The Political Process of International Education: Complementarities and Clashes in the Manitoba K-12 Sector through a Multi-level Governance Lens

International education has become a policy sector of growing importance to Canada. With increased government regulations, disconnect is often observed between the intended policy outcomes and practice. This study aims to explain this disconnect by analyzing the heterogeneity among stakeholder interests. It focuses on 1) distribution of authority; 2) heterogeneity of values; and 3) complementarities and clashes in policy issues. A multi-level governance (MLG) framework (Chou et. al., 2017; Hooghe & Marks, 2003), as a guiding theoretical lens, is applied to examine the interactions among governments (federal-provincial), non-governmental organizations, school administrators, international students and their families in the context of the Manitoba K-12 sector. Data for this study were collected through document analysis and 40 semi-structured interviews. Findings indicate increased steering power of both the federal and provincial governments to regulate international education with conflicting agendas based on political ideologies. The pursuit of Canada’s economic competitiveness through K-12 international education has Education Policy Analysis Archives Vol. 28 No. 1 2 led to a rise in the authority of non-governmental actors, including parents and students, to shape the services, programs and curriculum content offered by public schools. The study proposes adding an additional layer to the MLG framework, that of the complexities within stakeholder groups.


Introduction
International education has become a policy area where global competition for talent has provided strong incentives for governments and educational institutions to work closely together (Marginson et al., 2011;Scott et al., 2015;Yonezawa, & Shimmi, 2015). Competition for highly skilled migrants and economic incentives are seen to be the prominent drivers for governments to engage in international education policy (Boucher & Cerna, 2014;Hawthorne, 2010;Trilokekar & El Masri, 2017). Consequently, it is assumed that governments are pursuing a coherent line of policies, responding primarily to economic pressures. This literature, however, ignores the complexity of the policy-making process that is ingrained with conflicting values and stakeholder interests that have direct impacts on policy and practice.
Significant evidence shows how governments' policy attempts to secure immigration pathways for international students have not necessarily translated into practice (see Coffey et al., 2018;Scott et al., 2015). Intercultural perspectives, so often embraced in the policy documents, do not always materialize in curriculum or teaching practice (Guo & Guo, 2017). Sá and Sabzalieva (2018) examined international education policies in the UK, Australia and Canada and concluded that the growth in international student mobility numbers appears to occur despite rather than because of political and policy changes. These examples demonstrate that government policies may fall short in delivering intended outcomes. Rather than supporting international education, they represent the "desired and imagined futures" (Rizvi & Lingard, 2010) of governments, while 'stitching together' competing interests and values.
Decisions concerning international education are inherently political (Buckner & Stein, 2019;Johnstone & Lee, 2017). Kenway (1990) has argued that policies represent "the temporary settlements between diverse, competing, and unequal forces within civil society" (p. 59). Thus policies may encompass "the authoritative allocation of values" (Rizvi & Lingard, 2010), having direct implications for students and shaping national education systems and global educational developments. The complexity of policy-making in international education is deepened by the fact that it has become a policy area that cuts across many policy sectors such as education, economic development, labour markets, immigration, trade, foreign relations, health, research and innovation. It is crucial to know more about how public policies are shaped and examine how policies get translated into local contexts.
The objective of this paper is to examine the complexity of governments' policy-making in international education and to analyze the conflicting values and power struggles among stakeholders. This paper focuses on the K-12 1 sector in its analysis, examining the relationship between the Canadian federal government, the Manitoba provincial government, non-government organizations (e.g. MCIE, CMEC, CAPS-I), K-12 sector school administrators, and international students and their parents, all of whom are all operating in the context of international education policy. There is a dearth of research on international education policy in the K-12 sector despite a wealth of research on the topic at the post-secondary level. However, the K-12 sector is more regulated than the post-secondary sector and may therefore be more directly impacted by government policy. Furthermore, the perspectives of international students and their families are often excluded from policy discussions even though they are directly impacted by international education policies. The following research question guides the study: How can multi-level governance framework, as a theoretical approach, explain the political process of international education policy in the K-12 sector in Manitoba? By using multi-level governance theory, this paper examines the dynamics between the governments and other stakeholders groups, analyzing the complementarities and clashes in values that guide internationalization initiatives in the province. The paper highlights the importance of viewing international education as a multi-layered complex political process shaped by diverse stakeholder interests with implications for practice.

Context
Canada has seen exponential growth in international student enrolments over the past few years. The Canadian Bureau of International Education (CBIE) reported that Canada had "another record year" for international education with 572,415 international students in 2018, representing a 16% increase over 2017 (CBIE, 2019). Students enrolled in K-12 schools accounted for 14% of this number (CBIE, 2018). International students contributed $15.5 billion to Canada's economy through tuition, accommodation and discretionary spending in 2016 (Roslyn Kunin & Associates, 2017). Therefore, most provinces in Canada see international education as a beneficial mechanism to secure skilled labour and enhance economic growth locally.
Nevertheless, the policy scene in Canadian international education has been rather cautious and fragmented, lacking collaboration and coherence (Jones, 2009;Sá & Sabzalieva, 2018). Canada introduced its national strategy for international education only in 2014. Several provincial strategic documents for international education were developed in the early 2000s. Canada, lacks a federal Ministry of Education, and education throughout the country is governed by the provincial and territorial governments.  noted that the Canadian federal government has consciously avoided investing in initiatives that could be interpreted as 'educational', as it has regarded such initiatives as a provincial responsibility. Nevertheless, Canada's domestic labour market needs, its aging population, and increasing dependence on immigration have served as prominent policy drivers for the federal approach to international education. Scholars have been critical towards the growing steering role of the federal government in international education and its perception of international students as ideal immigrants (Trilokekar & El Masri, 2017). Attracting and retaining highly educated immigrants helps to increase Canada's competitive advantage, yet these individuals often experience higher unemployment rates, earn less, and are overrepresented among the poor (Sakamoto et al., 2013). Furthermore, Canada is a primary beneficiary of highly skilled immigrants, which reinforces global inequalities in an already highly uneven geopolitical landscape (Stein, Andreotti & Suša, 2019).
