tuition and living expenses. e majority
(86%) were enrolled at the post-secondary level, with a smaller number (14%) studying at the
Kindergarten to Grade 12 (K–12) level in public and independent schools in B.C. In addition,
international students were studying in B.C.-certified oshore schools.
ere are only two types of K–12 schools that operate with a for-profit business model: B.C.-
certified oshore schools that operate outside Canada, and Group4 independent schools
(Group4 schools) that operate in B.C. ese schools recruit and cater almost exclusively to
K–12 international students and are certified by the Ministry of Education to deliver B.C.
education programs. e first B.C.-certified oshore school was founded in 1998 in Dalian,
China, under the authority of the School Act. e first Group4 school was certified in 1989,
when the Independent School Act came into force. During the 2018/19 school year, the Ministry
of Education was responsible for regulating the delivery of B.C. education programs at 45
oshore schools, operating in seven countries, and 24 Group4 schools operating in B.C.
Although oshore and Group4 schools operate under the authority of dierent legislation, the
process for becoming certified and the ongoing monitoring processes are similar. Both types of
schools are subject to inspections, by ministry-qualified school inspectors, to ensure they are
delivering the B.C. curriculum and operating in a way that meets the ministry’s expectations.
Where these schools dier is in their financial relationship with the Ministry of Education.
Oshore schools pay a licensing fee to deliver the B.C. curriculum and an annual fee for each
student participating in the education program. ey are also required to reimburse the
ministry for all school inspection costs. Group4 schools do not pay any fees to deliver the
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AUDITOR GENERAL OF BRITISH COLUMBIA | NOVEMBER 2020 | OVERSIGHT OF INTERNATIONAL EDUCATION PROGRAMS IN OFFSHORE AND GROUP 4 SCHOOLS
SUMMARY
B.C. curriculum and, as with all independent schools in B.C., are not required to reimburse
the ministry for school inspection costs. However, Group4 schools are required to place a
minimum $100,000 financial bond with the ministry to provide some protection for students
should the school close for any reason. Because oshore schools operate outside Canada, no
similar bonding requirement has been established for oshore schools.
Although oshore and Group4 schools are certified to deliver the K–12 curriculum, most
focus on delivering the curriculum for Grades 10 to 12 as part of a graduation program.
Graduation from a B.C. education program is seen as a pathway to post-secondary education
in the student’s destination of choice.
Why we did these audits
We carried out these audits to determine whether the Ministry of Education provides
eective oversight of the delivery of B.C. education programs in oshore and Group4 schools.
We chose to audit the ministry’s oversight of oshore schools and Group4 schools at the
same time because of the similarity in their for-profit business models and because of the
importance of these schools to developing pathways for international students to B.C.
post-secondary institutions.
Both types of schools also face similar financial risks and operational challenges, and
conducting the audits concurrently provided an opportunity to identify similarities and
dierences in certification requirements. e insights from these two audits provide
the ministry with an opportunity to consider the impact of dierences in certification
requirements, including how the dierent fee structures and bonding requirements work to
support eective ministry oversight and protect the interests of international students and
school sta.
Eective oversight is central to ensuring that certified oshore and Group4 schools are
delivering education programs that meet ministry expectations and support the positive
international reputation that B.C.’s education system enjoys. e failure of an oshore or
Group4 school, whether for financial reasons, non-compliance with local licensing laws or
non-compliance with ministry requirements, would negatively impact students and B.C.-
certified teachers, and could potentially aect the reputation of the Ministry of Education.
Rigorous oversight by the ministry, and the ability to revoke a school’s certification, can
serve to maintain the ministry’s reputation. Protecting the quality and reputation of B.C.’s
education system is critical to preserving both the flow of international students into B.C.
and the continuation of economic benefits to the province from international education.
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AUDITOR GENERAL OF BRITISH COLUMBIA | NOVEMBER 2020 | OVERSIGHT OF INTERNATIONAL EDUCATION PROGRAMS IN OFFSHORE AND GROUP 4 SCHOOLS
SUMMARY
What we found
In each audit, we found that the ministry’s oversight focused on ensuring the delivery of B.C.
education programs through processes to:
confirm that new schools meet ministry business and educational requirements before
they are certified
monitor ongoing compliance with certification requirements
monitor school performance
We concluded that, except for the limitations in initial certification requirements related to
obtaining business and financial information, the ministry’s oversight of both oshore and
Group4 schools was eective. Our findings and observations regarding ministry processes
for certification, compliance monitoring and performance monitoring are presented in the
following three sections.
Certification
An important element in the eective oversight of schools is clearly defined requirements
that must be met before a school can be certified to deliver a B.C. education program. We
looked to see, for both oshore schools and Group4 schools, whether the Ministry of
Education had:
established certification requirements that address the five areas of responsibility for
schools delivering B.C. education programs, as listed in the Statement of Education
Policy Order
established certification requirements that address the responsibilities of applicant
school operators to be in good standing and to have the business plans and financial
resources to operate their school
confirmed that applicant schools met certification requirements before certifying them
for the first time
Certification requirements for schools address key educational areas of responsibility
For both oshore and Group4 schools, we found that the ministry had established
requirements that address the five areas of responsibility for schools delivering B.C.
education programs, as listed in the Statement of Education Policy Order:
school finance and facilities
program direction, development and implementation
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AUDITOR GENERAL OF BRITISH COLUMBIA | NOVEMBER 2020 | OVERSIGHT OF INTERNATIONAL EDUCATION PROGRAMS IN OFFSHORE AND GROUP 4 SCHOOLS
SUMMARY
student access and achievement
teaching performance
system evaluation and public accountability
We did note one important dierence between the certification requirements for oshore
schools and Group4 schools. Oshore schools are required to have a process for assessing
new students’ English language abilities, but Group4 schools are not. A requirement to assess
the English language abilities of international students entering a Group4 school would
provide schools with information on what English language learning supports are necessary
to set their students up to successfully complete their programs.
Certification requirements address school operator responsibilities but do not provide
enough information to adequately assess business risks
For both oshore and Group4 schools, we found that the ministry has established
certification requirements that address the responsibility of school operators to be in good
standing with local regulations and to have the financial resources to open their schools. We
looked at documents that demonstrated school compliance with local laws and licensing
requirements, and business information such as planned enrolment levels and financial
statements. However, we found that the ministry does not require sucient detailed
information from applicant school operators to inform an assessment of the business and
financial risks that could impact the capacity of school operators to deliver B.C. education
programs over the longer term, consistent with the ministry’s goals and expectations.
In recent years, with the growth in the number of both oshore and Group4 schools,
competition for students and teachers has increased. Today, international school operators
are running a business in a highly competitive international education market and need to
be in a position to enrol enough students, recruit and retain enough B.C.-certified teachers,
and invest funds where necessary to support delivery of a quality education program. In this
competitive environment, both oshore and Group4 school operators are at risk of not being
able to maintain the financial capacity to sustain school operations.
Oshore schools
We found that the business and financial information required from oshore school
operators is not sucient for the ministry to assess the financial sustainability of schools or
to understand local laws and licensing requirements relevant to each oshore school.
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AUDITOR GENERAL OF BRITISH COLUMBIA | NOVEMBER 2020 | OVERSIGHT OF INTERNATIONAL EDUCATION PROGRAMS IN OFFSHORE AND GROUP 4 SCHOOLS
SUMMARY
Although applicant oshore school operators are required to provide the ministry with
annual business plans, audited financial statements and some financial forecasts, we found
these were not sucient for the ministry to assess whether applicant school operators were
in a position to sustainably deliver B.C. education programs in the competitive international
education environment.
Further, school operators are not required to provide the ministry with detailed information
von local regulatory processes. Without this information, it is dicult for the ministry to
understand how unique local regulations relate to ministry requirements and to determine
what evidence is required from each school to demonstrate compliance with ministry
requirements, both at the time of initial certification and in subsequent years. For example,
local regulations for building safety and criminal record checks are unique to each foreign
jurisdiction, so the evidence necessary to demonstrate compliance with ministry safety
requirements will be unique for each oshore school.
Group 4 schools
We found that the ministry has established certification requirements that address school
operator responsibilities, including that a Group4 school operator be in good standing with
the Registrar of Companies and in compliance with municipal zoning requirements. However,
the ministry does not gather enough business and financial information from applicant
Group4 school operators to assess whether they have the business plans and financial
resources to sustainably deliver B.C. education programs.
The ministry confirms that schools meet certification requirements before certifying
them for the first time
We examined the initial certification documents for 12 oshore schools and six Group4
schools. Despite some gaps in ministry records, we concluded that the ministry’s initial
certification processes for both oshore and Group4 schools confirm that new school
operators meet established requirements before they are certified for the first time.
Compliance monitoring
Two important elements of eective oversight are a process to monitor ongoing compliance
with certification requirements, and a mechanism to initiate corrective action when issues
are identified. We looked to see whether the ministry monitors both oshore and Group4
schools for compliance with certification requirements. We also looked to see whether the
ministry takes corrective action when a school is not compliant with those requirements.
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AUDITOR GENERAL OF BRITISH COLUMBIA | NOVEMBER 2020 | OVERSIGHT OF INTERNATIONAL EDUCATION PROGRAMS IN OFFSHORE AND GROUP 4 SCHOOLS
SUMMARY
Oshore schools
We found that the ministry monitors compliance through regular reporting from oshore
schools and annual on-site school inspections that are completed by qualified inspection
teams. When issues are reported by school inspectors for follow-up, the ministry takes
corrective actions to bring schools into compliance. However, we did observe that current
reporting procedures for oshore school inspections result in inspector suggestions for
improvement and pending teacher certifications not being tracked and followed up. We also
found that with the growth in the number of oshore schools over time, the monitoring
process has become more administratively onerous, reducing ministry time available for
critical review of areas of concern or risk.
Group 4 schools
e ministry monitors compliance through regular reporting from Group4 schools and on-
site school inspections. We found that all external evaluations and monitoring inspections
were completed as expected and carried out by qualified inspection teams. When issues are
reported by school inspectors for follow-up, we found that the ministry takes corrective
actions to bring schools into compliance. However, the inspection and follow-up process
involves a significant volume of documents, and the increase in the number of Group4
schools since 1989 has resulted in an administrative burden that limits the sta time available
to critically review the information submied, and to identify potential risks to the ongoing
success of schools.
Performance monitoring
An important element of eective oversight is monitoring school performance data to
understand how schools are doing and to identify opportunities for improvement. We looked
to see if the Ministry of Education had established and communicated performance reporting
requirements for oshore and Group4 schools, and whether the ministry used reported
performance data to evaluate the delivery of B.C. education programs by oshore and
Group4 schools.
Oshore schools
We found that the ministry has established and communicated performance reporting
requirements for oshore schools, and that schools consistently submit required performance
reports, including information on student achievement, graduation rates and transitions to
post-secondary schools. We also found that the ministry uses reported performance data to
evaluate the delivery of education programs by individual oshore schools.
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AUDITOR GENERAL OF BRITISH COLUMBIA | NOVEMBER 2020 | OVERSIGHT OF INTERNATIONAL EDUCATION PROGRAMS IN OFFSHORE AND GROUP 4 SCHOOLS
SUMMARY
While the ministry uses performance data to assess oshore schools as a program area, it
does not assess the performance of oshore schools against the goals of the B.C. Global
Education Program (Oshore School Program).
