Tag: implications

  • strategic implications for UK and Australian universities

    strategic implications for UK and Australian universities

    Aston Education, a Hong Kong-based international education consultancy, has long supported students in securing places at universities in the UK and Australia. However, Hong Kong’s outbound market is changing.

    According to the Hong Kong Education Bureau’s data for the 2023/24 academic year, the growth rate of local students studying abroad stands at just 2%, significantly lower than global market averages. Factors behind this include Hong Kong’s stable job market and rising tuition and living costs overseas—both encouraging families to reconsider traditional study-abroad pathways.

    At the same time, migration incentives such as the UK’s BNO visa scheme have encouraged significant numbers of Hong Kong residents to settle abroad. This movement has contributed to local talent gaps. To help fill these, the Hong Kong government introduced the Top Talent Pass Scheme (TTPS) in late 2022. By September 2024, over 100,000 applications had been received, with more than 95% of successful applicants coming from mainland China. The result is a rapidly changing demographic profile and increasing integration between Hong Kong and the mainland.

    These shifts are mirrored in student priorities. Families—particularly those newly settled in Hong Kong from mainland China—are placing greater emphasis on employment outcomes when considering overseas study. Choice of destination, university, and programme is increasingly shaped by how international qualifications align with career trajectories back in Hong Kong or across the region.

    Against this backdrop, Aston Education has evolved its strategy. The demand from mainland China, especially the GBA, is growing rapidly. In 2022, around 661,200 Chinese students pursued study abroad, a sharp increase from earlier years. And the GBA continues to emerge as an integrated educational and economic region. Several Hong Kong universities have established campuses in Shenzhen, Guangzhou, and Dongguan, further strengthening cross-border academic links.

    For education providers, the GBA presents a unique environment. Language, policy, and cultural familiarity create a landscape where nuanced, locally embedded strategies are vital. With deep roots in Hong Kong and a working understanding of both Cantonese and Mandarin, Aston Education is well positioned to navigate this space. Our approach differs from traditional mainland recruitment: we focus on a culturally blended student population, many of whom see Hong Kong as a stepping stone for international education and regional employment.

    This shift is not just geographical—it’s philosophical. Understanding why students choose to study abroad, and what they hope to gain, is key to engaging the next generation. By working closely with institutions in the UK and Australia, we aim to provide tailored recruitment support in markets that are evolving beyond traditional patterns.

    As the GBA continues to gain momentum, opportunities abound for international universities ready to think regionally and act locally. Aston Education looks forward to contributing to this conversation—and to building more agile, informed partnerships that reflect the changing realities of the Asian education landscape.

    About the author:

    Boyi Huang is the managing director of Aston Education with over 15 years of experience in international education planning. She holds a postgraduate diploma in international education from the University of Bath She has guided students to top universities across the UK (Oxbridge and G5), the US (Ivy League & Top 20), and Australia (Go8). With strong experience in cross-border admissions and institutional partnerships, Boyi specialises in helping students from Greater China and Southeast Asia access world-class higher education through personalised strategies.

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  • The implications for UK universities of Trump’s attacks on EDI

    The implications for UK universities of Trump’s attacks on EDI

    Few will be unaware of Donald Trump’s antipathy towards diversity, equity, and inclusion (DEI) in the US. In February 2025, Trump issued executive orders and policy directives aimed at eliminating DEI programmes and removing references to “gender ideology” from federal agencies.

    For those of us who know DEI as equality, diversity and inclusion (EDI), there is concern about the ripple effects of Trump’s measures on UK universities, for research as well as teaching and learning.

    One of the immediate impacts of this manoeuvre was to remove essential LGBTQ+ content from federal websites. Terms such as “transgender”, “LGBT”, and “pregnant person” were all banned. Decades of HIV data, contraception guidelines, and research on racial health disparities were suddenly inaccessible. For US researchers in higher education, such staggeringly blatant anti-EDI policies have disrupted the passage of critical research focused on improving health outcomes for marginalised groups.

    Such censorship – to our minds at least – thoroughly undermines scientific integrity, limiting the study of complex health and social issues. Our colleagues in the US are now forced to work within these constraints, which threaten accuracy and inclusivity. Indeed, the politicisation of scientific terminology arguably damages public trust in research and, in the US, diminishes the credibility of federal agencies.

    Implications for LGBTQ+ researchers

    Trump’s anti-EDI stance is a menace to any form of university research seeking to address inequalities and build inclusion for seldom heard population groups, and the effects of these decisions will have wide-reaching and intersectional repercussions.

    As committee members of a university’s LGBTQ+ staff network, our focus is understandably on the impact for our colleagues working on LGBTQ+ issues. US-based researchers working on LGBTQ+ themes now face obstacles in securing funding and publishing their work. And this has a knock-on effect on wider LGBTQ+ population groups. The suppression of critical health information and the suspension of targeted research leaves LGBTQ+ communities bereft of vital support and resources.

    More fundamentally, Trump’s policies send the signal that LGBTQ+ identities and needs are irrelevant from his agenda for US growth. It’s a quick step from this to the increase of social stigma and discrimination targeted at LGBTQ+ people. And this in turn worsens mental health and social marginalisation. To put it bluntly: the absence of LGBTQ+ representation in official communications sends a damaging message about the validity of these communities’ experiences.