At the federal level, Canada was governed by the Liberal Party from 1993 until 2006, followed by the Conservative Party from 2006-2015. The Liberal Party won the election again in 2015 and is in power presently. International education as a trade policy framework was developed under a Liberal government and further strengthened under the subsequent Conservative government. The main policy shifts have taken place under the Conservative government.  noted that, at the federal level, the Conservatives have made larger investments in the international education arena. They were the first federal government to develop an international education strategy for Canada. Changes in immigration policy with the Canadian Experience Class (2008) and Express Entry immigration selection system (2015) have had great impact for international students who had an employment record in Canada (Bhuyan et al., 2017;Sá & Sabzalieva, 2018). In early 2016, the new Liberal government committed to a review of Express Entry to reduce further barriers to permanent residency for international students (Zilio & Chiose, 2016). This is direct evidence of government affirming a stronger steering power in the global marketplace for talent and implementing policies that help to secure pathways for international students to settle and become skilled labourers.
Provincial governments, responsible for education, have played a key role in facilitating developments in international education. In 2018, Manitoba welcomed record numbers of international students, with enrolment in schools and post-secondary institutions reaching 18,725, an increase of 17% (Kusch, 2019). While all regions of Canada have seen a significant growth in the number of international students they are hosting, proportionally Ontario and Manitoba have shown the most year-over-year growth (CBIE, 2017). Tamtik (2018) argued that the steady growth of international students in Manitoba can be partly explained by the strong government policy support of the New Democratic Party (NDP) government until 2016.
In 2016, the Progressive Conservative (PC) Party won the elections in Manitoba, ending a 17year era of power for the New Democratic Party (1999)(2000)(2001)(2002)(2003)(2004)(2005)(2006)(2007)(2008)(2009)(2010)(2011)(2012)(2013)(2014)(2015)(2016). This change in government was followed by several striking changes in the international education arena. The International Education Branch, once the leading unit for international education in the provincial government, was dissolved and its responsibilities were redistributed across several departments. The province was left without an updated International Education Strategy (or revised goals for provincial IE activities). Furthermore, in the fall of 2017, the provincial government decided to introduce an Enrollment Cap Policy in Manitoba K-12 Schools, which placed a 20% cap on the enrollment of international students in any one school in a given school year (Government of Manitoba, 2017). This policy directly conflicted with the goals for international education set by the federal Conservative government (Government of Canada, 2014). The conflict evident from provincial policy changes demonstrates how international education has become a battlefield for the "authoritative allocation of values" (Easton, 1953).

Theoretical Framework
Multi-level governance (MLG) theory was used to frame this study (Hooghe & Marks, 2003;Marks, 1993). This theory views policy-making as a negotiated process and emphasizes interdependency among stakeholders' resources and interests. It ce onsiders political actors as interestoriented, constantly acting according to their agendas, yet constrained by institutional rules and organizational norms. The changing role of the territorial state, increasing globalization, and the internationalization of education have resulted in the need to approach contemporary governance dynamics from a MLG perspective (Fumasoli, 2015;Jones & Oleksiyenko, 2011). The MLG approach allows researchers to focus on a system as a unit of analysis and acknowledges stakeholder relationships across multiple levels of authority. This approach also takes into account the increasingly dispersed group of stakeholders involved in policy-making, a phenomenon that can lead to a weakened steering role and authority for a national government. Hooghe and Marks (2003) differentiated between two distinct types of multi-level governance: Type I, in which different levels of authority are neatly nested within each other and form a fixed system of governance (e.g. federalism), and Type II, where the focus is on issue or task jurisdictions across different levels of authority where jurisdictions may overlap (as in international education). These two categories may not be sufficient to examine stakeholder dynamics across policy sectors, as each sector might have a distinct method of coordination and uphold their unique sectorial rationales (Vukasovic et. al., 2017). Therefore, this binary perspective does not facilitate analyzing the influence of non-government stakeholders (parents, students, schools, school boards, professional organizations) either. As such,  developed an analytical frame within MLG to allow the use of a more nuanced lens. This frame focuses on the following: 1) multi-level characteristics of government (focus on antecedents and consequences of distribution of authority across governance levels); 2) multi-actors characteristics (focus on the state and its institutions and non-state actors); 3) multi-issue characteristics (focus on emerging policy issues, identifying clashes and complementarities). This analytic frame is more helpful as it highlights the importance of contextuality and views policies as political processes shaped by the actors, their interests, and organizational capacities. Gornitzka and Maassen (2017) argued that multi-level governance theory with the analytic frame focusing on multi-level, -actor, and -issue perspectives helps to bring forward the complexity of policy-process, yet it may not necessarily lead to increased policy coordination as different strategies provide different actors with leeway for opportunistic behaviours. They pointed out that MLG may help to explain why policies do not necessarily translate into practice. In this paper, we argue that MLG can be used as a lens to bring forward the policy complexities but also to explain how policies can lead to different outcomes, decoupled from the actual developments and policies across different levels of government as is shown in the context of international education in Manitoba.

Methodology
This paper draws on document analysis (7) and semi-structured stakeholder interviews (40).  , 2017). Information was also collected from government and non-government stakeholder websites (e.g. CAPS-I, MCIE) to understand what these actors do, and to examine how they understand internationalization. The selection criteria for documents involved: 1) most recent strategic plans and policies governing international education federally and provincially in Manitoba; 2) direct relevance to international education (including trade policies); 3) public accessibility (publicly available online). The aim of the document analysis was to collect information on the system-wide actors, focus on the issues associated with international education across policy sectors, and explore stakeholder position and authority in the system. We also looked for key terms and concepts that were associated (or not) with internationalization, revealing the silent issues and policy problems linked with international education.