Group 4 schools
We found that the ministry has established and communicated performance reporting
requirements for Group4 schools, and that schools consistently submit required performance
reports, including information on student achievement, graduation rates and transitions
to post-secondary schools. We also found that the ministry uses reported performance
data to evaluate the delivery of education programs by individual Group4 schools but does
not formally evaluate the performance of Group4 schools as a unique group within the
independent school sector.
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AUDITOR GENERAL OF BRITISH COLUMBIA | NOVEMBER 2020 | OVERSIGHT OF INTERNATIONAL EDUCATION PROGRAMS IN OFFSHORE AND GROUP 4 SCHOOLS
SUMMARY OF RECOMMENDATIONS
Oshore schools
We recommend that the Ministry of Education:
as part of the oshore school application process:
expand current information requirements to include a comprehensive five-
year business plan, with detailed financial forecasts based on projected student
enrolment and B.C.-certified teacher stang levels, and
enhance its review of submied business plans and financial forecasts to confirm
that school operators have demonstrated their capacity to deliver B.C. education
programs over an extended period, consistent with the ministry’s goals and
expectations
require oshore school operators to provide detailed, translated information on local
regulatory processes so that the ministry is able to understand how local regulations
relate to ministry requirements and to determine what evidence is required from
each school to demonstrate compliance, both at the time of initial certification and in
subsequent years
review and update its compliance monitoring model for oshore schools to:
require inspectors to report pending teacher certifications and any significant
suggestions for improvement as requirements to ensure they are tracked and
resolved before the next inspection cycle
rationalize the volume of documents required in order to reduce administrative
eort, and
ensure sucient time is allocated to review business issues that could impact the
sustainability and quality of education programs delivered
use available performance data to evaluate progress in meeting the stated goals of the
B.C. Global Education Program
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AUDITOR GENERAL OF BRITISH COLUMBIA | NOVEMBER 2020 | OVERSIGHT OF INTERNATIONAL EDUCATION PROGRAMS IN OFFSHORE AND GROUP 4 SCHOOLS
SUMMARY OF RECOMMENDATIONS
Group 4 schools
We recommend that the Ministry of Education:
require Group 4 schools to conduct assessments of the English language ability of all
new students to ensure that necessary learning supports are put in place
as part of the Group4 school application process:
require applicant Group4 school operators to provide a comprehensive five-
year business plan, with forecasted student enrolment and teacher recruitment
strategies, and
establish a process to review submied business plans to confirm that school
operators have demonstrated their capacity to deliver B.C. education programs over
an extended period, consistent with the ministry’s goals and expectations
review and update its compliance monitoring model for Group4 schools to:
rationalize the volume of documents required in order to reduce administrative
eort, and
ensure sucient time is allocated to review business issues that could impact the
sustainability and quality of education programs delivered
establish a regular process for evaluating the performance of Group4 schools as a
unique group of independent schools
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AUDITOR GENERAL OF BRITISH COLUMBIA | NOVEMBER 2020 | OVERSIGHT OF INTERNATIONAL EDUCATION PROGRAMS IN OFFSHORE AND GROUP 4 SCHOOLS
RESPONSE FROM THE AUDITEE
e Ministry of Education would like to thank the Auditor General and sta for the Report
on the Oversight of International Education Programs in Oshore and Group4 Schools (the
Report). I appreciate the work of the Auditor General and sta and for the insight provided
from their thorough review.
e Ministry has overseen the delivery of the British Columbia educational program in
certified oshore schools since 1998. Originally starting in 1998 with one school in northeast
China, the Oshore Schools Program has steadily grown and now oversees the delivery of the
BC K-12 curriculum to more than 11,000 students in 8 dierent countries. Within BC, Group4
independent schools create uniquely internationalized learning environments through their
enrolment of both local and international students. Over time, ongoing improvements to
both the Oshore School Program, and the certification/regulation of Group4 schools, have
been implemented to enhance program oversight and support student success.
International education enriches the BC K-12 education system and our communities
by providing students, teachers and citizens with opportunities and access to diverse
perspectives. It also makes significant contributions to BC’s economy. In keeping with
its commitment to continuous improvement, the Ministry will continue to pursue every
opportunity to further enhance educational excellence and administrative rigour across all its
international education programs.
e Report’s finding that the Ministry of Education provides eective oversight of both oshore
schools and Group4 schools acknowledges and validates these eorts. e Report also remarks on
the Ministry’s work to continuously evolve and improve program oversight, which will continue in
the spirit of ensuring the intent of the Report’s recommendations is achieved.
RECOMMENDATION 1: We recommend that the Ministry of Education, as part of
the oshore school application process:
expand current information requirements to include a comprehensive five-
year business plan, with detailed financial forecasts based on projected student
enrolment and B.C.-certified teacher stang levels, and
enhance its review of submied business plans and financial forecasts to confirm
that school operators have demonstrated their capacity to deliver B.C. education
programs over an extended period, consistent with the ministry’s goals and
expectations.
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AUDITOR GENERAL OF BRITISH COLUMBIA | NOVEMBER 2020 | OVERSIGHT OF INTERNATIONAL EDUCATION PROGRAMS IN OFFSHORE AND GROUP 4 SCHOOLS
RESPONSE FROM THE AUDITEE
RECOMMENDATION 6: We recommend that the Ministry of Education, as part of
the Group4 school application process:
require applicant Group4 school operators to provide a comprehensive five-
year business plan, with forecasted student enrolment and teacher recruitment
strategies, and
establish a process to review submied business plans to confirm that school
operators have demonstrated their capacity to deliver B.C. education programs
over an extended period, consistent with the ministry’s goals and expectations.
RECOMMENDATIONS 1 AND 6 RESPONSE – ACCEPTED: e Ministry has already taken
action to introduce more robust business planning requirements as part of its Oshore
School and Group4 School application processes. Oshore School applicants are now
required to submit a 5-year growth plan which includes details about the school’s projected
enrolment, teacher recruitment plans, grade level expansion and, for purpose-built facilities, a
timeline for completion of the campus.
Group4 school applicants are now similarly required to submit 5-year business plans
that include a Market Feasibility Study, 5-year Sustainability Plan, Financial Plan, Human
Resources Plan (including ensuring an adequate supply of BC certified teachers), and
Marketing and Student Recruitment Plan.
Independent school certification (for all groups of independent schools) verifies compliance
with the requirements of the Independent School Act (ISA) and regulations, including
demonstration of the delivery of a sound educational program. As per the ISA, certification is
not contingent on a school’s continued financial viability. In response to Recommendation Six,
the Ministry will, however, review the amount of bonding required by Group4 schools and
current policy regarding licensing and inspection fees for Group4 schools to determine what
is in the best interest of BC citizens.
RECOMMENDATION 2: We recommend that the Ministry of Education require
oshore school operators to provide detailed, translated information on local
regulatory processes so that the ministry is able to understand how local regulations
relate to ministry requirements and to determine what evidence is required from
each school to demonstrate compliance, both at the time of initial certification and in
subsequent years.
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AUDITOR GENERAL OF BRITISH COLUMBIA | NOVEMBER 2020 | OVERSIGHT OF INTERNATIONAL EDUCATION PROGRAMS IN OFFSHORE AND GROUP 4 SCHOOLS
RESPONSE FROM THE AUDITEE
RECOMMENDATION 2 RESPONSE – ACCEPTED: e Ministry is commied to reviewing
this recommendation while continuing to recognize and respect local business and cultural
practices. e Ministry already requires confirmation of this compliance and will continue
to require Oshore Schools to submit documents and translations that demonstrate schools
meet local regulatory requirements. e Ministry will also continue to require that oshore
schools provide copies of local teacher certification documents and criminal record checks for
local teachers and teacher assistants.
RECOMMENDATION 3: We recommend that the Ministry of Education review and
update its compliance monitoring model for oshore schools to:
require inspectors to report pending teacher certifications and any significant
suggestions for improvement as requirements to ensure they are tracked and
resolved before the next inspection cycle
rationalize the volume of documents required in order to reduce administrative
eort, and
ensure sucient time is allocated to review business issues that could impact the
sustainability and quality of education programs delivered.
RECOMMENDATION 7: We recommend that the Ministry of Education review and
update its compliance monitoring model for Group4 schools to:
rationalize the volume of documents required in order to reduce administrative
eort, and
ensure sucient time is allocated to review business issues that could impact the
sustainability and quality of education programs delivered.
RECOMMENDATIONS 3 AND 7 RESPONSE – ACCEPTED: e Ministry now requires
Oshore Schools to report monthly on the status of pending teacher certifications. e
Ministry is also exploring business solutions that would enable more ecient collection
and analysis of school level data. e Ministry agrees there is an opportunity to further
streamline administrative eorts to ensure sucient capacity exists for the thorough review
of issues identified via inspections and/or submied documentation from Oshore and
Group4 schools.
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AUDITOR GENERAL OF BRITISH COLUMBIA | NOVEMBER 2020 | OVERSIGHT OF INTERNATIONAL EDUCATION PROGRAMS IN OFFSHORE AND GROUP 4 SCHOOLS
RESPONSE FROM THE AUDITEE
RECOMMENDATION 4: We recommend that the Ministry of Education use available
performance data to evaluate progress in meeting the stated goals of the B.C. Global
Education Program.
RECOMMENDATION 8: We recommend that the Ministry of Education establish a
regular process for evaluating the performance of Group4 schools as a unique group
of independent schools.
RECOMMENDATIONS 4 AND 8 RESPONSE – ACCEPTED: e Ministry agrees with the
principle of using Oshore School Program and Group4 Independent School data to evaluate
the performance of Group4 and Oshore Schools as unique groups of schools. For both
areas of operation, the Ministry will explore ways to further augment its existing program
evaluation practices.
For Oshore Schools, the Ministry already encourages and tracks the development of
partnerships between oshore schools and schools throughout BC, as well as transitions
of oshore school graduates to BC public post-secondary institutions. For all independent
schools, including Group4 schools, the Ministry has historically analyzed sector outcomes,
including international student outcomes.
RECOMMENDATION 5: We recommend that the Ministry of Education require
Group 4 schools to conduct assessments of the English language ability of all new
students to ensure that necessary learning supports are put in place.
RECOMMENDATION 5 RESPONSE – ACCEPTED: e Ministry will introduce this
requirement for all Group4 schools for the 2021/22 school year. e Ministry agrees that
requiring Group4 schools to conduct assessments of English language ability for all new
students will further advance the Ministry’s mandate of improving student outcomes.
Overall, the Report’s recommendations align with the Ministry’s strategic direction and
priority initiatives, including the Ministry Strategic Framework (2020/21), the Policy for
Student Success, and the Framework for Enhancing Student Learning – all of which prioritize
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AUDITOR GENERAL OF BRITISH COLUMBIA | NOVEMBER 2020 | OVERSIGHT OF INTERNATIONAL EDUCATION PROGRAMS IN OFFSHORE AND GROUP 4 SCHOOLS
RESPONSE FROM THE AUDITEE
evidence-informed decision-making within the education sector to support and improve
student outcomes.
We thank the Oce of the Auditor General for a report that confirms the Ministry’s eective
oversight of Oshore and Group4 schools, and for its specific recommendations that will
support and advance continuous program improvement.
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AUDITOR GENERAL OF BRITISH COLUMBIA | NOVEMBER 2020 | OVERSIGHT OF INTERNATIONAL EDUCATION PROGRAMS IN OFFSHORE AND GROUP 4 SCHOOLS
ABOUT THE AUDITS
Background
International education in B.C.