    Lessons for UK universities

    To bring this back to the UK context then, a few things come to mind.

    First, the UK has its own, depressingly recent, history of government-led suppression of LGBTQ+ communication, which we’d do well to remember. Section 28 of the Local Government Act 1988 banned the promotion of homosexuality in schools across England, Scotland, and Wales. Repealed in England and Wales in 2003, this act led to years of silence and marginalisation within educational settings.

    Section 28 not only harmed students and staff at the time but also created a culture of fear and misinformation, curtailing inclusive teaching and research. To ensure the UK does not repeat such history, universities must prioritise legal advocacy and protection for all involved in higher education, to safeguard academic freedom and inclusivity. Being involved in the LGBTQ+ staff network as we are, we might also add that coalition building among universities, LGBTQ+ advocacy groups, and non-profits can also strengthen efforts to resist any potential policy shifts that might echo the restrictive measures of the past.

    Second, Trump’s agenda also urges us to re-think our approach to US-UK research collaborations and student exchanges. There seems to be an increasing discrepancy between what the UK and US each consider to be worthy of research and funding.

    Universities in the UK should assess how they foster links with other nations whose research agendas align more closely with UK priorities, to mitigate any potential funding losses. Moreover, UK universities should ideally review their reliance on external funding from the US to determine whether any existing projects might be impacted by shifts in US policy. Equally, with US suppression of data relating to LGBTQ+ issues impacting LGBTQ+ health and wellbeing, it’s vital that UK universities ensure that their research connected to LGBTQ+ issues is readily available.

    Third, it seems crucial that UK universities futureproof their relationships with US students. The possibility of new limitations on exchange programmes, including restrictions on modules with extensive EDI content, could impact the accessibility of UK higher education for US students. Online programmes that currently enrol US students may also face scrutiny, raising concerns about whether course content is monitored or whether degrees will continue to be recognised in the US due to their inclusion of EDI principles.

    Looking forward

    UK universities have a pivotal role to play in responding to what’s happening in the US in relation to Trump’s anti-EDI stance.

    We’ve focused particularly on the impacts of these political and policy shifts on LGBTQ+ research and culture in higher education. But they represent a more wholesale attack on initiatives seeking to safeguard the wellbeing of marginalised population groups. UK universities must continue to represent a safe space for education which upholds inclusivity, critical thinking, and academic integrity. This requires a strong coalition of organisations, advocacy groups, and academic institutions working together to resist the erosion of rights and the suppression of essential research.

    Such a coalition of critically-minded parties seems all the more important given the recent ruling by the Supreme Court on 16 April 2025 in relation to the Equality Act 2010, which insisted on the binary nature of sex, which is determined by biology. As a result, this leaves trans women unable to avail themselves of the sex-based protections enshrined in the Equality Act.

    Universities, like other institutions, will need to review their policies accordingly and should do their utmost to continue to assert a safe and inclusive environment for trans people. But this decision, coming so soon after the Cass review, is also contributing to the anxiety and uncertainty experienced by LGBTQ+ people more broadly. With echoes between the US situation and recent UK developments, the direction of travel is concerning.

    By standing together, we can safeguard the rights of all marginalised communities and ensure that the integrity of scientific research, human dignity, and social progress are protected.

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  • The Foreign Influence Registration Scheme has sector-specific implications

    The Foreign Influence Registration Scheme has sector-specific implications

    The Foreign Influence Registration Scheme (FIRS) emerged out of the National Security Act 2023.

    The idea was that, by way of the mandatory registration of activities broadly defined as involving “foreign influence” on the UK, both the UK’s political system and wider civil society would be made both more transparent and, in the case of certain countries’ actions, less of a national security risk.

    The government published light-touch draft guidance for FIRS in September 2023, promising further detail ahead of implementation – including sector-specific guidance for research, academia and higher education.

    FIRS trap

    Nothing happened for a while, and then following the general election news emerged of a delay to the scheme, seemingly tied up with the question of Labour’s (still ongoing) “China audit” and a (hotly contested) claim that guidance wasn’t ready to go live.

    One particular sticking point has become whether China would be put on the “enhanced tier” of the scheme, a development which would enormously increase the scrutiny faced by all organisations – including universities – involved in partnerships or collaborations with Chinese institutions. The Conservatives were rumoured to have been considering it while in power, and more recently Labour has reportedly been “resisting” such a move.

    Fast forward to today, and there is still no decision over China – but the government has laid draft regulations placing Russia and Iran on the enhanced tier, announced that FIRS will come into operation from 1 July, and published sector-specific guidance for academia and research.

    The additional wrinkle for higher education is that when the Department for Education announced that the Higher Education (Freedom of Speech) Act would go ahead in revised form, it decided that the overseas funding measures in section 9 would be “kept under review” while FIRS was implemented and the interaction between the two was assessed.

    Tiers for FIRS

    You will be glad to learn that FIRS is not “a register of foreign spies” – we even get a short section in a fact sheet to make this clear. It is, however, a register of arrangements – and the individual or power who makes an arrangement with a foreign power (or controlled entity) has to let the Home Office know.

    At heart, FIRS is structured around two tiers: the “political influence tier” and the “enhanced tier”. All countries – except the Republic of Ireland – will be put in one or the other. And the difference between the two is vast.