In-person interviews were carried out with government officials in the provincial International Education Branch (4); school administrators in Manitoba (4); parents of international students (14); and international students (18). We did not interview individuals from non-governmental organizations; however, their importance emerged from the other interviews. The IEB Unit, a branch of Manitoba Education and Training, had an overall mandate of overseeing, developing and implementing international education policy in the province. The officers had been working in the branch between 2.5 and 10 years. Each officer was also responsible for a specific portfolio (e.g. overseeing provincially affiliated schools overseas, facilitating the implementation the International Education Act, liaising with other provincial units). The school administrators were working as International Student Program (ISP) coordinators and managers. They had a variety of experience in the area. Two were working in their positions for about two years yet being involved in international student programs previously in other capacities (e.g. working as a homestay program manager). Two had more than 10 years of experience in the field. The students interviewed were studying in Grades 6, 10, 11, and 12 at various public schools in the Pembina Trails School Division in Winnipeg, Manitoba. Their program length was mainly one year. The parents were located in their home countries. The students were interviewed at the end of their yearlong study, shortly before their trip back home. The students represented the following countries: Brazil (1), China (1), Germany (1), Hong Kong (1), Italy (7), Japan (1), Mexico (1), and Spain (5). Students' inclusion criteria involved their participation in the International Student Program, their parents' consent, and their own assent to participate in the study. Parents represented the following countries: Spain (3), Italy (4), China (2), Japan (2), Norway (1), Germany (1), and Mexico (1). Only those parents with sufficient English skills responded to the call to participate and were included in the study. In one case, a student served as an interpreter for her parents. The data collection process involved various levels of Ethics approvals, including approvals from the University of Manitoba Ethics Board, the school division's consent, parental consent, and, finally, students' assent. The first contact with the participants was made by email, after which a time for an interview was scheduled. Reaching the parents required a willingness from the divisional ISP coordinator to send out a formal invitation to parents on behalf of the researcher. Interested parents could then reach out directly to the researcher by email, revealing the contact information of their child. The process was time consuming and largely dependent on the school administrators' willingness to assist. In this case, all school administrators were extremely cooperative and helpful. All interviews with the government officials were conducted face-to-face. Other interviews were conducted mostly via Skype at the participants' requests and/or for logistical reasons (as parents were located overseas and several students were travelling). Participants received interview questions in advance together with the individual consent forms. Interviews were recorded, transcribed, and analyzed.
Textual analysis of documents and interview transcripts was performed through deductive categorization (Bogdan & Biklen, 2006;Burnard, 1991;Creswell, 1998), whereby the structure of analysis was operationalized on the basis of previous knowledge, directly informed by our theoretical framework. The main categorization matrix, as our starting point for data analysis, included the following categories: 1) themes on multi-level perspectives (e.g. distribution of authority leading to cooperation, resistance or legitimacy building among stakeholders); 2) themes on multi-issue perspectives (e.g. issues emerging from the heterogeneity of values such as liberal vs conservative, heterogeneity in perceived benefits of IE such as economic vs political, academic or cultural); 3) themes on multi-actor perspectives (e.g. emerging policy issues, such as competitiveness vs quality of education, policies that support and those that restrict IE). All data were initially coded in correspondence to this three-category matrix. For example, any mention in documents or interviews in regards of multi-level, multi-actor or multi-issue perspectives was highlighted and grouped together based on the three broad categories mentioned above. Next, these broad higher order categories were gradually developed into more specific and nuanced groups (e.g. factors influencing authority across levels, diversity of stakeholder perspectives, evidence of authority shifts across stakeholders). Through such in-depth analysis, unique themes were identified within the three broader groups (Burns & Grove, 2005;Elo & Kyngäs, 2008). For example, a unique theme of complexity within each stakeholder group (as opposed to between and across stakeholder groups) emerged through such nuanced analysis, a theme not mentioned previously in the theoretical frame.
As this theme did not fit into the three-category matrix, it formed a category on its own, leading to the adaptation of Chou et al.'s (2017) analytical frame. This updated framework proved to be very helpful in order to see and compare the differences in values and ideologies across the stakeholder groups, helping to explain disconnect in the policy outcomes of international education.
To secure trustworthiness, each researcher conducted her own categorization independently. Then, several meetings among the researchers were conducted to discuss and agree upon the way in which the data were categorized, and distinct themes were identified within the matrix. Content validation was achieved through member checking (Creswell & Miller, 2000); interview summaries were sent to participants for verification to ensure that their experiences were correctly understood. This process facilitated additional understandings, resolved coding disparities, and ultimately yielded full agreement about the coding of each theme between the two researchers.

Findings
In presenting the findings of the study, we follow the three categories proposed by Chou et al. (2017), examining first the distribution of authority across the stakeholder groups (the category of multi-level characteristics), then analyzing the heterogeneity of values among stakeholders (the category of multi-actor characteristics) and, subsequently, describing the complementarities and clashes between stakeholder groups (the category of multi-issue characteristics). Within each section, we describe the unique themes that emerged from the data. Furthermore, our data indicated that there were noteworthy differences within stakeholder groups. Therefore, a fourth layer of the MLG framework was added -complexities within stakeholder groups -that allowed for a more systematic and nuanced approach to analysis.