International education—the two-way flow of students, educators and ideas between
countries—has the potential to open doors to learning and establish positive relationships
around the world. e reported benefits of international education—for students, host
countries and countries of origin—are many, including economic benefits for host countries,
cultural exchange, establishing relationships and furthering knowledge and skill development.
In the past 20 years, the market for international education has grown significantly
and become increasingly profitable and competitive. However, the social and economic
opportunities of international education are also susceptible to external shocks from changes
in the global landscape. Political events or disagreements can cause a country to withdraw its
support of a program operating within its authority or recall its students from their studies
abroad, as when Saudi Arabia announced its plans to withdraw all of its government-funded
post-secondary students studying in Canada in 2018.
Reliance on a single source of international students may expose an educational provider to
sudden loss of income if business, economic or political forces cause a significant decline in
enrolment from that region.
In November 2019, a major oshore school operator, Maple Leaf Education Systems, announced that
12 of its B.C.-certified oshore schools would transition out of the program over the next three school
years, beginning in September 2020. is change will reduce the total number of B.C. oshore schools
by close to a third and the related student population by about 5,500, or nearly 50%. is will result in
an estimated loss of $2.1 million in program recoveries to the ministry.
World economic or health events can cause a global decline in demand for international
education if students can no longer aord the fees or are no longer free to travel. e current
COVID-19 pandemic is a good example of such an event.
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AUDITOR GENERAL OF BRITISH COLUMBIA | NOVEMBER 2020 | OVERSIGHT OF INTERNATIONAL EDUCATION PROGRAMS IN OFFSHORE AND GROUP 4 SCHOOLS
ABOUT THE AUDITS
e declaration of the COVID-19 pandemic on March 11, 2020, has impacted the number of
international students enrolling in B.C. for the 2020/21 school year. According to a news article
published in the Vancouver Sun on May 8, 2020, it is dicult to forecast how many international
students will return to Canada and when. It is expected that global competition for international
students will become fiercer.
Schools that deliver international education must both earn and maintain an international
reputation for high educational standards to succeed in such a market. British Columbia
has proven itself to be a top competitor in aracting international students. Approximately
one-quarter of all international students at all levels of study across Canada study in B.C. In
2010, the provincial government implemented a five-year International Education Strategy
as part of its BC Jobs Plan. According to this plan, international education was B.C.’s fih-
largest export at that time and oered potential for significant economic growth. e five-
year update to the BC Jobs Plan reported that the economic benefits to the province from
international education were:
$3.5 billion spent by international students in 2015
$2.0 billion contributed to the B.C. economy in 2015
29,300 jobs generated in 2015
In 2017, according to the most current data available, more than 150,000 international
students studied in B.C. and spent $4.7 billion on tuition and living expenses. e majority
(86%) were enrolled at the post-secondary level, with a smaller number (14%) studying at the
Kindergarten to Grade 12 level (K–12) in public and independent schools in B.C. In addition,
international students were studying in B.C.-certified oshore schools that operate outside
Canada. In the context of B.C. K–12 schools, international students are defined as those
students who are not normally resident in the province.
Public schools, most independent schools and all oshore schools deliver B.C. education
programs. For the purposes of this report, the term “B.C. education program” means an
education program that must meet the B.C. curriculum and graduation requirements as
determined by the Minister of Education and must be delivered by B.C.-certified teachers. B.C.
education programs must also be delivered in appropriate facilities and supported by sta
that meet the Ministry of Education’s requirements for the physical safety and personal well-
being of students.
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AUDITOR GENERAL OF BRITISH COLUMBIA | NOVEMBER 2020 | OVERSIGHT OF INTERNATIONAL EDUCATION PROGRAMS IN OFFSHORE AND GROUP 4 SCHOOLS
ABOUT THE AUDITS
ere are only two types of K–12 schools that operate with a for-profit business model:
B.C.-certified oshore schools that operate outside Canada, and Group4 independent
schools (Group4 schools) that operate in B.C. Both oshore and Group4 schools recruit and
cater almost exclusively to K–12 international students and are certified by the Ministry of
Education to deliver B.C. education programs.
Oshore schools
rough the B.C. Global Education Program (Oshore School Program), the Ministry of
Education licenses for-profit oshore school operators to deliver the B.C. curriculum to
international students in their home countries. e ministry’s role in overseeing these schools
includes seing goals for the B.C. Global Education Program, establishing educational and
operational requirements for oshore schools and developing policy for the administration of
the program. e B.C. Global Education Program aims to:
increase recognition of B.C.’s high-quality education brand
create opportunities for B.C. schools to develop international partnerships
aract more international students to study and eventually work and live in B.C.
A 2017 study of the B.C. Global Education Program reported that the socio-economic
contributions of the program extend beyond the quantifiable economic activities and include
long-term, broader social and economic benefits enabled by the program, including:
supporting employment of B.C. teachers
enhancing B.C. teachers’ intercultural knowledge and skills
contributing to local businesses in B.C.
aracting international students to B.C. and Canada
facilitating international trade and partnerships
enhancing B.C.’s reputation abroad
e first B.C.-certified oshore school was founded in 1998 in Dalian, China, and until 2005
there were only two oshore schools operating. During the 2018/19 school year, there were 45
oshore schools operating in seven countries. irty-nine of these schools were in China, and
there was one each in Japan, Colombia, Egypt, France, Qatar and ailand. A total of 11,650
students aended these schools, and they employed 747 B.C.-certified teachers. In 2018/19,
the program was expected to continue to expand; two new schools were added in the 2019/20
school year, and another is tentatively scheduled to open in September 2020. Most oshore
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AUDITOR GENERAL OF BRITISH COLUMBIA | NOVEMBER 2020 | OVERSIGHT OF INTERNATIONAL EDUCATION PROGRAMS IN OFFSHORE AND GROUP 4 SCHOOLS
ABOUT THE AUDITS
schools focus their educational programs on the Grades 10 to 12 curriculum, although a few
schools deliver Kindergarten to Grade 12 curriculum.
e Minister of Education is authorized to enter into an agreement with a school
authority outside B.C. under section 168(3) of the School Act. Before an oshore school is
legally permied to deliver the B.C. curriculum, it must undergo a formal application and
certification process. Oshore schools are also subject to ongoing inspections to ensure
they are delivering the B.C. curriculum and operating in a way that meets the ministry’s
expectations. e Ministry of Education is responsible for regulating the delivery of B.C.
education programs at oshore schools.
Oshore schools pay a licensing fee to deliver the B.C. curriculum and an annual fee for each
student participating in the education program. ey are also required to reimburse the
ministry for the costs of all school inspections. Oshore schools are for-profit businesses
operated by private entrepreneurs. In this report, we refer to these oshore school business
operators as school operators.
Overseeing the delivery of B.C. education programs in such a wide variety of foreign jurisdictions is
complex and challenging. One example from Korea illustrates the complexities.
In the spring of 2017, due to reported teacher visa irregularities, the Korean authorities abruptly
detained 14 teachers from one of five B.C.-certified oshore schools operating in that country. All
foreign teachers holding an E-2 visa, including most of the B.C.-certified teachers in Korea, were
ordered to leave the country immediately. Aer a four-month review of the situation, the ministry
removed certification from all five B.C.-certified oshore schools in Korea. ere were indications at
the time that the departure orders were related to increasing enforcement of restrictions on foreign
teachers working in Korea with incorrect visas.
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AUDITOR GENERAL OF BRITISH COLUMBIA | NOVEMBER 2020 | OVERSIGHT OF INTERNATIONAL EDUCATION PROGRAMS IN OFFSHORE AND GROUP 4 SCHOOLS
ABOUT THE AUDITS
Group 4 schools
e Independent School Act specifies four dierent classifications for independent schools in
British Columbia: Groups 1, 2, 3 and 4.
Both Group 1 and Group 2 schools are run by non-profit societies (authorities) and deliver
the B.C. curriculum mostly to students who are B.C. residents. ey receive funding from the
ministry. Group 3 schools are also run by non-profit societies and teach mostly B.C.-resident
students, but they do not necessarily deliver the B.C. curriculum and they do not receive any
funding from the ministry.
Group4 schools are operated as for-profit businesses; in practice, most cater to international
students. Group4 schools receive no funding from the ministry. e ministry refers to the
operators of all independent schools as school authorities. For the purposes of this report, we
refer to Group4 school authorities as school operators, consistent with the terminology used
for oshore schools.
Group4 schools have been certified by the ministry since the Independent School Act came into
force in 1989. For the 2018/19 school year, 24 Group4 schools were operating in B.C., with a total
enrolment of 2,622 students. Most of these schools are concentrated in the Lower Mainland.
Before a Group4 school is legally permied to deliver the B.C. curriculum, it must undergo a
formal application and certification process. Group4 schools, like all independent schools, are
regulated by the Ministry of Education. ey must meet a common set of requirements and
are subject to annual school inspections to ensure they are delivering the B.C. curriculum and
operating in a way that meets the ministry’s expectations.
Group4 schools do not pay any fees to deliver the B.C. curriculum and are not required to
reimburse the ministry for the cost of school inspections. is is consistent with the policy
for all independent schools in B.C. However, unique to Group4 schools, operators are required
to post financial guarantees and maintain valid bonds while they are operating, as well as for
two years aer operations cease, in order to protect international students from financial loss
should a school suddenly close.
Recently, some oshore school operators have begun to partner with public post-secondary
institutions in B.C. to open Group4 independent schools on their campuses. For example,
Maple Leaf Education Systems—one of the oldest and largest of the oshore operators—
has opened two Group4 schools on post-secondary campuses in B.C.: one at Kwantlen
Polytechnic University and the other at ompson Rivers University.
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AUDITOR GENERAL OF BRITISH COLUMBIA | NOVEMBER 2020 | OVERSIGHT OF INTERNATIONAL EDUCATION PROGRAMS IN OFFSHORE AND GROUP 4 SCHOOLS
ABOUT THE AUDITS
Why we did these audits
For international students, graduation from a B.C. education program is seen as a pathway
to post-secondary education in their destination of choice. Although oshore and Group4
schools are certified to deliver the K–12 curriculum, most focus on delivering the curriculum
for Grades 10 to 12 as part of a graduation program. To meet B.C. graduation requirements and
be awarded a British Columbia Certificate of Graduation (Dogwood Diploma), students must
earn required credits in Grade 10, 11 and 12 courses and write provincial numeracy and literacy
assessments. A Dogwood Diploma is recognized by post-secondary institutions in B.C., in
other Canadian provinces and around the world. e K–12 sector, and particularly oshore
and Group4 schools, have the potential to contribute to the number of international students
coming to provincial post-secondary–level programs. International students who’ve earned a
Dogwood Diploma are provided with a clear pathway by which to enter B.C. post-secondary
institutions and to then possibly stay and work in B.C.
Together, oshore schools and Group4 schools enrol over 40% of all K–12 international
students in B.C. education programs, as seen below.