    Political influence is restricted to specific “directions” from other countries to influence the UK’s political domain. So this involves things like elections and referenda (perish the thought), ministerial or departmental decision-making, political parties’ activities, or the actions of parliamentarians (including in the devolved nations). There’s also the wider concept of influencing “public life”, which includes certain kinds of communications and the disbursement of money.

    Where the Secretary of State deems it necessary to keep the UK safe or protect its interests, they will designate a foreign power (or part thereof) as being subject to the “enhanced tier”. This additionally requires the wider registration of “arrangements to carry out activities at the direction of a foreign power”, or activities carried out in the UK by specified entities controlled by a foreign power. In this case there is the possibility of a tailored approach to address particular risks.

    At each level, the requirement is that you register the activities to be carried out, their nature, their purpose, any intended outcomes – plus start dates, end dates, and frequencies where relevant. Of course registration will include passing on details of who is carrying out the activities, and which foreign power is directing them. Some of this information will be published – but this will be limited to what is needed to achieve the transparency aims of FIRS. Personal details, information that would prejudice personal safety or national security, and commercially sensitive information will not be published.

    Designating a country as being subject to the enhanced tier requires parliamentary approval – and as above this is currently being sought for Iran and Russia. How about China? As will be clear when we turn to some examples below, this is the big question when it comes to FIRS for UK higher education – China being moved up into the advanced tier would greatly complicate all kinds of educational and research initiatives.

    The Conservatives in opposition are pushing strongly for it, though they never bit the bullet while in power. Speaking in the House of Commons today, security minister Dan Jarvis said:

    For reasons that I completely understand, the shadow Home Secretary asked about China. He will recall the remarks I made to this House on 4 March, where I was very clear that countries will be considered separately and decisions will be taken by this Government based on the evidence. I said then, as I say again now, that I will not speculate on which countries may or may not be specified in future. That is the right way to proceed, and I hope he understands that.

    It’s likely the question will continue to recur, every time an issue involving national security and China (or other countries) rears its heads – we should expect calls in Parliament and in the press for a country seen as a national security threat to be moved over to the enhanced tier.

    Direction and production

    For the purposes of FIRS, “direction” implies a power relationship – a contract or conditional payment on the one hand, coercion or the promise of future benefits on the other. So for our purposes a genuine collaboration, or a very generic request, would not count as direction. Neither is something “direction” simply because it is funded by a foreign power.

    The actual registration and publication will be done by a special unit within the Home Office. This will also be the means by which the Secretary of State can issue “information notices” to get more information, or remind you to register activity should you be doing something that it is felt you should tell the Home Office about.

    FIRS is an information gathering tool – it doesn’t restrict anyone’s ability to do anything in and of itself, it simply requires that activity is registered appropriately. And it only applies where you are directed by a foreign power – anything else you do or say on your own behalf is not covered by these requirements.

    At FIRS I was afraid

    The meat of the higher education and research guidance (framed oddly as the “academia and research sector”) is a series of 34 examples, illustrating where registration is required and where it would not be. There’s a potential impact in every area of university and related activity – but rather than go through every example here it would make sense to pick out a handful of points to illustrate some key impacts on research, teaching, and SUs – both for enhanced and political tiers. If this stuff is your job, or becomes your job, chances are you’ll be getting to know these examples very quickly anyway.

    Teaching and recruitment

    Let’s start at the beginning (example 1) – the education department of country A (not subject to the enhanced tier) wants to build a relationship with a UK university: the university gets more students via promotion and enticements within country A, but it also has to lobby the UK government about a short-term visa study programme for students from country A.

    Clearly this is registerable – there’s an arrangement with country A, it is directed, and requires the use of political influence.

    A lot of the concerns that led to the requirements that went into the Higher Education (Freedom of Speech) Act were about the potential for foreign powers to influence what is taught at universities. In example 6, a student from country G (enhanced tier) is studying a human rights course at a UK university, which includes material on the oppression of an ethnic group in country G by its government. The country G embassy contacts the students, and requires them to change course – threatening to force them to leave the UK if they don’t.

    Here it is the student that is obliged to register – they have been obliged, with coercion used, by a foreign power, to change their course. What’s not at all clear is what would convince said student that this would be a good idea, or what protections would be available to them when they reported their own government to UK authorities.

    But what about universities reporting back to an enhanced tier government on student behaviour? Examples 15, 16, and 17 all deal with reporting back to country V: we learn that a student reporting back on their progress, or a university reporting back on results, is not registerable. However, where the student is coerced into organising a protest about a speaker critical of country V, this is registerable (again, by the student).

    Elsewhere on the enhanced tier regulations, there’s been an important concession (following consultation responses) regarding scholarships, which are now exempt from being registered. And importantly, activities carried out wholly at overseas universities – such as transnational education – will not require registration either.

    A Swiss cheese of foreign influence

    The more tedious and public end of the free speech debate has been concerned with otherwise low-profile, little known, escaping the public attention student activity. Student societies, students getting together in their own time, and reasonable debate. Almost entirely absent from the public but not policy discourse has been the regulation of research activity. Put bluntly, the ways in which other countries influence research into lethal weapons has had less political attention than which culture issue The Telegraph is upset about this week.