Distribution of Authority across the Levels
International education has become a policy area that crosses boundaries across policy sectors and levels of government and as such involves a growing number of stakeholder groups. This has, on one hand, pushed towards closer cooperation among stakeholders, and, on the other hand, provided opportunities for individual stakeholders to increase their own legitimacy and authority as actors in international education. All participants in this study representing the schools as well as those from the provincial government referred to the notion of closer cooperation. For example, schools administrators emphasized closer cooperation with other schools ("the schools are not doing it [cooperating on IE] on their own so much but they're doing it together") and with international education organizations such as CAPS-I or MCIE ("we do work a lot with the CAPS-I guidelines and policies," "We wanted to match our goals with theirs [CAPS-I]," "MCIE and the province work really closely together and all of us, all of the institutes that belong to MCIE"). All provincial government representatives mentioned stronger connections with the federal government ("we work together as provinces and then we bring in the federal government as our partner," "we have to work collaboratively with them [the federal government] because students need in many cases visas and study permits to come"). A participant working at the provincial government summarized the situation with international education policy, saying, "The international part belongs to the feds and the education part belongs to the provinces and so international education is kind of right in between, so we have to work with the federal government." Policy decisions concerning immigration or labour markets are made at the federal level, leaving little room for the provinces to resist or challenge them. However, provinces have the authority to use those opportunities for building their own momentum locally. For example, in 2014, Citizenship and Immigration Canada (now Immigration, Refugees and Citizenship Canada) adopted a policy that requires provinces to prepare a list of Designated Learning Institutions (DLI) that can issue acceptance letters for international students. It was left in the hands of the provinces to determine which educational institutions could be included to the list and how. The Manitoba provincial government developed a legally binding document, the "International Education Act" (IEA), and a regulatory document, "The Code of Conduct," that regulate the practice of offering programs to international students. That Act placed Manitoba above all other provinces as the first to have formal legislation in place for international education. Informants in this study, representing both schools and the provincial government, recognized how the IEA has been an important piece of regulation, suggesting an increased trust in the provincial government. A school administrator reflected: "It [the International Education Act] gives us credibility," another noted: "The province of Manitoba has been very, very good. Manitoba [government] wants us to make sure that we are working with good agents /.../ we are looking at them [the provincial government] now." Marketing activity, as an essential component for recruiting international students, was brought up by school administrators as well as by provincial government representatives ("our best marketing tool is students that are here in our program," "I think it's the marketing strategies that have brought success," "we will go on recruitment trips to Germany and to South America, to Spain, Italy, because we want to grow those markets.") The availability of provincial funds for recruitment activities has been an additional incentive that has drawn school administrators towards the provincial government. As an administrator noted: "We have a very limited budget for travel and recruitment overseas. So, this is one of the areas that I am working with the province now." Our analysis suggests a rise of authority among the other non-governmental stakeholder groups relevant to K-12 education. The most prominent is the Canadian Association of Public Schools-International (CAPS-I). CAPS-I is committed to advocacy and the promotion of international education programs among Canadian K-12 public schools. Among other advocacy activities, CAPS-I works closely with the federal government regarding issues around immigration. A school administrator reflected on the growing importance of CAPS-I: "CAPS-I has grown tremendously. I think we have over a hundred and twenty school boards that belong to CAPS-I now. CAPS-I works very closely with the federal government as a national association." As a result of its work, CAPS-I is able to receive information directly from the federal government and has established a clear authority among school administrators. One school administrator made a strong statement confirming the legitimacy of CAPS-I: "If I had to choose between asking a question about policy or guidelines or procedures to CAPS-I or to the International Education Branch [the provincial government], I would probably call CAPS-I first." Another organization with growing legitimacy among educational stakeholders is the Council of Ministers of Education Canada (CMEC). CMEC has created a pan-Canadian committee where directors responsible for international education in the provinces and territories meet and consult. In its strategic plan, CMEC claims its primary coordinating role "in international education-related meetings and on the world stage" (CMEC, 2017). CMEC has signed an understanding with the Department of Foreign Affairs and International Trade (now Global Affairs Canada), intended to facilitate the contribution of the provincial governments' perspectives internationally. CMEC operates at a higher government level and serves as another example of how distribution of authority has created opportunities for pan-Canadian associations to increase their role as lobby groups by creating a platform for collective action among provincial-territorial stakeholders.
A fundamental role in maintaining international education initiatives in K-12 schools is given to school administrators. It is important that schools ensure the high quality of education and secure the overall positive learning experience among students. Increasing numbers have also drawn more attention to the potential for growth in the K-12 sector. As a result, school administrators have experienced increased power in their communication with the federal government. One administrator reflected: Some of the CIC people, the policy people, know me now. So, they will phone, just have a chat, see what do I think of this from a K to 12 perspective. So, 10 years ago that wouldn't have happened. They would just run these policies through and say, oh yeah, I forgot about K to 12. So, it is certainly getting better.
Finally, it is the families and the international students that are making the final decisions about studying abroad. As competition becomes more heightened among countries and educational institutions, the family's decision-making power and authority has increased. As paying customers, parents and students have become more selective in their decisions. A parent reflected: "While we considered other countries such as the United Kingdom, Ireland, and the USA, we ultimately chose Canada." Several parents and students commented on an aspect of their decision-making process, sharing about specific factors or anticipated benefits influencing their choice in favour of Canada over any other country. Factors such as easier visa process ("We chose Canada partly because the easier visa process than in the USA"), quality of education, country's reputation ("The decision to choose Canada was based on the quality of the education system, the chance to go to an Englishspeaking school, and the reputation of the country") and Canada being a bilingual country ("the chance to improve French alongside English") were mentioned. The following quote from a parent summarizes their thinking: "As a parent, you always want the best for your children. Expectations are very high." School administrators concurred that the competition has increased and that parents have become the ultimate decision-making authority ("I will show a parent on the map where Winnipeg is, and we have to tell them that we actually have heat in Winnipeg and the students are not just sitting in snowmobile suits in an igloo in a classroom"). Competition pushes Manitoba educators to work twice as hard in order to attract students. Often this involves recruitment agents and companies that work on behalf of the school, enhancing the power and influence of agents in the process. School administrators, and students in particular, mentioned working with an agency or recruitment agents for their study abroad decisions ("My agent talked to my Mom about the places that she has sent kids before and one of them was Winnipeg"). An administrator stated that "most of our students come from agents. We have literally hundreds and hundreds of recruitment agents around the world." This situation makes it especially important for school administrators to maintain great relationships and keep the communication flowing with the agents. These examples show that the distribution of authority across government levels has opened up spaces for government and non-government stakeholders to collaborate in order to increase their individual authority and influence. At the same time, these collaborations take place within the overall framework of established authority, providing opportunities for stakeholders with less power such as parents, school administrators, and NGOs to increase their influence and legitimacy through these processes.