EXHIBIT 1: Number of K–12 international students (2018/19)
Source: Oce of the Auditor General of British Columbia, per Ministry of Education data
0
5,000
10,000
15,000
20,000
25,000
Public schools
Groups 1-3 schools
Oshore schools
Group 4 schools
16,395
11,650
2,022
2,854
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AUDITOR GENERAL OF BRITISH COLUMBIA | NOVEMBER 2020 | OVERSIGHT OF INTERNATIONAL EDUCATION PROGRAMS IN OFFSHORE AND GROUP 4 SCHOOLS
ABOUT THE AUDITS
e economic contributions from international education, at both the post-secondary and
K–12 level, are significant to B.C.’s economy. e quality of education programs delivered by
oshore and Group4 schools can significantly impact the reputation of the B.C. education
system worldwide. ey are central to B.C.’s eorts to promote the province as a destination
of choice for international students entering post-secondary studies. At the same time,
operators of oshore and Group4 schools are running businesses in a highly competitive
international market, and their ability to aract and retain students, recruit B.C.-certified
teachers and invest funds where necessary to maintain quality is key to their success.
We decided to audit the ministry’s oversight of oshore schools and Group4 schools at
the same time because of the importance of these schools to developing pathways for
international students into B.C. post-secondary institutions, and because of the similarity
in their business models: both operate as for-profit businesses that deliver B.C. education
programs to international students. Eective oversight is critical to ensuring that certified
oshore and Group4 schools are delivering education programs that meet the expectations
of the ministry and support the positive international reputation that B.C.’s education system
enjoys. e failure of an oshore or Group4 school, whether for financial reasons, non-
compliance with local licensing requirements or non-compliance with ministry requirements,
would negatively impact students and B.C.-certified teachers, and could potentially aect the
reputation of the Ministry of Education. Rigorous oversight by the ministry, and the ability
to revoke a school’s certification, can serve to maintain the ministry’s reputation. Protecting
the quality and reputation of B.C.’s education system is critical to preserving both the flow
of international students into B.C. and the continuation of economic benefits to the province
from international education as a whole.
Audit scope
In these performance audits, we focused on the Ministry of Education’s certification and
oversight of both oshore schools and Group4 independent schools, as they are the primary
providers of B.C. education and graduation programs at the K–12 level for international
students. e audits looked at initial certification requirements, ongoing monitoring of
compliance with ministry requirements, and the collection and use of school data to help the
ministry evaluate the delivery of education programs by these schools. We did not include
B.C. public schools and other B.C. independent schools that also serve international students
in the scope of these two audits. We also did not look at international education provided
through post-secondary institutions in the province.
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AUDITOR GENERAL OF BRITISH COLUMBIA | NOVEMBER 2020 | OVERSIGHT OF INTERNATIONAL EDUCATION PROGRAMS IN OFFSHORE AND GROUP 4 SCHOOLS
ABOUT THE AUDITS
Although certification of oshore and Group4 schools requires that most teachers be
certified by the Teacher Certification Branch (TCB), we did not include the activities of the
TCB in our audit scope. Further, we did not include in the scope of this audit any other B.C.
government entities or agents operating in the field of international education.
e period of our audits covered three inspection years for Group4 schools (2015/16 to 2018/19)
and four inspection years for oshore schools (2014/15 to 2018/19). e dierences in audit
periods reflect a dierence in school inspection cycles for the two categories of schools.
e six Group4 schools in our sample were first certified between 1989 and 2018, and the 12
oshore schools in our sample were first certified between 2004 and 2018. To understand
the initial certification process for each school in our sample, the audit team obtained and
reviewed documentation that covered a time frame of almost 30 years.
Audit method
Our work for both audits consisted of three main activities:
1. Walk-throughs of business processes to understand Ministry of Education activities as
they relate to establishing certification requirements, initial certification and ongoing
monitoring of oshore and Group4 schools.
2. Inspection of relevant documents from a sample of oshore and Group4 schools to
verify whether the ministry’s certification, monitoring and reporting processes had
been followed consistently throughout the period of our audit. We reviewed over 3,000
ministry documents.
e sample oshore and Group4 schools were selected from those identified by the
ministry as operating in the 2018/19 school year:
From a total of 45 oshore schools, we selected 12, or about 25% of all oshore
schools. is sample included schools from all seven countries where the
ministry had certified schools, and about 40% of the total oshore student
population.
From a total of 24 Group4 schools, we selected six, or 25% of all Group4 schools.
is sample covered about 40% of the Group4 student population and included
schools from six dierent municipalities—three in the Lower Mainland, two on
Vancouver Island and one in the rural community of Lillooet.
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AUDITOR GENERAL OF BRITISH COLUMBIA | NOVEMBER 2020 | OVERSIGHT OF INTERNATIONAL EDUCATION PROGRAMS IN OFFSHORE AND GROUP 4 SCHOOLS
ABOUT THE AUDITS
3. Interviews with key sta and a sample of school inspectors.
We developed seven audit criteria, based on ministry legislation and policy documents, to
assess oversight processes related to certification, compliance monitoring and performance
monitoring, which are listed in Appendix A. ese criteria were applied to both audits.
e report is dated November 5, 2020. is is the date on which the audit team finished
obtaining the evidence used to determine the findings and conclusions of the report.
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AUDITOR GENERAL OF BRITISH COLUMBIA | NOVEMBER 2020 | OVERSIGHT OF INTERNATIONAL EDUCATION PROGRAMS IN OFFSHORE AND GROUP 4 SCHOOLS
OFFSHORE SCHOOLSAUDIT OBJECTIVE
AND CONCLUSION
Audit objective
To determine whether the Ministry of Education provides eective oversight of the delivery
of education programs by oshore schools.
Audit conclusion
We concluded that, except for the identified limitations in certification requirements, the
Ministry of Education provides eective oversight of the delivery of education programs by
oshore schools.
e ministry’s oversight focuses on ensuring delivery of the B.C. curriculum by B.C.-certified
teachers through processes to:
confirm that new oshore schools meet ministry business and educational
requirements before they are certified
monitor ongoing compliance with certification requirements
monitor school performance
However, we found that certification requirements addressing the responsibilities of
applicant oshore school operators did not result in the ministry having the business and
financial information necessary to provide eective oversight. Specifically:
School operators must provide the ministry with business information, including
an annual business plan, audited financial statements and a three-year forecast of
revenues and expenses. However, as the ministry does not require projected enrolment
and stang levels beyond the first year of operations, the information is not sucient
for the ministry to assess whether the school operator has the business plans and
financial capacity to deliver B.C. education programs over an extended period,
consistent with the ministry’s goals and expectations.
School operators are required to confirm their compliance with local laws and licensing
requirements (local regulations). ey must also demonstrate that they meet ministry
safety and regulatory requirements by providing evidence of compliance in areas
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AUDITOR GENERAL OF BRITISH COLUMBIA | NOVEMBER 2020 | OVERSIGHT OF INTERNATIONAL EDUCATION PROGRAMS IN OFFSHORE AND GROUP 4 SCHOOLS
OFFSHORE SCHOOLSAUDIT OBJECTIVE AND CONCLUSION
including building safety, local teacher credentials and criminal record checks for local
sta. Local regulations are unique to each foreign jurisdiction, so the evidence provided
to meet ministry requirements will be unique for each oshore school. A limitation with
the current application process is that school operators are not required to provide the
ministry with detailed information on local regulations. Without this information, it
is dicult for the ministry to determine what evidence is required from each oshore
school to demonstrate compliance with ministry requirements, whether at the time of
certification or in subsequent years.
e closure of an oshore school for business or compliance reasons could be sudden, would
negatively impact students and sta, and could potentially aect the international reputation
of B.C.’s education system.
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OFFSHORE SCHOOLSKEY FINDINGS AND
RECOMMENDATIONS
Certification
An important element in the eective oversight of oshore schools is clearly defined
requirements that must be met before a school can be certified to deliver a B.C. education
program.
We looked to see whether the Ministry of Education had:
established certification requirements that address the five areas of responsibility for
schools delivering B.C. education programs, as listed in the Statement of Education
Policy Order
established certification requirements that address the responsibilities of applicant
school operators to be in good standing and to have the business plans and financial
resources to operate their school
confirmed that applicant oshore schools met certification requirements before
certifying them for the first time
We found that certification requirements for oshore schools did cover the five key areas
listed in the Statement of Education Policy Order.
We also found that the ministry has established certification requirements that address
oshore school operator responsibilities to be in good standing and to have the resources
necessary to open an oshore school, with some limitations. Specifically, the business and
financial information required from school operators is not sucient to support eective
ministry oversight.
Finally, despite some gaps in ministry records, we concluded that the ministry’s certification
process confirms that new school operators meet established requirements before they are
certified for the first time.
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AUDITOR GENERAL OF BRITISH COLUMBIA | NOVEMBER 2020 | OVERSIGHT OF INTERNATIONAL EDUCATION PROGRAMS IN OFFSHORE AND GROUP 4 SCHOOLS
OFFSHORE SCHOOLSKEY FINDINGS AND RECOMMENDATIONS
Certification requirements for oshore schools address key educational
areas of responsibility
e Ministry of Education established certification requirements for oshore schools, under
the authority of the School Act, with the opening of the first oshore school in 1998.
e current application process for the initial certification of oshore schools includes seven key steps:
1. Expression of interest
2. In-person interview with ministry to assess operator motivations, experience, familiarity with
provincial curriculum requirements and capacity to start an oshore school that will meet the
ministry’s requirements
3. Formal application (including submission of business plan)
4. On-site application verification inspection (including payment of fees) to determine level of
readiness and what improvements/additional documents are required before pre-certification
can be granted and the school can begin delivering the B.C. curriculum (this was a new step for
2018/19 applicants, introduced to enhance the rigour of the application process)
5. Acceptance as a candidate for certification, and execution of pre-certification agreement
6. Certification inspection (including payment of fees) to determine level of readiness and what
improvements/additional documents are required before full certification can be granted
7. Signing of certification agreement and issuance of certificate confirming qualification as a B.C.-
certified school (includes payment of program and student fees)
Detailed certification requirements related to the delivery of B.C. education programs
by oshore schools are documented in the Operating Manual for Oshore Schools and
formalized in the signed certification agreement between the Minister of Education and the
oshore school operator. rough detailed examination of these primary documents, we
found that the ministry certification requirements cover the five key areas of responsibility
for schools delivering B.C. education programs, as identified in the Statement of Education
Policy Order:
finance and facilities
program direction, development and implementation
student access and achievement
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AUDITOR GENERAL OF BRITISH COLUMBIA | NOVEMBER 2020 | OVERSIGHT OF INTERNATIONAL EDUCATION PROGRAMS IN OFFSHORE AND GROUP 4 SCHOOLS
OFFSHORE SCHOOLSKEY FINDINGS AND RECOMMENDATIONS
teaching performance
system evaluation and public accountability
Certification requirements address oshore school operator
responsibilities, but do not provide enough information to adequately
assess business risks
A school operator must be in good standing and have the business plans and financial
resources necessary to open an oshore school before the ministry will certify the school to
deliver B.C. education programs.
Applicant oshore school operators must provide:
wrien confirmation, from the government entity responsible for education in the
jurisdiction in which they are operating, that they are approved to operate a school, hire
teachers and deliver B.C. education programs
confirmation that they are operating in compliance with local laws and licensing
requirements, including relevant labour and employment laws
a business plan for the first year of operations, including projected enrolment and stang
levels, audited financial statements and a three-year forecast of revenues and expenses
In recent years, with the growth in the number of oshore and Group4 schools, competition
for qualified students and B.C.-certified teachers has increased. Today, oshore school
operators are running a business in a highly competitive international education market and
need to be in a position to enrol enough students, recruit and retain enough B.C.-certified
teachers, and invest funds where necessary to support delivery of a quality education
program. In this competitive environment, school operators are at risk of not being able to
maintain the financial capacity to sustain school operations. Further, the increase in the
number of oshore schools and the number of countries in which they operate has added
complexity to ministry oversight as legal requirements vary in each jurisdiction.