    The new guidance provides that agents of specified foreign powers will have to register under the enhanced scheme where they are “undertaking a research project directed by a specified foreign power or specified foreign power-controlled entity.” As we learn from the Minister of State for Security Dan Jarvis the current specified countries under the enhanced tier are Iran and Russia.

    This means that individuals directed by Iran, Russia, and whoever else comes under the future ambit of the scheme, would be required to register that they are being directed by these states and declare they are undertaking state directed activity. Somehow, this seems extremely unlikely to capture the full range of state directed activity even with the threat of a five year custodial sentence.

    The scheme is narrowly applied and broadly defined as to avoid capturing a broad swathe of activities. Under the political tier

    Registration would only be required under the political tier if the research formed part of an intentional effort by a foreign power to influence the UK’s democracy, for example, a specific area of government policy.

    This is a really high bar to clear. As we learn further in the guidance activity which is funded and directed by a foreign power will not necessarily count as political influencing activity if researchers are free to arrive at their own recommendations. In other words, it is possible to influence the terms of the debate but not its conclusions and remain outside the scope of the scheme.

    One of the oddities of the regulation is that “activity is only registerable where carried out in the UK.” This would seem to mean that where there are campuses abroad which included UK researchers, researchers from other countries, and researchers who would be a specified power within the UK, activity would be outside of this scheme.

    The political influence tier of activity is designed to capture activities which are directly aimed toward parliamentary mechanisms and procedures. Aside from any debate on whether the specified countries are broad enough this means that political but not parliamentary political activities are not covered either. The guidance specifically states that

    …any published research which intended to influence a political process would not require registration under the political influence tier, if it was clear on the research report that it was completed as part of an arrangement with a foreign power.

    The scope of the research element of the scheme feels very narrow. The examples make clear that a UK provider would need to register under the political scheme where they are lobbying the UK government to further the interests of a foreign power as part of a funding arrangement. An individual would need to register under the political tier where they are acting as an intermediary for selling the technologies of a foreign power. And under the enhanced tier UK universities cannot rely on the ambiguity of a relationship and would seemingly have to register where there are future potential income opportunities.

    It is also made clear that just because activities clear these schemes they do not get a clean slate for other legislation like the National Security and Investment Act. As long as a provider is not taking funding from a foreign power, and especially specific foreign powers, to direct research, funding, and influencing outcomes, they should not be impacted by FIRS. This does not mean they will not be impacted by the bureaucracy of every other scheme.

    FIRS is helpful in setting an obvious floor for what is in scope but the ceiling is cavernous. There is significant latitude for influencing UK politics outside of parliamentary procedures and without directing research outcomes. The participants in the research ecosystem will on the one hand favour the flexibility but will rue the potential for being personally liable for another addition to an increasingly complicated web of international research rules.

    Societies, SUs and CSSAs

    One of the major concerns floating around the press coverage and the think tanks has been the activities of student societies on campus – specifically (but not exclusively), Chinese Students and Scholars Associations (CSSAs).

    Last year a Henry Jackson Society report, Studying Abroad to Serve China, alleged that CSSAs are closely tied to and influenced by the Chinese government, presenting themselves as cultural organisations while actually being integral to China’s “United Front Work” strategy.

    Meanwhile, the Telegraph has published allegations of Chinese students facing serious repercussions, including detention and interrogation in China, after participating in protests or making critical comments about the Chinese government while studying in the UK – which involve CSSAs locally and nationally.

    Like plenty of religious, political and sporting groups on campus, societies of this sort will say that they affiliate to a national body. Many rarely discuss or disclose the ways in which overt or covert control or influence may be placed on their activities.

    The sector-specific guidance covers “student bodies, societies or associations” – but there’s a problem. It appears from the guidance that Home Office officials think that student societies are legally separate bodies from their students’ union. But in the vast majority of cases, they have no separate legal personality – they are part of the SU. That matters because it impacts who has the legal duty to register.

    For example, in a section designed to reassure universities about their own liability to register, the guidance says:

    Where a registerable arrangement is made by a student society of a university: the society is required to register.

    And across three case studies discussing different types of activity, there’s the same issue. So where one describes a society being directed by the government of a country to sign a petition and campaign against a UK government decision, the guidance says:

    The student society is required to register as they are in an arrangement with the government of Country P (foreign power) from whom they receive funding (direction) to undertake campaigning activities to influence a government decision (political influence activities).

    But legally, in most universities the student society doesn’t exist. It’s a part of the SU – placing the onus on the SU to register – and so places duties on underfunded student activities staff to risk assess and probe the activities of societies in ways that many will object to.

    Separate guidance for charities then puts onerous duties on the trustees in the usual way.

    The upshot is that CSSAs – and any other international society undertaking activity of this sort – will soon clock that they themselves are under no legal duty to register. Universities will also take comfort in guidance that makes clear “societies” are separate and have their own reporting duties.

    The buck lands on the SU – who will be thinking hard about disproportionate scrutiny over a group of students that share protected characteristics, and who may object to their treatment by the SU to the university under OfS’ new harassment expectations.

    Not only will the SU not have experience of what amounts to a whole new type of complex risk assessment, it will all happen in a way that actually discourages joined-up risk assessment and sensible concern over the sorts of things the HJS and the Telegraph alleges. You really couldn’t make it up.