Heterogeneity of Values across Stakeholder Groups
Knight's (2012, p. 28) statement that "internationalization means different things to different people" speaks to the reality in the data of distinct and sometimes conflicting values of stakeholders. The dominant theme that emerged from the findings was the value -difference based on political ideologies. While both liberal and conservative governments have viewed international education as a useful mechanism for skilled labour and economic growth, the core difference has emerged in how the integration of international students into Canadian society should happen. The liberal worldview supports multiculturalism and enrichment by cultural diversity, which is in conflict with the conservative ideology promoting ethnocentric nationalism through cultural assimilation.
This ideological difference translates into how international education has been view ed in the policy documents. The International Education Strategy developed under the federal conservative government emphasizes Canada's objective of "attracting more than 450,000 international students to Canada by 2022" (Government of Canada, 2014, p. 11). This document highlights the economic impact of the strategy through the number of new jobs created, yet it largely ignores the aspect of how to support educational institutions locally to accommodate these international students. The local policy response seen in the International Education Act and consecutive Guide to the Code of Practice from the Manitoba provincial NDP government is more regulative in nature, aiming to secure coherence and quality of educational services locally.
This regulative nature of policies was extended in the recent Manitoba PCs' K-12 Enrolment Cap Policy whereby they limit the number of international students in the classroom to 20% of the total student pool. The stated objective of this regulation is to "safeguard the high quality of the existing Manitoba educational experience and the integrity of the Manitoba high school diploma" (Government of Manitoba, 2017), indicating the increasing number of international students essentially as a threat to the quality and integrity of public education. This policy document marks an ideological shift away from a dominant discourse that views internationalisation as a necessary and desirable component of Manitoba's education strategy, addressing it as a problem that needs monitoring and safeguarding. Interestingly, while the federal government's goal of student numbers has already been surpassed (CBIE, 2019), the provincially set cap of 20% of international students is still a far-off target by most public schools in Manitoba. These developments indicate a potentially reactionary policy approach to the already occurring mobility trend on the part of the federal government. They denote a largely a populist approach from the provincial government to shaping the perception of local taxpayers, showing that the growth of student numbers will not come at the expense of the local population.
In the literature, international education is commonly associated with significant economic benefits for educational stakeholders, especially in the higher education context (Brunner, 2017;Matthews & Lawley, 2011;Robertson, 2011). This view was echoed in Manitoba's International Education Strategy as well as PCs' K-12 Enrolment Cap Policy, which stated that one reason international students are recruited is "to boost enrolment and tuition revenue" (Government of Manitoba, 2017). However, this perspective was not confirmed by the K-12 school administrators in this study, who associated international education primarily with the opportunity to provide multicultural learning experiences for their students ("[the economic benefit] is not the primary reason at all for the program," "international students would help to provide multicultural experiences for our students"). The financial benefits were briefly mentioned by all of them ("the financial part in there because of the way our funding works. The schools do get a part of the revenue that our program generates but they use that money to provide the support for the students first and for most," "there is a cost to educating Canadian students and so, this [tuition fee] is essentially covering those costs"). However, these benefits were emphasized only by one individual working in a school with large numbers of international students who noted: Absolutely the rationales have changed! We no longer need an international student program to enhance diversity. We have a lot of diversity in our school division. For the schools who have a large number of international students, it can be a significant revenue source that will allow them [the schools] to do all kinds of great things for students that they would not be able to do otherwise, if they waited for public funding.
Government representatives hardly mentioned the economic rationales behind the international education agenda. The theme of financial benefit was brought up only once in connection with privately owned educational institutions jeopardizing educational quality in the province. Nevertheless, this theme was very present in the provincial trade documents, wh ere international students are regarded as a group that can "contribute to trade capability," "enhance Manitoba's profile internationally," and "help open doors for future trade and investment" (Government of Manitoba, 2011). School administrators rejected the idea of operating an International Student Program to recruit and support international students for financial purposes. A school administrator noted: The primary purpose of having the international student program in our school division is to help to provide multicultural experiences for our students /.../ This way at least there would be an understanding or exposure to different opinions and values and cultures.
Those perspectives show that the dominant values among educational administrators of Manitoba public schools are predominantly associated with academic and cultural rationales for international education, with a few exceptions from administrators representing schools with larger international student populations. This situation may change in the context of declining local student enrolment and the further radical funding cuts suggested by the provincial government (Government of Manitoba, 2019), whereby schools may be forced to look abroad for additional revenue, similar to the situation long faced by public schools in British Columbia (see Fallon & Poole, 2014). This theme of financial benefit was also very present in the federalprovincial trade documents. Families in this study viewed international education as a long-term investment in their children's future. According to both parent and student groups, international education was seen as a means to enhance one's career prospects, and advance opportunities for post -secondary education. A parent explained, "I do hope that this experience in Canada will benefit his future career development." The number one perceived advantage was the acquisition of fluency in the English language. A student commented, "If you don't know English really well, you can't get a good job. You can, but if you know English, the chances are better." Several students noted that getting into a particular university was one of the most influential factors behind their intentions for early study abroad. While most students had not chosen a specific university before participating in an early study abroad program, the experience itself had an impact on students' decisions regarding further education. As a result, eight students were considering or had already applied to a Canadian university, as they were now familiar with the cultural context. A few students had clear thoughts on their future careers and talked about becoming a doctor, a psychologist, a businessman, a heart surgeon, or a lawyer. All those jobs are associated with the upper-middle class of society, showing how in some cases early study abroad experiences are made mindfully by those considering how to remain in their current socio-economic class or move up the ranks in a society that is increasingly driven by global competition.
