International Australian Studies Association

Name (Individual/Organisation)

International Australian Studies Association

Responses

Q1. How could the purpose in the ARC Act be revised to reflect the current and future role of the ARC?

For example, should the ARC Act be amended to specify in legislation:
(a) the scope of research funding supported by the ARC
(b) the balance of Discovery and Linkage research programs
(c) the role of the ARC in actively shaping the research landscape in Australia
(d) any other functions?

If so, what scope, functions and role?

If not, please suggest alternative ways to clarify and define these functions.

The International Australian Studies Association (InASA) does not have specific recommendations about the purpose of the ARC Act. Indeed, we believe it is best that the legislation remains broad in defining the scope of the ARC so that there is flexibility to vary the programs which the organisation administers as the research landscape continues to evolve. Most importantly, we recommend against any codification of ratios of Discovery to Linkage research programs.

Q2. Do you consider the current ARC governance model is adequate for the ARC to perform its functions?

If not, how could governance of the ARC be improved? For example, should the ARC Act be amended to incorporate a new governance model that establishes a Board on the model outlined in the consultation paper, or another model.

Please expand on your reasoning and/or provide alternative suggestions to enhance the governance, if you consider this to be important.

InASA does not support the proposed model of governance. The main challenge, in our opinion, is political interference with the ARC – be that in the form of the ministerial veto or ever-changing aspects of applications (e.g. the creation and role of the National Interest Test) which are designed to appease particular political arguments about research funding. So long as the ARC Act facilitates political interference, the role of an advisory board could be overruled. Moreover, the existence of a ministerially appointed board runs the risk of itself becoming politicised as we have witnessed in other government-appointed boards and tribunals (e.g. the ABC and AAT). Instead, InASA advocates for the ARC Act to be amended to repeal the ministerial veto and to enshrine the independence of the ARC in its operation.

Q3. How could the Act be improved to ensure academic and research expertise is obtained and maintained to support the ARC?

How could this be done without the Act becoming overly prescriptive?

Appointments to the College of Experts have been scholars well recognised in their fields for research excellence: it is a highly competitive process that InASA endorses. In the Humanities, Social Sciences and Creative Arts, we also see a conscious effort to ensure gender balance among members of the College of Experts that InASA supports (InASA is not qualified to comment on other fields).

Any changes to the ARC Act need to ensure independence so that academic and research expertise is prized. InASA supports enshrining in the legislation that, as taken from the discussion paper, the Executive Directors be defined as “academic discipline leaders with research experience, hold the high regard of their respective research communities, and have credibility with relevant stakeholder communities.” We support this definition and believe the appointment of EDs should be commensurate with this expectation of senior leadership. Beyond this definition, InASA is hesitant to define other positions or appointment processes for fear of the legislation becoming overly prescriptive. However, we would be open to further consultation if changes to the proposed definitions of the roles and appointment processes were made publicly available.

Q4. Should the ARC Act be amended to consolidate the pre-eminence or importance of peer review?

Please provide any specific suggestions you may have for amendment of the Act, and/or for non-legislative measures.

InASA would like to see the consolidation of peer review. As a result, InASA strongly endorses amending the ARC Act to remove the ministerial veto. This will ensure that all grant decisions are based on the recommendations of the College of Experts after a rigorous peer review process, rather than being driven by political considerations. Internationally, comparable democracies which value academic freedom are guided by the Haldane Principle. This dictates that while governments should oversee funding bodies, individual projects should be judged by a process of expert peer-review. The use of the Ministerial power to decline grants approved by the ARC is personally devastating for the academics who invest substantial amounts of time in the application process and have funding withheld at the final stage for reasons that are ill-defined and unrelated to the quality of their research and its standing within the scholarly field. It is a diminishment of expert advice and commitment to a rigorous peer review process and the antithesis of the principle of academic freedom. Furthermore, the ministerial interventions in both 2017 and 2021 undermined confidence at home and abroad in our research system, leaving academics wondering if it is even worthwhile to seek funding in Australia. It also created unnecessary and wasteful work for the ARC, for peer reviewers, and Executive Directors without benefitting the Australian public.