    If you believe the allegations that swirl around CSSAs, there are major student welfare concerns here – both for students who might be “under surveillance” from their colleagues, and for students who might be being coerced into watching others and reporting them. If you’re less sure that what the Telegraph or the HSJ say is widespread or even real, then there’s welfare and harassment concerns that surround poking around and applying heavy scrutiny to a particular group of students. And in England, the moment you start to think about potential interactions with free speech requirements and OfS’ new harassment requirements a headache ensues given both seem to cover SUs and societies without directly regulating them.

    If nothing else, the guidance repeatedly states that it’s not that the activity is per se illegal – and if not, is it “free speech within the law” or does the influence chill free speech, and so on and so on and so on.

    It would certainly seem like a good time to consider whether those straight-line cuts to the SU’s already tight budget are wise if junior staff are about to start to have to offer training on these complexities – and front out difficult conversations with those running international student societies.

    Upshots

    All of these new duties kick in on July 1st – so there’s very little time to understand the implications and get houses in order. The question on China and its tier allocation will be one to watch – the allegations are unlikely to go away.

    There are several “foreign influence” offences, including a failure to register a foreign influence arrangement, and carrying out political influence activity where the overarching arrangement is not registered and the person knows that the activity is being directed by a foreign principal. The maximum penalty for failure to comply with the requirements of the political influence tier is 2 years imprisonment – and the maximum penalty in the enhanced tier is 5 years imprisonment.

    If there are those who are carrying out what is currently covert activity who are under pressure to keep it that way – whether through incentives, or threats, or both, there is a real question about the way in which those individuals might evaluate that against any rules put in by a university (or so) in pursuit of the scheme.

    More broadly, it’s yet another thing in terms of regulatory burden – and another one of those things where a duty is being placed on a public authority to do what many would argue is not their job to do at all, that they’re not sufficiently funded to do, and have not even been properly consulted on.

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  • NIH Grant Terminations Have ‘Frightening Implications’ for Science

    NIH Grant Terminations Have ‘Frightening Implications’ for Science

    After months of uncertainty about the future of federally funded research, the National Institutes of Health this month started canceling grants it deemed “nonscientific.”

    So far, that includes research into preventing HIV/AIDS; managing depressive symptoms in transgender, nonbinary and gender-diverse patients; intimate partner violence during pregnancy; and how cancer affects impoverished Americans.

    In letters canceling the grants, the NIH said those and other research projects “no longer [effectuate] agency priorities.”

    But the world’s largest funder of biomedical research didn’t stop there. The agency went on to tell researchers that “research programs based primarily on artificial and nonscientific categories, including amorphous equity objectives, are antithetical to the scientific inquiry, do nothing to expand our knowledge of living systems, provide low returns on investment, and ultimately do not enhance health, lengthen life, or reduce illness,” according to a March 18 letter sent to the University of Nebraska at Lincoln.

    Katie Bogen, a Ph.D. student in the clinical psychology program at UNL, found out via the letter that NIH was canceling the $171,000 grant supporting her dissertation research. She was planning to explore the links between bisexual women’s disclosure of past sexual violence experience to a current romantic partner and subsequent symptoms, including traumatic stress, alcohol use and risk for violence revictimization within their current relationship. She started work on the project last May and was set to start data collection at the end of this month.

    The NIH told Bogen and other researchers that “so-called diversity, equity, and inclusion studies are often used to support unlawful discrimination on the basis of race and other protected characteristics, which harms the health of Americans,” and that NIH policy moving forward won’t support such research programs.

    “No corrective action is possible” for Bogen’s project, because “the premise of this award is incompatible with agency priorities, and no modification of the project could align the project with agency priorities.”

    Last week, Bogen, who told Inside Higher Ed that she was inspired to pursue this topic because she herself is a bisexual woman with a trauma history, posted on TikTok about the termination letter.

    She received thousands of comments and messages lamenting the loss of her work, with some characterizing the letter’s language as “appalling” and “horrifying.” Another commenter, who identified “as a bi femme who has survived the specific harm you’ve been studying,” told Bogen their “heart is broken” for her and other researchers “and all the folks who could be helped by the studies being defunded.”

    Inside Higher Ed interviewed Bogen for more insight into her research and what the NIH’s abrupt cancellation of her and other projects means for public health and the future of scientific discovery.

    (This interview has been edited for clarity and style.)

    Q: What got you interested in researching intimate partner violence prevention for bisexual women? Why do you believe it’s an important line of scientific inquiry?

    A: We know that bisexual women are at an elevated risk of experiencing intimate partner violence and sexual harm. We also know they have higher rates of post-traumatic stress disorder after these experiences compared to other people, and that they have greater and more problematic high-risk alcohol use afterwards. A key part of the process of meaning-making after the experience of violence is disclosure because of ambient bi-negativity. Bisexual people’s disclosure processes are often burdened by anti-bisexual prejudice.

    For example, if you’re a bisexual woman who’s experienced violence at the hands of a woman partner, and you disclose that to a man partner that you’re seeing now, that man partner might say, “How much did she really hurt you?” If you’re a bisexual woman who’s now with a woman and you disclose violence perpetrated by a man, your woman partner might say something like, “This is what you get for dating men. We all know better than to date men.”