Both parent and student groups also recognized the reality of changing global environments, which require adaptation and advanced cultural training. Parents and students expressed the sense that study abroad opportunities would help advance students' global knowledge of world events and help them learn about different cultures ("the experience has given her a new perspective on the world and the society we, and you, live in," "he learns from his international students from Syria, Cuba, Somalia, China. He is getting to know about the international situation compared to Japan"). Parents felt that early exposure to global political situations and diverse cultural norms and traditions would help their children to develop crosscultural competencies and adapt to various cultural aspects early. The following quote from a parent represented this theme: "I think now that we are dealing with global environments. It is vital to have the cultural awareness, knowledge about global situations internationally ." The analysis showed that there is a mutual and shared interest among stakeholders in advancing the international education agenda. The perceived benefits include economic, political, academic, and cultural interests. The main striking difference is the change in political ideology revealed by the recent policy document from the Manitoba provincial government, which purports to restrict the enrolment numbers of international students in K -12 schools. Rather than directly impacting numbers of international students, the cap appears to be a political move without an imminent policy problem, instead demonstrating the ultimate authority of the provincial government and appealing to the values of local taxpayers.

Complementarities and Clashes among Policy Issues
The analysis revealed both complementarities and clashes among stakeholder groups that further show the political nature of the policy process. As noted earlier, international education is commonly viewed as a tool for advancing economically oriented immigration and skilled labour policy by the government. In the federal International Education Strategy, the theme of competitiveness ("to enhance Canada's competitive advantage," "to envision a more prosperous, competitive Canada," "competitiveness as key to success") is mentioned 17 times. Another common theme is the emphasis on Canada's reputation as a study destination. The federal governments' openness in immigration policy is expected to be on par with strengthening "the world-class reputation of Canada's post-secondary education system" (Government of Canada 2014). The Manitoba provincial government's International Education Act is similarly aimed to regulate education providers in order to "enhance Manitoba's education reputation" (Government of Manitoba 2016). The emphasis on competitiveness and reputation from both sides is an effort to increase a status of Canada and Manitoba as leaders in global education markets. High numbers of international students are viewed as both indicators of a competitive edge in education as well as inputs, which will make Manitoba and Canada more advanced in other sectors.
There is a strong impetus for marketization and recruitment activities, which was supported by a branding strategy called EduCanada both at the federal and provincial level until 2016. The federal IE strategy is aligned with the Global Markets Action Plan (2013), which specifies priority markets and emphasizes customized marketing approaches. The Manitoba provincial IE strategy is similarly aligned with the International Trade Strategy for Manitoba (2011) and the Guide to the Code of Practice is aimed to address issues around the marketing of programs of education or training. The focus on advancing competitiveness, reputation, and a marketization agenda is a political process that advances and legitimizes a Western approach to education. It establishes Western knowledge provided in the English language as superior to others. The federal IE strategy only compares Canada to the United States, the United Kingdom, Australia, Germany, and France when describing global competition for international students. For example, the document states, "The United States, United Kingdom, Australia, Germany and France all attracted more international students than Canada" (Government of Canada, 2014, p. 5). It seems that the West is competing with the West, perpetuating inequity. Well-funded marketization activities provide an advantage to Canada; they concentrate power in Canada as one of the 'knowledge keepers' that can provide access to 'legitimate' education valued on a global scale and use this as a strategy for recruiting students (see also Stein & de Andreotti, 2016).
One of the most striking clashes associated with international education policy is the disconnect between the federal government's and the Manitoba provincial governments' policy decisions after 2016. With the shift of government, international education has become less of a policy priority without clear policy support. The Conservative government of Manitoba has not updated its International Education Strategy since it expired in 2013, although the draft had already been developed, as noted our government informant ("So last year, in 2015, we started to work on a new strategy to replace, to renew that existing strategy which expired.... We haven't released that strategy, it was not to be released before the government changed. So now that the government has changed, we are working with the new government to see how to move forward on it"). Recent organizational changes include the elimination of the International Education Branch (IEB) within the provincial government. The responsibilities of the IEB were distributed among three divisions within Manitoba Education and Training in 2017: (a) Post-Secondary Education and Workforce Development, (b) Immigration and Economic Opportunities, and (c) Healthy Child Manitoba Office and K-12 Education. With this restructuring, it remains to be seen how coordination across the units will be achieved and what impacts the restructuring will have on international education in the province.
The aspect of quality is another area in which federal-provincial policy perspectives differ. Because Manitoba is a relatively small player in international student recruitment, it is strongly focused on providing high quality education in order to maintain and increase its student numbers. A government official noted: "We want to make sure that Manitoba promotes a safe, welcoming, high quality, and affordable study experience for K-12 students." This framing of international students as indicators of quality clashes with the restrictive Enrolment Cap Policy. As noted above, one of the rationales for this policy is to maintain the quality and integrity of Manitoba's K-12 education. This rationale implies that international students may lower the quality of public education and reveals a deficit approach to thinking about international students. This approach contradicts the language used by the previous NDP government about valuing international students because they "enhance Manitoba's social fabric, bring unique perspectives to our classrooms and contribute to our economic and community development" (Government of Manitoba, 2008). The enrolment cap policy also "encourages schools to recruit international students from a broad range of countries to ensure diversity in the international student body" (Manitoba Government, 2017). This could be interpreted as an effort to increase global awareness and intercultural competencies by diversifying the student groups, which is in alignment with the views of the educational administrators in this study. However, considering the political ideology, this recommendation may instead be an effort to ensure that no particular cultural or ethnic group becomes so large that it has a potential to shift school culture or change the status quo in Manitoba schools with regards to their potential cultural impact on Manitoba society and curriculum. Within a more ethnocentric political climate, in which public opinion is more socially conservative, the policy could be viewed as an opportunity to shape a public perception that the quality of education at the K-12 level should be maintained by regulating the influx of students from other countries.