To support eective oversight, the ministry needs to gather enough business information
from school operators to be able to assess whether they have the business plans and financial
capacity to sustainably deliver B.C. education programs. Also, given that oshore schools
operate in foreign jurisdictions, the ministry needs to have enough understanding of local
laws and licensing requirements to verify whether school operators remain in compliance
with ministry certification requirements for oshore schools.
e reputation of school operators and the long-term success of oshore schools directly
impacts the reputation of the Ministry of Education.
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AUDITOR GENERAL OF BRITISH COLUMBIA | NOVEMBER 2020 | OVERSIGHT OF INTERNATIONAL EDUCATION PROGRAMS IN OFFSHORE AND GROUP 4 SCHOOLS
OFFSHORE SCHOOLSKEY FINDINGS AND RECOMMENDATIONS
Information to assess financial sustainability of school operators is limited
Although applicant oshore school operators are required to provide the ministry with
annual business plans, audited financial statements and some financial forecasts, we found
these were not sucient for the ministry to assess whether applicant school operators were
in a position to sustainably deliver B.C. education programs in the competitive international
education environment.
As part of the application process, oshore school operators are required to submit an annual
business plan that includes projected first-year enrolment figures, plans for marketing the
school and recruiting students, and strategies for hiring and retaining B.C.-certified teachers.
ey must also provide audited financial statements for the most recent two years available,
as well as a three-year forecast of revenues and expenses. School operators are not asked to
provide forecasts of enrolment and stang levels beyond the school’s first year of operations.
As such, the business plan information is focused on the first year of operations.
e ministry reviews the financial statements and forecasts provided to assess whether an
applicant school has sucient funds to deliver its B.C. education programs over the one-
year term of the certification agreement. is review also looks at the three-year forecast to
see if the school expects to be profitable within the first three years of operations. However,
because this forecast is not substantiated with projected enrolment and stang levels, the
information is not enough to enable the ministry to assess whether the financial forecasts are
reasonable or sustainable.
A requirement for applicant school operators to provide a five-year business plan, with
financial forecasts that are supported by projected enrolment and stang levels, would give
the ministry more of the information it needs to assess a school’s ability to establish, and
sustainably deliver, its B.C. education programs.
Since the 2016/17 school year, the ministry’s certification agreement for oshore schools
has required that schools make reasonable eorts to enrol at least 60 students per grade.
However, based on a review of enrolment levels for our sample schools, we found the ministry
accepts a wide range of enrolment levels for oshore schools, including many well below
the stated goal of at least 60 students per grade. e ministry has allowed lower enrolment
levels if it has determined that an operator’s business plans support the operator’s capacity
to sustainably deliver B.C. education programs in the school. Each school is unique, and the
ability to assess each applicant’s capacity to deliver the program over the long term is critical
to ensuring quality and stability of the program oshore.
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OFFSHORE SCHOOLSKEY FINDINGS AND RECOMMENDATIONS
In discussions with the ministry on this topic, we heard that there are two main reasons
for seing a goal of 60 students per grade. e first is that having more students per grade
allows for more electives for students in the higher grades, which means students are given
more educational opportunities. Also, having more students in a school will generally require
more teachers to be employed, which increases opportunities for collegial interchange and
support amongst sta. is is particularly important for sta teaching in remote areas. ese
conditions enable a school to deliver education programs consistent with the ministry’s goals
and expectations.
e second reason for seing an enrolment goal is that the ministry does not want instability
in the program. For example, it does not want operators to open an oshore school thinking
they can increase enrolment but not having the requisite business planning to support that
enrolment growth, and then exiting the program a few years later because they do not have
enough students to be financially viable.
When an oshore school operator applies for certification, it is important the ministry
receives the information necessary to understand how the school plans to recruit and retain
students over the long term and how the operator plans to be competitive in recruiting and
retaining qualified teachers. A five-year business plan, including detailed financial forecasts
of enrolment and stang levels, is a tool that can give the ministry more information on how
an operator plans to aain financial sustainability with the students and sta necessary to
deliver B.C. education programs, initially and over time.
RECOMMENDATION 1: We recommend that the Ministry of Education, as part of
the oshore school application process:
expand current information requirements to include a comprehensive five-
year business plan, with detailed financial forecasts based on projected student
enrolment and B.C.-certified teacher stang levels, and
enhance its review of submied business plans and financial forecasts to confirm
that school operators have demonstrated their capacity to deliver B.C. education
programs over an extended period, consistent with the ministry’s goals and
expectations.
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AUDITOR GENERAL OF BRITISH COLUMBIA | NOVEMBER 2020 | OVERSIGHT OF INTERNATIONAL EDUCATION PROGRAMS IN OFFSHORE AND GROUP 4 SCHOOLS
OFFSHORE SCHOOLSKEY FINDINGS AND RECOMMENDATIONS
Ministry understanding of local laws and licensing requirements is limited
Each oshore school operates within a unique foreign regulatory environment. As part of
the certification process, applicant school operators are required to confirm their compliance
with the laws and licensing requirements in their local jurisdiction (local regulations). Local
regulations may include:
building standards and safety inspections
inspections for food service operations
teacher classifications and certification requirements
criminal record check processes
educational governance
foreign teacher visa requirements
At the same time, each school operator must demonstrate that it meets ministry safety and
regulatory requirements, including those related to building safety, local teacher credentials
and criminal record checks for local sta. As local regulations are unique to each foreign
jurisdiction, the evidence provided to demonstrate compliance with ministry requirements
will be unique for each oshore school.
A limitation in the current application process is that school operators are not required
to provide the ministry with detailed information on local regulatory processes. Without
this information, it is dicult for the ministry to understand how local regulations relate
to ministry requirements and to determine what evidence is required from each school to
demonstrate compliance, both at the time of initial certification and in subsequent years.
For example, in one country, building inspections may be conducted annually; in another,
there may only be an original building occupancy inspection with no subsequent inspections
performed. e evidence required to demonstrate compliance with ministry building safety
requirements will be dierent for each school operator.
In our review of annual report documents submied by the 12 sample oshore schools, we
found several areas where confirming compliance with ministry requirements was dicult,
including requirements for criminal record checks and local teacher credentials.
e ministry requires each school to have a current criminal record check on file for each local
sta person who interacts with minors. We found that for seven of our 12 sample schools, it
was stated or implied that criminal record checks for local sta were conducted as part of
a local credentials process, such as teaching certification or work permit issuance. To meet
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AUDITOR GENERAL OF BRITISH COLUMBIA | NOVEMBER 2020 | OVERSIGHT OF INTERNATIONAL EDUCATION PROGRAMS IN OFFSHORE AND GROUP 4 SCHOOLS
OFFSHORE SCHOOLSKEY FINDINGS AND RECOMMENDATIONS
this ministry requirement, these schools provided copies of the relevant credentials for all
sta needing criminal record checks. However, for four of these schools, the ministry files did
not include any independent information to verify that criminal record checks were in fact
completed as part of the credential process. In the absence of clear and reliable information
on how and why criminal record checks are performed in the local regulatory environment,
we were unable to verify that the documents provided were sucient evidence that the
school was in compliance with the ministry’s criminal record check requirements.
Another ministry requirement is that local teachers hired to deliver exempted courses must
be licensed by local authorities. We found that school documents sometimes included only
a diploma from a college as proof of teaching credentials. A diploma in a subject area, such
as visual arts, does not necessarily mean that the individual is licensed to teach art. We
found that due to incomplete translation or a lack of documents to support local teacher
qualifications, we could not always verify that the ministry was doing enough to confirm
compliance with its requirement that local teachers possess the required local certification to
teach exempted courses.
e ministry does not consistently enforce its requirement that all ocial documents from
foreign jurisdictions be translated. rough our review of documents related to our sample
of 12 oshore schools, we found that ocial documents from foreign jurisdictions were not
always fully or independently translated, making interpreting them dicult. As a result, in
these cases we could not verify that these documents satisfied the ministry’s requirements
for which they were provided.
Before certifying an oshore school, the ministry needs to understand and document
how the local regulatory framework operates and how it relates to ministry certification
requirements. Currently, school operators are not required to give the ministry detailed,
translated information on local regulatory processes as part of the application process.
Without this information it is dicult for the ministry to understand how local regulations
relate to ministry requirements or to determine what evidence is required from each school
to demonstrate compliance, whether at the time of certification or in subsequent years.
e closure of five oshore schools in Korea in 2017 as a result of non-compliance with local
regulations highlights the importance of understanding the unique regulatory environment
of each oshore school.
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AUDITOR GENERAL OF BRITISH COLUMBIA | NOVEMBER 2020 | OVERSIGHT OF INTERNATIONAL EDUCATION PROGRAMS IN OFFSHORE AND GROUP 4 SCHOOLS
OFFSHORE SCHOOLSKEY FINDINGS AND RECOMMENDATIONS
RECOMMENDATION 2: We recommend that the Ministry of Education require
oshore school operators to provide detailed, translated information on local
regulatory processes so that the ministry is able to understand how local regulations
relate to ministry requirements and to determine what evidence is required from
each school to demonstrate compliance, both at the time of initial certification and in
subsequent years.
The ministry confirms that oshore schools meet certification requirements
Using ministry records, we looked for evidence that the ministry had confirmed that all
oshore schools in our sample met certification requirements before they were certified for
the first time. We observed that, in all cases, the ministry had a documented process in place
to verify that schools met requirements before certifying them for the first time. We also saw
that these requirements evolved over time, demonstrating continuous eorts by the ministry
to improve the eectiveness of its oversight of oshore schools.
e 12 oshore schools in our sample were first certified between 1998 and 2018. In our
document review, we found that initial certification documentation was incomplete for all 12
schools. We also found many gaps in ministry files for school documents submied as part
of the certification application process. As a result, we could not verify that all certification
requirements had been met prior to initial certification for any of the 12 schools.
However, we recognize that most of our sample schools were certified more than 10 years
ago. Based on interviews and consideration of all available documentation for each school,
we determined that these gaps did not indicate that the ministry had failed to confirm
certification requirements, but rather were symptomatic of the fact that these were
old records. In addition, these 12 schools are still operating and were meeting ongoing
certification requirements at the time of our audit.
Compliance monitoring
Two important elements of eective oversight are a process to monitor ongoing compliance
with certification requirements, and a mechanism to initiate corrective action when issues
are identified.
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AUDITOR GENERAL OF BRITISH COLUMBIA | NOVEMBER 2020 | OVERSIGHT OF INTERNATIONAL EDUCATION PROGRAMS IN OFFSHORE AND GROUP 4 SCHOOLS
OFFSHORE SCHOOLSKEY FINDINGS AND RECOMMENDATIONS
In this audit, we looked to see whether the ministry monitors oshore schools for compliance
with certification requirements. We also looked to see whether the ministry takes corrective
action when an oshore school is not compliant with those requirements.
Overall, we found that the ministry monitors compliance through regular reporting
from oshore schools and on-site school inspections. When issues are reported by school
inspectors for follow-up, the ministry takes corrective actions to bring schools into
compliance. However, we did observe that current reporting procedures for oshore school
inspections result in some issues not being flagged for follow-up.