    Katie Bogen is a fifth-year clinical psychology Ph.D. student at the University of Nebraska at Lincoln

    So much of the disclosure research on sexual violence victims has been done with formal support providers like police or campus security or therapists, and then informal support providers like friends or parents or siblings. But very little research has documented the exposure process with intimate partners, which seems like a gap, given that intimate partners can then choose to sort of wield that insight or knowledge for good—or for harm.

    I want to study how to intervene so that they don’t develop severe post-traumatic stress and problematic drinking. And this is particularly important because problem drinking is a risk factor for revictimization, and so bisexual women have all of these factors working against them that contribute to the cycle of revictimization and chronic victimization over their life span.

    Q: Can you describe the process of applying for this NIH grant?

    A: In 2022, I had just finished my second year of graduate school when a colleague of mine sent me a funding opportunity from the National Institute on Alcohol Abuse and Alcoholism that had a notice of special interest on the health of bisexual and bisexual-plus people.

    We haven’t even been able to recruit our participants and I have none of the data.”

    I worked very hard for a year on my application. It was the first grant I wrote as a [principal investigator]. I submitted to NIH, and a kind of miracle happened—I scored a 20 on this grant, which means my very first grant being written up as a PI got funded on the first round of peer review, which is almost unheard-of.

    Q: How much of the project had you finished before receiving the termination notice?

    A: I started work last May. I’ve hired and trained an entire lab of undergrads.

    I’ve already done the literature reviews with the help of my undergraduate team and put together and tested the Qualtrics surveys. We set up backup safety measures in case the online surveys were infiltrated by bots or false respondents. The amount of literature I’ve read and the foundational conference presentations and analysis that I’ve run using other available data sets has been an immense labor.

    It has been a productive 10 months. The things that this research has made possible for me—not only as a student and trainee, but as a scientist and as now a mentor helping to train the next generation of scholars—cannot be understated.

    But we haven’t even been able to recruit our participants and I have none of the data. We were slated to begin data collection on March 31, and it’s a shame that will no longer happen.

    Q: The NIH’s termination letter said your project is “antithetical to scientific inquiry” and “harms the health of Americans.” What was your reaction to that characterization of your work?

    A: It hurts to hear that your work isn’t scientific. But it almost made me laugh because it’s so revelatory of the ignorance of folks in positions of power to claim that the work that I’m doing—that my colleagues are doing, that my mentors have taught me to do, that other folks in a field of doing—is ascientific and itself violence.

    To me, the language in the letter is an example of DARVO, which is a rhetorical abuse tactic that stands for deny, attack, reverse victim and offender. They’re saying that what I’m doing isn’t scientific, and that they’re actually trying to uphold the standards of science, and by me focusing on these marginalized groups, I’m harming, quote unquote, real or regular Americans.

    [The termination letter] almost made me laugh because it’s so revelatory of the ignorance of folks in positions of power to claim that the work that I’m doing … is ascientific and itself violence.”

    Q: How does your work benefit society broadly?

    A: Even if we take queerness out of the equation in this model, we are still garnering insight and understanding of the mechanism of post-traumatic stress, alcohol use and intimate partner violence for people in general. We’re getting a deeper understanding of how discussing sexual violence with a partner fundamentally changes that relationship, what is perceived as potentially acceptable in that relationship, norms of conflict within that relationship and sexual norms within that relationship.

    Being able to investigate questions like this and enact scholarship like this could be a balm to some of the self-blame and shame that survivors are experiencing. And when research like this is able to reach health-care providers, public health improves, people become safer and we’re better able to protect folks from things like intimate partner violence, revictimization and sexual revictimization, which is endemic in our society.

    Q: Given that this research grant was a central piece of your plan to complete your dissertation, how does its abrupt cancellation complicate your path toward degree completion?

    A: I now have to work with my mentors to generate a new dissertation proposal and send it to my committee and get it reapproved, which means I have to access data sets at my institution that have either already been collected or that are safe from future rounds of cuts like this.

    I believe I’m being intimidated [by the NIH] into taking the data that are already available, rather than collecting data with more specificity, which means the accurate data answering these research questions is tampered. I don’t necessarily want to go to a data set that was collected on, for example, masculinity and violence perpetration, and try and string together a similar enough model to pass the proxy of what I wanted. That’s poor scholarship.

    It’s something a lot of scholars who are dealing with this crisis are facing now. How does that further marginalize the populations we’re aiming to serve if we’re trying to presume or assume that data on different populations? It creates this ethical and academic quandary.

    Q: How might this termination affect your career in the long term?

    A: I have a demonstrated record of receiving grant funding on my own, which is a difficult thing to demonstrate when you’re still a trainee or you’re still a student. It makes folks more competitive for postdocs, research-oriented internships or research jobs at bigger research institutions down the line. If I wanted to work at an academic hospital, it shows that I’ll be able to bring in grant funding.

    But now I have this really sad line on my CV. I had to write several asterisks that the grant closed early, and I just have to hope that people who are reviewing my CV later know what that means—that the grant closed early, not because of my failure to complete the research, but because we have the infiltration of antiscientific thought in the federal government that forced a number of grants to close early.

    It doesn’t stop at political science, psychology or even economics. It has legs and encroaches and creeps into biophysiological sciences and neuropsychology. It leaves no science safe.”

    Q: How does your situation speak to any concerns you might have about the broader environment for science in this country right now?