Q5. Please provide suggestions on how the ARC, researchers and universities can better preserve and strengthen the social licence for public funding of research?

The National Interest Test (NIT) emerged out of political interference with the ARC in the form of ministerial vetoes. As such, the NIT itself has always been seen by researchers as more a matter of ensuring that their grants are politically palatable, rather than being any substantive measure of a grant proposal’s potential impact. Furthermore, if we read the context of the NIT’s emergence, it came after years of Coalition politicians’ and partisan media attacks on the ARC, with particular projects selected as supposed examples of wasteful taxpayer-funded research. The existence of the NIT has not changed this commentary and criticism – there will always be projects that particular casual observers deem unworthy of funding, regardless of the rigor and expertise of the academic evaluation process.

Given this context, InASA strongly recommends removing the NIT altogether. There is already a section in all grant applications where the researchers need to explain the potential national benefit of their research, and that section is more than adequate. The recent change by the ARC to make the NIT part of the standard review process is the first, and welcome, step; removal of the NIT is the second, essential part of this step-change.

Moreover, InASA recommends widening the definition of benefit so that researchers can also talk about other aspects to benefit beyond academia besides just social, cultural, economic and environmental benefits (e.g. health and mental health benefits). Alternatively, we support a broader definition of what constitutes a social, cultural, economic or environmental benefit, such as social benefits to particular communities (e.g. Indigenous communities) or individuals (e.g. project participants).

Q6. What elements of ARC processes or practices create administrative burdens and/or duplication of effort for researchers, research offices and research partners?

InASA appreciates that this is a huge question and that the ARC has already considered numerous challenges. In regards to the points already listed in the discussion paper:

• delays to, and uncertainty regarding, announcements;

InASA advocates for a set announcement date to be announced when the funding scheme opens. This date could only be varied in exceptional circumstances (e.g. the COVID pandemic interrupting processes in both 2020 and 2021).

• unexpected changes to grant rules and deadlines;

InASA supports amending rules and legislation which say that changes to grant rules and deadlines can only happen in exceptional circumstances.

• onerous requests for information, including duplication;

InASA agrees that onerous requests for information, including duplication, should be reduced.

• prescriptive financial requirements, variations, and approvals (especially if budget requests are not fully funded);

Researchers have expressed frustration at the time it takes to receive responses to variation requests. For instance, we know of cases where a CI changed institutions and it took several months for the ARC to approve a variation around this. InASA supports the ARC introducing a list of routine situations where researchers must notify the ARC of a variation, but which would not require approval. Such situations include:
Change of institution for a CI/PI
Death of a CI/PI
Budget variations where the money is still being used for purposes outlined in the grant application

• the scope and currency of Australia’s Science and Research Priorities;

InASA is aware that these are already under review but strongly believes that, in their current form, the research priorities generally exclude the Humanities and Social Sciences. Until 2015, the predecessor departments to the present Department of Industry, Innovation and Research published a set of ‘Strategic Research Priorities’. Until 2015 there was always a research priority around ‘Securing Australia's place in a changing world,’ with strategic goals that could align well with Humanities, Creative Arts and Social Sciences scholarship. In 2016, the ‘Strategic Research Priorities’ were renamed the ‘Science and Research Priorities’ and, as the name suggests, all of them are centred around the sciences. This disadvantages scholars in the Humanities, Social Sciences and Creative Arts and devalues their research. It also ignores the major contribution made to the Australian economy, from the arts, media, publishing, social research and education (among many other fields). Narrowly defined priorities are narrow-casting Australia’s future unless they encourage full participation of the research community in addressing complex problems that improve our culture and society.

Comparable funding bodies internationally all have strategic research aims or programs which align with the Humanities, Social Sciences and Creative Arts. For instance, the UK Arts and Humanities Research Council has five relevant funding focus themes: Connected Communities, Creative industries cluster program, Design research, Heritage research, Hidden histories and Humanities in the European Research Area (https://ahrc.ukri.org/research/fundedthemesandprogrammes/themes/).