The ministry monitors ongoing compliance with certification requirements
e Ministry of Education has a robust and documented process to confirm that oshore
schools continue to meet certification requirements. e ministry requires annual reporting
by schools and ensures that all required documents are submied. All schools undergo
extensive annual on-site inspections that detail how they are doing in key compliance areas.
Schools then must respond to any findings of non-compliance made by inspectors before
their certificates are renewed. Finally, to maintain certification, all schools must submit
the required annual program information, student enrolment data and inspection fees, as
invoiced, on time.
In reviewing compliance documents for oshore schools, we noted many gaps in the
ministry’s records. We also saw that with the increase in the number of oshore schools, from
two to 45 between 2005 and 2018, the monitoring process has become more administratively
onerous, reducing ministry time available for critical review of areas of concern or risk.
Completing annual inspections
We reviewed documents for three annual inspections for each of the 12 sample oshore
schools, looking for evidence that the ministry monitored for compliance in six specific areas:
All required documents for inspections were submied to the ministry on time by
each school.
An inspection was completed as required.
e inspection was conducted consistent with the current inspection catalogue.
e chair of the inspection team was qualified to conduct the inspection.
Compliance issues were identified in the inspection report.
e ministry followed up with each school to ensure that it had responded to the
compliance issues identified in the inspection report before renewing its certificate.
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AUDITOR GENERAL OF BRITISH COLUMBIA | NOVEMBER 2020 | OVERSIGHT OF INTERNATIONAL EDUCATION PROGRAMS IN OFFSHORE AND GROUP 4 SCHOOLS
OFFSHORE SCHOOLSKEY FINDINGS AND RECOMMENDATIONS
We also tested payment data to see whether schools were paying the required fees in full and
on time.
We found that ministry records were not complete. As a result, we could not verify that all
sample schools had submied all annually required documents on time. In particular, we found
that out of the 36 annual report submissions, ministry records for 19 submissions were either
missing documents or had documents that did not clearly comply with our understanding of
the requirements for one or more of the 18 annual reporting areas. For example:
four school submissions had multiple missing documents
seven school submissions had missing or inadequately translated documents
seven school submissions had missing or inadequate evidence of criminal record checks
for local sta
four school submissions had issues with documents supporting teacher credentials,
either Teacher Certification Branch (TCB) or local certifications
While not all documents were available, we found that the ministry conducted all inspections
as designed and scheduled. We also found that all fees were being paid as expected. However,
we found some areas where the overall monitoring processes could be improved to focus
on key risks. At the time of the audit, the ministry was working to improve its records
management processes.
Monitoring processes do not always focus on key risks
When a school inspector identifies issues of non-compliance, these issues are documented
in a section of the inspection report called “Requirements.” e information in this section is
made public, and all reported issues of non-compliance are flagged for follow-up and tracked
by the ministry until it is satisfied that the school has resolved the issues.
We found that 28 compliance issues (requirements) were identified by inspectors in the 36
inspection reports we reviewed for our 12 sample oshore schools. All 28 issues were recorded
and monitored by the ministry to ensure that the schools had responded satisfactorily before
their certificates were renewed.
However, during the audit we identified two areas where potentially significant issues were
not reported in the “Requirements” section of an inspection report, and as a result were not
included in the ministry’s tracking and follow-up process. e first area relates to suggestions
made by school inspectors, and the second relates to pending teacher certifications.
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AUDITOR GENERAL OF BRITISH COLUMBIA | NOVEMBER 2020 | OVERSIGHT OF INTERNATIONAL EDUCATION PROGRAMS IN OFFSHORE AND GROUP 4 SCHOOLS
OFFSHORE SCHOOLSKEY FINDINGS AND RECOMMENDATIONS
Inspectors document their suggestions for improvements, including actions needed to ensure
compliance in future inspections, in a section of the inspection report called “Suggestions.”
Items listed as suggestions are not tracked and followed up by the ministry. We reviewed
all suggestions made in the 36 inspections covered under our sample to assess whether
any suggestions related to specific compliance or safety issues might have been more
appropriately included in the requirements section of the report. We found that 52 of the 164
suggestions reviewed related to either compliance or safety issues, or to the quality of the
education programs being delivered. Further, the inspectors had indicated the issues needed
to be addressed before the next inspection, even though there was no formal tracking and
follow-up. Given this finding, we concluded that many of the suggestions might have been
more appropriately reported and tracked as requirements.
e second area we identified relates to the ongoing status of teachers not certified by the
Teacher Certification Board (TCB) at the time of an inspection. If an employed teacher is in
the process of applying for certification, the school will request a leer of exemption from
the ministry. is leer of exemption temporarily exempts the oshore school from the
requirement that the teacher be B.C.-certified. When an exemption is in place at the time of
the school inspection, the inspector does not report an uncertified teacher as a compliance
issue. As a result, these pending certificates—a compliance issue—are not flagged for formal
follow-up.
e ministry has its own process, separate from the inspection process, to track these leers of
exemption, which are usually valid for four to six weeks, and has its own process to follow up
if the leers have expired. For nine of the 36 inspections we examined, involving four dierent
schools, TCB certification was pending for a total of 57 teachers at the time of the inspections.
Of these teachers, we confirmed that 19, or one-third, were never subsequently certified.
Ministry records provided evidence that four of these teachers were given additional leers
of exemption and two teachers were confirmed to have le the school mid-year. For the
remaining 13 cases, ministry records did not contain evidence that these teachers had stopped
delivering B.C. education programs once their leers of exemption had expired, even though
they did not receive additional leers of exemption. A key element of a B.C. education
program is that it is delivered by B.C.-certified teachers. Improved tracking of pending
certifications, as part of reported compliance issues, would reduce the risk of non-certified
teachers delivering B.C. education programs.
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AUDITOR GENERAL OF BRITISH COLUMBIA | NOVEMBER 2020 | OVERSIGHT OF INTERNATIONAL EDUCATION PROGRAMS IN OFFSHORE AND GROUP 4 SCHOOLS
OFFSHORE SCHOOLSKEY FINDINGS AND RECOMMENDATIONS
RECOMMENDATION 3: We recommend that the Ministry of Education review and
update its compliance monitoring model for oshore schools to:
require inspectors to report pending teacher certifications and any significant
suggestions for improvement as requirements to ensure they are tracked and
resolved before the next inspection cycle
rationalize the volume of documents required in order to reduce administrative
eort, and
ensure sucient time is allocated to review business issues that could impact the
sustainability and quality of education programs delivered.
Performance monitoring
An important element of eective oversight is monitoring school performance data to
understand how schools are doing and to identify opportunities for improvement.
We looked to see if the Ministry of Education had established and communicated performance
reporting requirements for oshore schools, and if performance reporting included
information on student achievement, graduation rates and transitions to post-secondary
schools. We also looked to see if schools complied with performance reporting requirements.
We then looked to see if the ministry used reported performance data to evaluate the delivery
of education programs at the individual school level and at the group or program level.
We found that the ministry has established and communicated performance reporting
requirements for oshore schools, and that schools consistently submit required performance
reports, including information on student achievement, graduation rates and transitions to
post-secondary schools. We also found that the ministry uses reported performance data to
evaluate the delivery of education programs by individual oshore schools.
While the ministry uses performance data to assess oshore schools as a program area, it
does not assess the performance of oshore schools against the goals of the B.C. Global
Education Program (Oshore School Program).
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AUDITOR GENERAL OF BRITISH COLUMBIA | NOVEMBER 2020 | OVERSIGHT OF INTERNATIONAL EDUCATION PROGRAMS IN OFFSHORE AND GROUP 4 SCHOOLS
OFFSHORE SCHOOLSKEY FINDINGS AND RECOMMENDATIONS
The ministry monitors performance reporting by oshore schools
Performance reporting requirements for oshore schools are documented in eight key
documents:
the Oshore School Certification Agreement
the Operating Manual for Oshore Schools
the annual report template
the B.C. Graduation Program Handbook of Procedures
the Oshore School TRAX Requirements and Procedures document
“Kindergarten–12 Data Collections” (ministry webpage)
Reports, Records and Data Submission Order
Student Progress Report Order
B.C. Performance Standards
We assessed these eight documents and determined that the ministry does communicate
performance reporting requirements to oshore schools, including requirements for data on
student achievement, graduation rates and transition statistics.
rough review of ministry and sample school documents, we verified that all key
performance reporting requirements, as communicated through the various source
documents, were being met by oshore schools. In this way, we verified that schools
understood the reporting requirements and reported back to the ministry as expected.
Evaluating performance of oshore schools
We found that the ministry uses reported performance data to evaluate the delivery of
education programs by oshore schools at the individual school level. e ministry compiles
performance data received from schools to provide inspection teams with data reports to
inform performance conversations during annual inspections. ese reports include key
school and student data for the most recent five years, such as:
enrolment levels by grade
dierences between course and exam marks for individual oshore schools and how
these results compare with those of other oshore schools
graduation rates compared with those of public and independent schools in B.C.
transition rates to B.C. public post-secondary institutions
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AUDITOR GENERAL OF BRITISH COLUMBIA | NOVEMBER 2020 | OVERSIGHT OF INTERNATIONAL EDUCATION PROGRAMS IN OFFSHORE AND GROUP 4 SCHOOLS
OFFSHORE SCHOOLSKEY FINDINGS AND RECOMMENDATIONS
Oshore school inspectors found these data reports to be very useful, both for themselves
and for oshore schools, and used them as a key reference when discussing potential
strategies to improve student outcomes.
rough our review of documents, we verified that the ministry uses reported performance
data to:
routinely report student outcomes for oshore schools against other school types
brief ministry executive on oshore student outcomes in comparison with other school
types, English language learners in other schools and all international students studying
in B.C.
periodically brief ministry executive on other performance measures related to the B.C.
Global Education Program, including program recoveries and indirect economic benefits
to the province
verify possible trends or areas of concern, as identified by inspectors, stakeholders and/
or the media, to improve processes or inform policy decisions
identify professional development needs in order to support the delivery of the
education programs by oshore school administrators and teachers
rough annual reporting from oshore schools, the ministry collects data that could be
used to regularly assess its progress in meeting the stated goals of the B.C. Global Education
Program:
to increase recognition of B.C.’s high-quality education brand
to create opportunities for B.C. schools to develop international partnerships
to aract more international students to study and eventually work and live in B.C.
RECOMMENDATION 4: We recommend that the Ministry of Education use available
performance data to evaluate progress in meeting the stated goals of the B.C. Global
Education Program.
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AUDITOR GENERAL OF BRITISH COLUMBIA | NOVEMBER 2020 | OVERSIGHT OF INTERNATIONAL EDUCATION PROGRAMS IN OFFSHORE AND GROUP 4 SCHOOLS
GROUP  SCHOOLSAUDIT OBJECTIVE
AND CONCLUSION
Audit objective
To determine whether the Ministry of Education provides eective oversight of the delivery
of education programs by Group4 independent schools.