    A: We’re in this identity war moment, and it’s not based on anything but people’s own prejudice and bias and a sense of being victimized because they no longer have access to the power they used to. This is an attempt to recollect and to narrow who has that power, which has frightening implications across the board.

    It doesn’t stop at political science, psychology or even economics. It has legs and encroaches and creeps into biophysiological sciences and neuropsychology. It leaves no science safe.



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  • When OfS reopens its register, there will be implications for everyone else

    When OfS reopens its register, there will be implications for everyone else

    The process may be paused right now, but if you are thinking of registering with the Office for Students (by choice, or following the requirement for larger franchise providers to get on board) the game is changing.

    The Office for Students has issued a consultation on two new initial conditions of registration.

    Interested parties have until 23 April to offer feedback, with the overwhelming majority of conditions due to come into force from August – at the point where OfS is planning to resume registration activity following the current pause.

    This will have a particular impact on providers who are currently planning (or preparing to restart) submissions quashed when the pause started. Expectations and requirements will change – and while OfS hopes to primarily assess documents a provider will already have, these things do tend to be tailored to fit requirements.

    C5: Treating students fairly

    New condition C5 replaces C1 (consumer law) and C3 (protection plans) as initial conditions – an assessment will be based on identifying behaviours that constitute unfair treatment of students (there is a list) from documents providers already have.

    There are implications from that one that reach far beyond new applications to the register – Jim Dickinson has covered those in detail elsewhere on the site.

    E7: Effective governance

    This new initial condition replaces the current E1 (on public interest governance) and E2 (on management and governance), though those two remain as ongoing conditions. OfS offers a rationale:

    We are increasingly finding that newly established providers (with less experience of delivering higher education) are less sure about what is required in terms of the self-assessment we ask for at registration. This leads to inefficiencies in the assessment.

    Providers have been engaged in substantial back-and-forth conversations with OfS about what is expected during registration. The regulator has noted that people are describing existing documents where it would be quicker to submit them, and has spotted that what is submitted can often be poorly written and excessively tailored to paint a rosy (and hopefully successful) picture.

    Some applicants have been borrowing and adapting plans and documentation from other providers that are inapplicable (a small, single subject, provider using processes developed for a traditional, multi-faculty, university) – in part because of perceived expectations that newly established providers need to have the same range of processes and policies.

    So the self-assessment aspect will go – the plan is that providers should submit actual governance documents, a five year action plan, and other bits on the knowledge and experience of those involved.

    One surprising shift is that there will no longer be an explicit test of “public interest governance” (the Nolan principles and suchlike) in the registration process. OfS reckon that the strengths of the rest of these new requirements, plus the continued inclusion in ongoing condition E1, makes up for this.

    Ditto the absence of the (largely toothless) student protection plan – the line being that this should be visible to students via the documentation provided, which is a win for all those applicants who read governance documentation before they decide where to apply. See Jim’s piece for more detail.

    Documentation

    So what would you now need to submit:

    • The governing body’s terms of reference (or similar), which would cover purpose, membership, appointment procedures, responsibilities, decision-making procedures, meeting frequency and the arrangements for reviewing effectiveness
    • Establishing documents – like a Royal Charter or articles of association
    • A scheme of delegation (or anything else useful) about who makes decisions and how
    • Documentation pertaining to risk and audit – the operations of the committee responsible is given as one example
    • A policy on conflict of interest

    These are, to be clear, governance documents, not detailed operational arrangements – although of course such policies would need to be operationalised for ongoing conditions E1 and E2.

    In assessing these documents, OfS intends to look at the “appropriateness of arrangements”, bearing in mind a provider’s size, complexity, context, and business plan.

    Oh yeah, you need a five year business plan too. The regulator hasn’t been impressed with what has been seen so far.

    Some providers applying for registration have not been able to demonstrate that they have sufficient understanding of how the higher education sector operates. This can result in a provider making unrealistic assumptions in its planning, such as overestimating its ability to recruit students in a competitive market, which can pose risks to the ongoing viability of the provider and cause associated harm to students.

    Part of being sufficiently equipped to deliver higher education is preparing to meet the relevant regulatory requirements. We have encountered issues where newly registered providers were not sufficiently aware of the regulatory framework and so did not have robust plans in place to meet ongoing requirements

    And there’s a telling indication that problems multiply pretty quickly when the plans get hit with a dose of operational reality.

    Where a provider does not have robust plans in place, it may encounter financial challenges after registration. Providers have at times taken steps to address this without fully considering the risk of doing so, for example:

    a. Rapidly entering into new partnership arrangements because of the unexpected withdrawal of a current partner without having the governance and management processes needed to manage this change properly.

    b. Employing financially incentivised external recruitment agents to meet recruitment targets that are too ambitious.

    c. Taking out additional unplanned borrowing to fund unanticipated expenditure.

    All of these behaviours can result in negative consequences for students and taxpayers

    Being objective

    Who could possibly have foreseen, eh? Going forward OfS would like business plans to be comprehensive and clearly written – and demonstrate an understanding of the sector, of managing risks, and of the conditions of registration.

    It’s all standard stuff (objectives and targets and how to achieve them, risks and how to manage them, regulatory compliance) over a challengingly long five-year period. OfS’ assessment will not be based on the targets themselves, but whether the provider can deliver these in practice given their resources and prevailing sector conditions. As an overriding primary consideration the plans need to focus on the interests of students.