The public discourse around quality is appealing to educational administrators and parents alike. Among all educational administrators in this study, as well as most government officials, there was a shared concern over not being able to provide quality services to international students. One administrator noted: "It's not just a matter of us dumping them [international students] off at the school and saying good luck. That is where a lot of the infrastructure and support has to happen." Several parents specifically mentioned that educational quality is the core aspect that swayed their decision in favour of Canada. The perceived quality of education associated with Canadian schools was the most dominant theme that characterized parents' study abroad decisions. Parents explicitly reflected how, in their opinion, the education available in Canada is excellent and at a higher level compared to some other English-speaking countries they were considering, such as the United States or the United Kingdom. In two cases, the quality of high school education was mentioned in relation to broadening future higher education opportunities.

Complexities within Stakeholder Groups
An important aspect that is not currently emphasized in the MLG theory is the within-group dynamic. Our data showed that veiled conflicts were present not only across the stakeholder groups but also within groups. The most evident was the ideological conflict among the provincial governments whereby the New Democratic Party has been supportive of the international education developments in the province, in contrast to the approach taken by the Conservative government. Differences were apparent across the policy sectors within the provincial government as well. Whereas Manitoba's International Trade Strategy focuses on international student contributions to future trade capabilities, immigration, and economic growth, the IE strategy focuses more on the social and cultural benefits international students bring to Manitoba. Tensions among educational administrators were also apparent. For example, two school administrators raised potential inequities in the opportunity to generate additional funding through International Student Programs. One noted: "So up until recently, there was no direct benefit to them [small schools]." Some school with limited resources and/or a different emphasis on international education are afraid of losing out financially ("the schools that don't host any students don't get a lot of money"). In order to promote equality and fairness, at least one school division has decided to distribute the generated income across all schools to avoid inequalities. A school administrator commented: I think that was a change I was really proud of actually. That allows our small schools, a little bit of money, it's only a thousand dollars at this point. But its money that, where they are not handcuffed with what to do with it.
As the K-12 segment of student mobility amounts to about 10% of the total number of international students in Manitoba (Tamtik, 2018), the overall political visibility of K-12 level international mobility is peripheral compared to the post-secondary sector. The main focus of the (federal) government policies and attention is on post-secondary-level student mobility, making other forms of international educational (e.g. language learners, short-term mobility programs, K-12 exchanges) less visible. A school administrator commented: So, we are not being ignored but the bulk of students still come for post-secondary and that is where their [federal] focus has to be. But there are over 20,000 K -12 students over Canada, so we keep reminding the government of that. We are not a small piece of the pie.
This lack of political attention has sometimes caused immigration issues, as most K-12 students are minors and some have experienced difficulties obtaining student visas to enter Canada. It has also indirectly affected the status and visibility of international student programs within schools. Although all ISP administrators in this study spoke positively about their relationship with their school and divisional leadership ("I couldn't have asked for better people. They are so supportive of our program and myself personally," "there haven't been any complaints about my work," "we [school administration] are very passionate [about international education]"), two out of four still mentioned that internationalization activities are not always fully considered within schools and school divisions ("If you could convince my boss to let us hire more people," "I wanted to streamline things, to make it easier for everyone. I don't think it was related to me, but this change was difficult"). An interesting difference emerged within the parent group when discussing future prospects for their children in regard to immigration. Among the parents, the topic of potential immigration for their children did not emerge as a theme. Several parents were from countries with stable political situations and well-paying jobs and they did not see the need for their children to relocate. Only one parent from Japan noted that it might be easier to immigrate to Canada after completing a post-secondary education there: "It's easier to immigrate to Canada than to the US. In Manitoba, you can get 1 to 3 years of work permit after graduation from a post-secondary school. Which can ultimately lead to permanent residency within 2 years." Students were more receptive to the idea. Three students mentioned thinking about moving to an English-speaking country or living in a different country than their own: "I would like to live in an English speaking country like Canada or US or England so it's helping me find a possible destination," "I was thinking of doing my university degree in Canada or the US," "I think cause I think I may have go to the universities in Canada." The financial resources involved in short-term study abroad experiences overseas are significant and include tuition fees, living expenses, travel costs, and other expenditures. Unsurprisingly, the high expenditure related to early study abroad was a topic mentioned by most parents ("The tuition fee is of course quite a lot of money," "we found the tuition fee a bit challenging," "As parents, my wife and I have had to take up extra jobs to meet the tuition fee"). Nevertheless, most parents believed this was an investment in the future of their children to make sure they do well in life ("it [fee payments] is challenging for us but we're very happy and proud of our daughter's development and achievement," "[name of the student] benefit from the stay is worth every penny." Parents recognized the privileged position that they were in, being able to support those decisions financially. The following quote is illustrative of their recognition of their privilege: "The whole operation is not cheap and is definitively reserved to a limited percentage of kids. We could afford it and we consider it worth the expense." The findings demonstrated that, with the considerable costs involved, only parents with financial security can afford for their children to study abroad. Parents viewed an opportunity for the children to study abroad as an opportunity to improve their children's chances to get into university or desirable employment, so they were willing to make those investments. This perspective aligns with previous research, pointing to the idea of maintaining class privilege though international study abroad experiences (Leung, 2013;Waters, 2008).