Audit conclusion
We concluded that, except for the identified limitation in certification requirements, the
Ministry of Education provides eective oversight of the delivery of education programs by
Group4 independent schools.
e ministry’s oversight focuses on ensuring delivery of the B.C. curriculum by B.C.-certified
teachers through processes to:
confirm that new Group4 schools meet business and educational requirements before
they are certified
monitor ongoing compliance with certification requirements
monitor school performance
However, we found that certification requirements addressing the responsibilities of
applicant Group4 school operators did not result in the ministry having the business and
financial information necessary to provide eective oversight. Specifically, school operators
are not required to provide a business plan and financial information that would enable
the ministry to assess their financial capacity to deliver B.C. education programs over an
extended period, consistent with the ministry’s goals and expectations.
e closure of a Group4 school for financial reasons could be sudden, would negatively
impact students and sta, and could potentially aect the international reputation of B.C.’s
education system.
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GROUP  SCHOOLSKEY FINDINGS
AND RECOMMENDATIONS
Certification
An important element in the eective oversight of Group4 schools is clearly defined
requirements that must be met before a school can be certified to deliver a B.C.
education program.
We looked to see whether the Ministry of Education had:
established certification requirements that address the five areas of responsibility for
schools delivering B.C. education programs, as listed in the Statement of Education
Policy Order
established certification requirements that address the responsibilities of applicant
school operators to be in good standing and to have the business plans and financial
resources to operate their school
confirmed that applicant Group4 schools met certification requirements before
certifying them for the first time
We found that certification requirements for Group4 schools did cover the five key areas
listed in the Statement of Education Policy Order, in detail.
We also found that the ministry has established certification requirements that address
school operator responsibilities, including that a Group4 school operator be in good standing
with the Registrar of Companies and in compliance with municipal zoning requirements.
However, the ministry does not gather enough business and financial information from
applicant Group4 school operators to assess whether they have the business plans and
financial resources to deliver B.C. education programs over an extended period, consistent
with the ministry’s goals and expectations.
Finally, despite some gaps in ministry records, we concluded that the ministry’s certification
process confirms that new school operators meet established requirements before they are
certified for the first time.
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GROUP 4 SCHOOLSKEY FINDINGS AND RECOMMENDATIONS
Certification requirements for Group 4 schools address key educational
areas of responsibility
e Ministry of Education established certification requirements for Group4 schools in 1989,
when the first Group4 schools were established under the authority of a new Independent
School Act.
Certification process for a Group4 school:
1. School operator submits expression of interest (this was a new step for 2018/19 applicants)
2. In-person interview with ministry to assess operator motivations, experience, familiarity with
provincial curriculum requirements and capacity to start an independent school that will meet
the ministry’s requirements (this was a new step for 2018/19 applicants)
3. School operator submits formal application for interim certification
4. Inspector of independent schools issues interim Group4 certificate when the operator meets
application requirements (includes posting of financial bond)
5. School opens and school policies finalized
6. Ministry conducts external evaluation to verify that all requirements for delivery of education
programs are being met
7. Inspector of independent schools issues a certificate of Group4 classification, which certifies the
Group4 school to deliver B.C. education programs
e external evaluation catalogue used by inspectors expands on the certification
requirements related to the delivery of B.C. education programs by Group4 independent
schools, as documented in the Independent School Act. rough detailed examination of the
Act and the evaluation catalogue, we found that the ministry certification requirements
cover the five key areas of responsibility for schools delivering a B.C. education program, as
identified in the Statement of Education Policy Order:
finance and facilities
program direction, development and implementation
student access and achievement
teaching performance
system evaluation and public accountability
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AUDITOR GENERAL OF BRITISH COLUMBIA | NOVEMBER 2020 | OVERSIGHT OF INTERNATIONAL EDUCATION PROGRAMS IN OFFSHORE AND GROUP 4 SCHOOLS
GROUP 4 SCHOOLSKEY FINDINGS AND RECOMMENDATIONS
Group 4 schools are not required to assess English language proficiency
of new students
We did identify an opportunity to enhance certification requirements related to the delivery
of B.C. education programs for Group4 schools. As most students enrolled in Group4 schools
are international, their level of English language skills will vary. A requirement that Group4
schools assess the English language proficiency of new students could help support student
success in the program.
e ministry requires, as part of its certification process, that oshore schools have a process
for assessing the English language ability of new students. e requirement is included in the
certification agreement, which is established under the authority of the School Act.
ere is no requirement in the Independent School Act for Group4 schools, or any
independent school, to assess the English language ability of international students. However,
we noted that the inspector of independent schools, under the authority of section 4(1) of the
Independent School Act, has the discretion to establish requirements related to the issuing or
renewal of certification of an independent school.
ere is a risk that Group4 schools, as for-profit international education providers, will
enrol students who do not have the language skills to complete the B.C. Graduation Program
within the usual three years. Students also risk not being entitled to a B.C. Graduation
Certificate if they are not able to complete the program before the end of the school year in
which they turn 19.
A requirement to assess English language abilities of international students entering a
Group4 school would provide the school with information on what English language
learning supports are necessary to set their students up to successfully complete their
programs within the expected time frame.
RECOMMENDATION 5: We recommend that the Ministry of Education require
Group 4 schools to conduct assessments of the English language ability of all new
students to ensure that necessary learning supports are put in place.
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AUDITOR GENERAL OF BRITISH COLUMBIA | NOVEMBER 2020 | OVERSIGHT OF INTERNATIONAL EDUCATION PROGRAMS IN OFFSHORE AND GROUP 4 SCHOOLS
GROUP 4 SCHOOLSKEY FINDINGS AND RECOMMENDATIONS
Certification requirements address Group 4 school operator
responsibilities, but do not provide enough information to adequately
assess business risks
A school operator must be in good standing and have the financial resources necessary to open
a Group4 school before the ministry will certify the school to deliver B.C. education programs.
Applicant Group4 school operators must provide:
a declaration that all teachers are properly certified and that all employees working
with students have current criminal record checks
confirmation that the school is operating in compliance with municipal requirements
(zoning, building, fire and health)
confirmation that they are in good standing with the Registrar of Companies
evidence of compliance with the bonding requirements for the current school year
In recent years, with the growth in the number of oshore and Group4 schools, competition
for qualified students and B.C.-certified teachers has increased. Today, Group4 school
operators are running a business in a highly competitive international education market and
need to be in a position to enrol enough students, recruit and retain enough B.C.-certified
teachers, and invest funds where necessary to support delivery of a quality education
program. In this competitive environment, school operators are at risk of not being able to
maintain the financial capacity to sustain school operations.
To support eective oversight, the ministry needs to gather enough detailed information
from school operators to be able to assess whether they have the business plans and financial
capacity to sustainably deliver B.C. education programs. e reputation of school operators
and the long-term success of Group4 schools directly impact the reputation of the Ministry
of Education.
Information to assess financial sustainability of Group 4 schools is limited
e requirement for Group4 school operators to place a financial bond with the ministry
provides some protection for students in the event that an operator closes a Group4 school,
but it does not replace the importance of a school operator maintaining the financial capacity
to sustain school operations.
We found that the ministry does not require applicant Group4 school operators to
provide information on forecasted student enrolment levels and strategies for recruiting
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AUDITOR GENERAL OF BRITISH COLUMBIA | NOVEMBER 2020 | OVERSIGHT OF INTERNATIONAL EDUCATION PROGRAMS IN OFFSHORE AND GROUP 4 SCHOOLS
GROUP 4 SCHOOLSKEY FINDINGS AND RECOMMENDATIONS
and retaining B.C.-certified teachers as part of their application process. A plan to aract
and retain enough students and the necessary B.C.-certified teachers is key to a school
successfully establishing and sustaining delivery of its B.C. education programs.
Although an independent school is defined in legislation as having a minimum of 10 students,
Group4 schools may need to aract more students to generate the tuition revenue required
to sustain their operations, to allow for a variety of electives and extracurricular activities,
and to promote a richer intellectual exchange among students.
e recruitment and retention of B.C.-certified teachers is also critical to the sustainable
delivery of education programs by Group4 schools. Group4 schools are in competition with
public schools for B.C.-certified teachers, but public schools are oen able to pay higher
salaries. ere is also competition between oshore schools and Group4 schools for B.C.-
certified teachers with experience in delivering the B.C. curriculum to international students.
Regular turnover of teaching sta and administrators creates risks for both the long-term
viability and the quality of the education programs delivered by Group4 schools.
We found that school operators applying for Group4 certification are not required to submit
a business plan as part of their application process. When a Group4 school operator applies
for certification, it is important for the ministry to understand how the school plans to recruit
and retain students and qualified teachers, including whether its business plan anticipates
the ability to pay competitive salaries. A five-year business plan is a tool that can give the
ministry information on how an operator will maintain both financial sustainability and the
sta necessary to deliver education programs, initially and over time.
RECOMMENDATION 6: We recommend that the Ministry of Education, as part of
the Group4 school application process:
require applicant Group4 school operators to provide a comprehensive five-
year business plan, with forecasted student enrolment and teacher recruitment
strategies, and
establish a process to review submied business plans to confirm that school
operators have demonstrated their capacity to deliver B.C. education programs
over an extended period, consistent with the ministry’s goals and expectations.
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GROUP 4 SCHOOLSKEY FINDINGS AND RECOMMENDATIONS
The ministry confirms that Group 4 schools meet certification requirements
Using ministry records, we looked for evidence that the ministry had confirmed that all
Group4 schools in our sample met certification requirements before they were certified for
the first time. e six Group4 schools in our sample were first certified between 1989 and
2018. We observed that throughout this time frame the ministry had a documented process in
place to verify that schools met requirements before certifying them for the first time. We also
observed that certification processes were continuously being adjusted, demonstrating ongoing
eorts by the ministry to improve the eectiveness of its oversight of Group4 schools.
For the three schools certified in 1991 and earlier, there were not enough documents available
for the audit team to verify that all areas of compliance had been met before the ministry
certified them. Given the passage of time, and changes in ministry records management
practices over the years, not all initial certification or inspections records were saved or could
be easily found.
For the three schools certified aer 1991, ministry records were sucient to demonstrate
that the ministry had confirmed that these schools met certification requirements before
certifying them.
Despite the lack of documents for three of the six schools in our sample, we found that this
deficiency did not show a failure in the ministry’s certification processes and did not reflect
current practice, but rather was a result of historic records management issues observed at
the ministry. ese three schools were still operating and were meeting ongoing certification
requirements at the time of our audit.
Compliance monitoring
Two important elements of eective oversight are a process to monitor ongoing compliance
with certification requirements, and a mechanism to initiate corrective action when issues
are identified.
In this audit, we looked to see whether the ministry monitors Group4 schools for compliance
with certification requirements. We also looked to see whether the ministry takes corrective
action when a Group4 school is not compliant with those requirements.
Overall, we found that the ministry monitors compliance through regular reporting from
Group4 schools and on-site school inspections. When issues are reported by school inspectors
for follow-up, the ministry takes corrective actions to bring schools into compliance.
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GROUP 4 SCHOOLSKEY FINDINGS AND RECOMMENDATIONS
The ministry monitors ongoing compliance with certification requirements
e Ministry of Education has a robust and documented process to confirm that Group4
schools continue to meet certification requirements. e ministry requires Group4 schools
to renew their certification every two years, based on an external evaluation (comprehensive
inspection). In the interim year, schools undergo a monitoring inspection that covers all
the same areas an external evaluation would, but in slightly less detail. Schools then must
respond to any statutory and policy requirements, reported by inspectors, before they have
their certificates renewed.
School inspections involve a three-step process:
1. Each Group4 school prepares and submits all required documentation supporting the
claims it makes in the inspection report template.