    There’s no expectation that there will be an assessment of the objectives in and of themselves (or whether they are a proper thing for the provider to pursue), and OfS would not endorse these objectives – it’s more a matter of understanding a provider’s chosen approach in looking at the plans it has to deliver. A neat distinction.

    People who need people

    So who will be delivering these plans? The new condition would set out key knowledge and expertise for the chair of the governing body, accountable officer, and where applicable, the person with overarching responsibility for financial management and an independent member of the governing body. There’s a sensible sounding list on pages 30-33, but the big shocker is that these would be assessed via an interview with OfS officers!

    Yes, you read that right: 30 to 60 minutes based on key questions allowing said knowledge and experience to be demonstrated. On one level it feels sensible to talk to the people involved as a way of establishing the credibility of plans, but the feeling that OfS is appointing (or approving the appointment of) your chief financial officer is a hard one to shake.

    In contrast the “fit and proper persons” test is pretty much as expected, with additional requirements to supply new information (if you are disqualified as a director or trustee, or declared bankrupt) during the course of the application process. This is a welcome admission that these processes can take a long time to work through.

    You’ve probably spotted that OfS and government are now very focused on fraud in the sector – and assessment of arrangements to prevent fraud will focus on an institution’s track record where it has already been delivering higher education as part of a franchise or partnership arrangement.

    Other requirements for registration applications

    Got all that? Well strap in, there’s more.

    There’s the new C5, the new E7, and OfS intends to beef up their financial information requirements from August 2025 too.

    Financial viability and sustainability is currently assessed via initial condition D – providers already submit full, audited, financial statements for up to three years alongside four years of forecasts and a commentary on these. OfS has noted that new registrants tend to defer their first year of recruitment (setting up a HE provider is hard!) and substantially under recruit when they do – with current financial and recruitment pressures this isn’t going to improve any time soon.

    The new requirement is an addition to the template, which allows a provider to model financial viability against different yet plausible scenarios: zero growth over four years and 40 per cent below forecast followed by three years of zero growth for those currently delivering HE – zero growth followed by 80 per cent below forecast for the next three years for those entirely new to the sector.

    These aren’t set in stone – OfS reserves the right to tweak them based on emerging sector issues. And we may also get an alternative for providers whether the business model is not predominantly balanced on higher education provision.

    The commentary to this new table would let the provider set out mitigations, or provide evidence that these scenarios are unrealistic. But even so, there is a risk here that condition D becomes the hard one to pass – OfS reckon this is fair enough given short– and medium– term challenges to the sector. Although one cannot help but think of the many existing registered providers that would not pass these tests.

    By OfS request

    There’s another welcome recognition that applying for registration takes ages in the requirement for a provider to submit updated finances, student numbers, and commentary in the late stages of application by OfS request. While this makes sense in that the regulator isn’t relying on year-old (and the rest…) numbers this is a hard sell for those prospective registrants now expecting to submit similar data twice – although it could be argued that this gets them used to regular submissions while registered.

    Likewise, if the financial year turns over during the registration process you’ll need to put an extra batch of audited financial statements in for that year.

    And, wonderfully, OfS wants an ownership and corporate structure diagram too – it’s been finding some structures “complex”, poor thing.

    If your provider is or has been under investigation by another regulator – or awarding organisation, professional body, funding body, statutory body, and so forth – you’d better believe that OfS wants to know about that up front too. Apparently it keeps finding out about such things midway through the assessment process – and it does tend to be relevant, even if it is not an automatic fail.

    The rules are for the 60 months proceeding application, any investigation that closed or opened during the application period is something OfS wants to know about: a brief description, the responsible body, the dates, and the findings and/or outcomes.

    And if you are looking forward to the exciting world of “reportable events”, something similar now applies during registration. If stuff happens (there’s a long and familiar list on page 42) then you’d best drop OfS a note within 28 days.

    Finally, from January 2026 you won’t be able to reapply within 18 months of an unsuccessful registration application. This “double jeopardy” rule is a new one, and it looks like it is aimed at ensuring that OfS capacity is not clogged with resubmissions of poor quality applications where identified weaknesses are not addressed. We learn that 40 per cent of applications don’t comply with the existing guidance.

    There is the possibility of individual exemptions from this rule, for example where there have been IIT problems or where information that was not available for reasons outside of the provider’s control is now available.

    How this will be done

    The changes to application requirements were done via the same “manner of application” loophole – section 3(5) of HERA – that was used to pause the registration process. It is, as we said at the time, a reach in terms of legislative interpretation but it is difficult to argue against many of the principles here.

    It is regrettable that the same group of providers that have been forced to delay or resubmit applications due to the pause will now have to do considerable extra work to get these into the new format.

    While the principle of assessing existing documents rather than new ones is a good one, the reality of this is not as neat as regulators sometimes think. For an expected influx of new registrations – the franchise thing, and whatever ends up happening with the lifelong learning entitlement is expected to flush out at least a few – it makes sense to have all this in order. But there are always winners and losers with these things, and the losers have lost several times in a row here.

    The only other disappointment is probably that these new approaches will apply only to new registrations – there’s clearly a lot of benefit to similar approaches (especially for C5 and the financial requirements) to be extended to existing registered providers, and it is likely that there is more to come on that front.

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