Conclusion and Discussion
In this paper, we have intended to draw out the complexities and nuances in government policy-making, helping to contribute to the broader understanding of why there is often disconnect between policy and practice when it comes to international education. The following main findings emerged from the analysis. First, even if there is indirect steering apparent from the federal government in Canada with regards to international education, the ultimate decision-making authority lies with the provincial government. Based on the comparison of the themes that emerged from document analysis and informants' responses, we found that international education policies as texts can be used to address an actual policy issue (e.g. secure coherence among educational providers as in Manitoba's IEA; attracting students as potential immigrants), but they can also be used for political purposes without an actual policy problem to advance certain ideologies. The federal International Education Strategy is an example of an attempt to justify and show support for student mobility trends in Canada that were already happening. In addition, the policy documents analyzed in this study emphasized the economic rationales while the interview participants commented primarily on multicultural rationales for administering the International Student Program. Furthermore, the Manitoba provincial Enrolment Cap Policy is an example of an effort to influence the perception of voters (e.g. no preference given to international students over local students, international students framed as threats to the quality of public education, the enrollment numbers of international students not coming close to the 20% mentioned in the documents). In each of these cases, stakeholders furthered their own political agendas in the process of policy making. Such complexities in values may potentially influence local practices and limiting the learning experiences of both international and local students. This could include limiting the resources provided to the students at the school level, influencing the perceptions of employers, and ultimately restricting ethical practices in international education.
Second, the overall trend apparent among both federal and provincial governments is the increasing governmental participation and regulation of international education despite the autonomy of educational institutions. This mirrors Megarrity's (2007) observations in the postsecondary context of increased regulation even as governments espouse neoliberal rhetoric of deregulation and market efficiency. Findings that emerge from this study indicate that this tendency is becoming apparent in the K-12 sector as well. This is closely linked with intertwining of international education with Canada's economic, trade, and immigration interests. As international students are perceived to transition easily into the Canadian labour market with Canadian education credentials and language proficiency, they have become the targets of government immigration policies with various immigration pathways supporting this transition. With increased marketization and competition in the global knowledge economy, national governments are affirming their stronger steering role through regulative policies to secure their competitive edge in a global race for talent and skilled labour. Manitoba's Enrolment Cap Policy is an example of a K-12 regulatory policy approach without an actual policy problem to address. Another example of the increasing steering role of the provincial governments, including that in Manitoba, is the signing of agreements with schools overseas regulating which providers can offer provincial curriculum and award Canadian high school diplomas abroad. The tendency to increased regulation reveals the growing importance of the role of international education in Manitoba and Canada in the eyes of government and suggests both federal and provincial governments expect it to continue expanding. As a response to governments' and educational institutions' actions under neoliberal pressures, scholars are increasingly calling for the adoption of ethical approaches to internationalization (Stein, Andreotti & Suša, 2019).
Third, we also argue that the blurring of boundaries across the authority and power of educational stakeholders has given an impetus for individual stakeholders, particularly nongovernmental stakeholders, to increase their own legitimacy, authority, and power in the international education process. We observed the increasing role of non-governmental organizations (e.g. CAPS-I, MCIE) in K-12 demonstrated by growing memberships and capacity in government lobbying. This finding confirms and adds to the emerging literature, where scholars have documented an increased provincial utilization of control over immigrant selection and the rise of post-secondary educational institutions as non-governmental selection actors for immigration in Canada (Brunner, 2017;McCartney & Metcalfe, 2018). We are witnessing governments incentivizing individual students to invest in their own education, as is evident in growing tuition costs and declining public funding. Consequently, students and their families have gained authority and power in this global market of education as they are courted for the potential economic and cultural benefits they bring to whichever place is able to attract them. As such, families from privileged socio-economic backgrounds are in the position to influence the services, programs, and curriculum content offered by schools working to stay competitive. This finding aligns with others in the literature concerned with how international education programs in Canada are associated with the increasing privatization of public education. A separate stream of research has suggested that international students from privileged families gain valuable social and cultural capital through educational experiences in Canada (see Bosetti, Van Pelt & Allison, 2017;Waters, 2006). This capital is resulting in a new wave of emerging global dominant elites who have arisen with the help of Canadian public schools. Consequently, international education has become a new type of leverage for some individuals to secure access to the labour market and global mobility, including immigration. As such, we see a growing trend of neoliberal influences, encouraged by the governments and implemented through international education policy. This tendency provides opportunities for powerful non-governmental organizations to shape the administrative practices in K-12 international education.
Finally, the MLG framework's emphasis on stakeholder interactions across levels, values, and policy issues was helpful, yet it currently does not provide a distinct lens to analyze differences within one group. MLG is useful as a framework that draws attention to those interactions in more comprehensive ways by examining the power dynamic and dependencies between stakeholder groups, providing new understanding of the policy process in international education. However, our findings have shown that we cannot objectively assume that the values and interests within one group are always similar, coherent, and complementary. Therefore, we propose adding another layer to Chou et al.'s (2017) analytical framework -the complexities within stakeholder groups -for a more cohesive and holistic approach to assessing the political process of international education. The theory focuses on analysis across levels, actors, and policy issues within the multi-level governance framework, yet overlooks the importance of values and norms represented among individuals within one group of actors at one level or related to one policy issue. Understanding the dynamic of those diverse values and norms represented within a single stakeholder group allows for explaining the power relationships between individuals leading to authoritative distribution of values, a notion that was pointed out in the beginning of the paper. Adding this fourth layer allows for more detailed and informed analysis, which would help to show the nuanced complexities within multi-level governance theory and explain the disconnects and differences in the processes of policy formulation and implementation. education policy analysis archives editorial board