2. e ministry hires education experts to conduct in-person inspections to verify the
veracity and accuracy of all related documentation and claims. e inspection also
identifies any statutory or policy-related compliance issues that need to be remedied
before the school can have its certificate renewed.
3. Each school is required to respond to the identified compliance issues by a specific
deadline, and the ministry ensures that it is satisfied with these responses before
permiing the school to renew its certification.
We reviewed the two most recent monitoring inspections and two most recent external
evaluations for each of the six sample Group4 schools, looking for evidence that the ministry
monitored for compliance in six specific areas:
All required documents for inspections were submied to the ministry on time by
each school.
An inspection was completed as required.
e inspection was conducted consistent with the current inspection catalogue.
e chair of the inspection team was qualified to conduct the inspection.
Compliance issues were identified in the inspection report.
e ministry followed up with each school to ensure that it had responded to the
compliance issues identified in the inspection report before renewing its certificate.
According to ministry sta, annual submissions are consistently provided on time but are not
always complete. Sta diligently follow up with schools to ensure all required documents are
submied. As part of this process, ministry sta confirm that documents have been received
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GROUP 4 SCHOOLSKEY FINDINGS AND RECOMMENDATIONS
and the school is ready for the inspection. A critical review of the content of these submission
documents is the responsibility of the inspection team, not ministry sta.
We found that all external and monitoring inspections were completed as expected and
carried out by qualified inspection teams, with each inspection chair having extensive
experience in the B.C. education sector.
We also found that the ministry takes corrective action when a school is not in compliance
with a requirement. Specifically, we found that the ministry monitors both statutory and
policy issues identified in inspection reports that require corrective action. e ministry then
follows up before renewing school certificates.
Monitoring processes do not always focus on key risks
Non-compliance with statutory or ministry policy requirements identified through school
inspections is recorded in a ministry database. is ministry system is used to track each
school’s inspection status and whether the school has resolved each reported issue. Our
review of this documentation verified that inspection findings and the required school
responses were tracked for resolution prior to the schools having their certificates renewed.
However, we found that ministry sta do not always critically review the substance of school
responses. is is oen because eort is focused on managing the volume of paperwork related
to the inspection process. In the absence of a critical review of school responses and supporting
documents, there is a risk that the ministry may accept a school’s assertion that an issue has
been resolved, when it has not been. Each year a small group of schools will be flagged for a
follow-up inspection when there are significant concerns. In these cases, the substance of each
school’s response to resolve issues of non-compliance will be reviewed by inspectors.
It was not clear from our testing whether the ministry requires inspectors in the following
inspection cycle to confirm that a Group4 school has put in place the reported changes in
response to the previous year’s inspection. However, schools will be inspected against the
same criteria as the previous year, so any unresolved issues would be noted.
We determined that the ministry does take corrective actions when schools are not compliant
with certification requirements. However, implementing more ecient processes to ensure
that adequate time is available for a critical review of all school responses to compliance
issues would improve the ministry’s corrective activities.
e inspection and follow-up process involves a significant volume of documents, and the
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AUDITOR GENERAL OF BRITISH COLUMBIA | NOVEMBER 2020 | OVERSIGHT OF INTERNATIONAL EDUCATION PROGRAMS IN OFFSHORE AND GROUP 4 SCHOOLS
GROUP 4 SCHOOLSKEY FINDINGS AND RECOMMENDATIONS
increase in the number of Group4 schools since 1989 has resulted in an administrative burden
that limits the sta time available to critically review the information submied, and to
identify potential risks to the ongoing success of schools.
e ministry should review its current processes to ensure the eort, and documentation,
is focused on key areas of risk and concern. Currently, the volume of documents being
submied means some areas of heightened risk may not be geing the aention they
deserve. A risk-based approach to monitoring compliance would enable the ministry to focus
on areas of concern identified by school inspectors and to monitor a school’s enrolment and
stang levels against its business plans.
RECOMMENDATION 7: We recommend that the Ministry of Education review and
update its compliance monitoring model for Group4 schools to:
rationalize the volume of documents required in order to reduce administrative
eort, and
ensure sucient time is allocated to review business issues that could impact the
sustainability and quality of education programs delivered.
Performance monitoring
An important element of eective oversight is monitoring school performance data to
understand how schools are doing and to identify opportunities for improvement.
We looked to see if the Ministry of Education had established and communicated performance
reporting requirements for Group4 schools, and if performance reporting included information
on student achievement, graduation rates and transitions to post-secondary schools. We also
looked to see if schools complied with performance reporting requirements.
We then looked to see if the ministry used reported performance data to evaluate the delivery
of education programs at the individual school level and for all Group4 schools collectively.
We found that the ministry has established and communicated performance reporting
requirements for Group4 schools, and that schools consistently submit required performance
reports, including information on student achievement, graduation rates and transitions to
post-secondary schools. We also found that the ministry uses reported performance data
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GROUP 4 SCHOOLSKEY FINDINGS AND RECOMMENDATIONS
to evaluate the delivery of education programs by individual Group4 schools, but does
not formally evaluate the performance of Group4 schools as a unique group within the
independent school sector.
The ministry monitors performance reporting by Group 4 schools
Performance reporting requirements for Group4 schools are documented in eight
key documents:
Reports, Records and Data Submission Order
the B.C Graduation Program Handbook of Procedures
the Independent School Act
the Policy on Reporting Requirements and Data Collection for Independent Schools
Monitoring Inspection and External Evaluation Report templates
“Kindergarten–12 Data Collections” (ministry webpage)
Student Progress Report Order
B.C. Performance Standards
We assessed these eight documents and determined that the ministry does communicate
performance reporting requirements to Group4 schools, including requirements for data on
student achievement, graduation rates and transitions. We found that the ministry also asks
for many other performance measures.
rough review of ministry and sample school documents, we verified that all key
performance reporting requirements, as communicated through the various source
documents, were being submied by Group4 schools. In this way, we verified that schools
understood the reporting requirements and reported back to the ministry as expected.
Evaluating performance of Group 4 schools
We found that the ministry uses reported performance data to evaluate the delivery of
education programs by Group4 schools at the individual school level. e ministry compiles
performance data received from schools to provide inspection teams with data reports to
inform performance conversations during annual inspections. ese reports include key
school and student data for the most recent five years, such as:
enrolment levels by grade
comparisons between course and exam marks for individual schools and for
other schools
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GROUP 4 SCHOOLSKEY FINDINGS AND RECOMMENDATIONS
graduation rates compared with those of public and independent schools
transition rates to B.C. public post-secondary institutions
In discussions with school inspectors, we heard that these reports are highly valued by
both inspectors and school administrators, and they form an important part of inspection
discussions. ey are used to help highlight areas where schools might need to make changes
in the way they deliver their programs, and they provide an opportunity for discussions
regarding possible strategies to improve student outcomes.
We found that the ministry does not generally evaluate the performance of Group4 schools
collectively, as a unique international education program. e Independent School Act
governs all independent schools, including Group4 schools. Because all types of independent
schools fall under the same legislation, the ministry inspection process and performance
management activities are generally inclusive of all independent schools.
However, in 2016/17 the ministry assigned the inspection of virtually all Group4 schools to
a single inspection team so that the ministry might get a greater sense of key performance
issues related specifically to this type of school. At the conclusion of the inspection cycle,
the ministry requested a compilation of the inspection lead’s personal observations and
recommendations. is initiative provided information on the performance of Group4
schools collectively, as well as several recommendations from the inspector that were
considered by the ministry, including recommendations to:
adjust bonding deadlines
establish fees for inspections
require Group4 schools to provide professional development for their sta
require Group4 schools to assess language skills of applicant students
Because Group4 schools operate so dierently from other independent schools, a regular
evaluation of the collective performance of Group4 schools would give the ministry
information on performance trends—both successes and challenges. In addition, regular
evaluation of Group4 schools as a program would provide an opportunity to compare trends
and issues with the performance of oshore schools.
RECOMMENDATION 8: We recommend that the Ministry of Education establish a
regular process for evaluating the performance of Group4 schools as a unique group
of independent schools.
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AUDITOR GENERAL OF BRITISH COLUMBIA | NOVEMBER 2020 | OVERSIGHT OF INTERNATIONAL EDUCATION PROGRAMS IN OFFSHORE AND GROUP 4 SCHOOLS
AUDIT QUALITY ASSURANCE
We conducted this audit under the authority of section 11(8) of the Auditor General Act. All
work in this audit was performed to a reasonable level of assurance in accordance with the
Canadian Standard on Assurance Engagements (CSAE) 3001—Direct Engagements, set out
by the Chartered Professional Accountants of Canada (CPA Canada) in the CPA Canada
Handbook—Assurance. ese standards require that we comply with ethical requirements
and conduct the audit to independently express a conclusion on whether the subject maer
complies in all significant respects to the applicable criteria.
e Oce applies the CPA Canadian Standard on Quality Control 1 (CSQC1) and, accordingly,
maintains a comprehensive system of quality control, including documented policies and
procedures regarding compliance with ethical requirements, professional standards and
applicable legal and regulatory requirements. In this respect, we have complied with the
independence and other requirements of the code of ethics applicable to the practice of
public accounting issued by the Chartered Professional Accountants of B.C., which are
founded on the principles of integrity, objectivity and professional competence, as well as due
care, confidentiality and professional behaviour.
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AUDITOR GENERAL OF BRITISH COLUMBIA | NOVEMBER 2020 | OVERSIGHT OF INTERNATIONAL EDUCATION PROGRAMS IN OFFSHORE AND GROUP 4 SCHOOLS
APPENDIX A: COMPLETE AUDIT CRITERIA
Certification
Criterion 1: e ministry has established certification requirements that address the
responsibilities of schools delivering the B.C. education program, including:
finance and facilities
program direction, development and implementation
student access and achievement
teaching performance
system evaluation and public accountability
Criterion 2: e ministry has established certification requirements that address the
responsibilities of applicant school operators to be in good standing and to have the business
plans and financial resources to sustainably operate their school.
Criterion 3: e ministry confirms that schools meet certification requirements before
certifying them.
Compliance monitoring
Criterion 4: e ministry monitors schools for compliance with certification requirements.
Criterion 5: e ministry takes corrective action when a school is not compliant.
Performance monitoring
Criterion 6: e ministry communicates performance reporting requirements to schools,
including:
student achievement
graduation rates
transition rates
Criterion 7: e ministry uses reported performance data to evaluate the delivery of
education programs by Group4/oshore schools.
AUDIT TEAM
Sheila Dodds,
Assistant Auditor General
Jacqueline McDonald,
Director, Performance Audit
Peter Argast,
Manager, Performance Audit
Barbara Underhill,
Manager, Performance Audit
Ruwa Mgodi,
Auditor, Performance Audit
Emily Braeuer,
Analyst, Performance Audit
SUBJECT MATTER EXPERT
Peter Drescher,
Education Development Consultant
and Inspection Chair
LOCATION
623 Fort Street
Victoria, British Columbia
Canada V8W 1G1
OFFICE HOURS
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8:30 am – 4:30 pm
Telephone: 250-419-6100
Toll-free through Enquiry BC: 1-800-663-7867
In Vancouver: 604-660-2421
FAX: 250-387-1230
EMAIL: bcauditor@bcauditor.com
WEBSITE: www.bcauditor.com
is report and others are available at our website,
which also contains further information about
the oce.
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