• duplication of national security requirements and processes outside the University Foreign Interference Taskforce;

InASA has no strong opinion on this because such research mostly falls outside our members’ remit, but any rejection of a grant on national security grounds needs to be transparent for the researchers involved.

• relative weighting of different research outputs (e.g. monographs);

InASA supports the existing weightings of different research outputs

• treatment of pre-prints and other discipline-specific forms of research outputs;

Rather than be prescriptive about any particular form of research outputs, this should be left to the assessors and College of Experts to determine the quality of types of research outputs.

• treatment of non-traditional research outputs;

Similar to the above, there needs to be respect for diverse forms of research outputs which are more common in particular disciplines. This is a matter for the College of Experts and assessors – though it should be noted that members of the College should themselves be educated about and familiar with the diverse disciplinary norms and publication/output practices within the different FoRs that come under their panels.

• research ethics and research integrity processes; and

The ARC’s research ethics and research integrity processes, in association with those of administering organizations, appear to InASA to be robust.

• complaints handling and appeals mechanisms.

The ARC’s complaints and appeals processes, in association with those of administering organisations, appear to InASA to be robust. InASA is in agreement with members of the ARC College of Experts who suggest that feedback from the Selection Advisory Committee could be valuable if it could be conveyed to unsuccessful applicants, and may mitigate complaints that arise from a mis-match between Expert Assessors’ reports and outcomes.

Q7. What improvements could be made:

(a) to ARC processes to promote excellence, improve agility, and better facilitate globally collaborative research and partnerships while maintaining rigour, excellence and peer review at an international standard?

(b) to the ARC Act to give effect to these process improvements, or do you suggest other means?

Please include examples of success or best practice from other countries or communities if you have direct experience of these.

Perhaps the biggest improvement would be for there to be a two-stage application process for larger schemes (e.g. Discovery). The first stage would be a two-page expression of interest where researchers outline the fundamental aims, background and proposed methodology of their project. Those projects which are selected by the College of Experts as having merit would then proceed to a second, more detailed stage which would go out to assessors. This is already the established practice in the Canadian Social Sciences and Humanities Research Council and New Zealand Marsden Fund, among other schemes.

InASA also advocates for the re-introduction of a small grants scheme for the Humanities, Creative Arts and Social Sciences, reflecting similar opportunities in equivalent bodies like Canada’s SSHRC, New Zealand’s Marsden Fund and the European Research Council.

Research in the Humanities, Social Sciences and Creative Arts is less expensive than research in the sciences, engineering and health, which generally have larger staffing needs and overheads (e.g. laboratory and equipment). Conducting research in many Humanities and Social Sciences fields represented by InASA is also becoming more cost-effective due to the digital revolution. For instance, historians can access many archival materials online, and when they visit archives they can use technology to scan documents rapidly rather than spend weeks working with the documents on site under restricted conditions. The Zoom/Teams revolution now means many project meetings and some research methods like interviews or focus groups can be done online, and often the software can even transcribe recorded meetings. There are opportunities for scholars in these fields to design smaller projects which are cost-effective, efficient, and highly productive of excellent research and impact, if given the right rules and assessment criteria.

Of course, multiple teaching modes during COVID and the departure of many academic and professional staff have left scholars in Humanities, Social Sciences and Creative Arts even more time-poor in relation to research workloads. This is exacerbated by the casualisation of the academic work force. This means that the primary funding required might be for teaching relief or research assistance, hence keeping the funding envelope fairly modest.

Until 2001, the ARC ran a Small Grants Scheme (websites with the guidelines are archived on the National Library of Australia’s Pandora Web Archive). After the ARC disbanded this scheme, some universities subsequently allocated funds for internal small grants to help build grant writing skills and track records, especially for ECRs. This is by no means consistent across the sector, with some universities offering no internal funding schemes at all. While InASA is not privy to why the ARC terminated this scheme, we agree with a 2010 recommendation from the House Standing Committee on Industry, Science and Innovation that the value of small grant schemes be investigated with a view to reinstating this important funding.

We also encourage the ARC to consider other new grant schemes which would be accessible for Humanities, Social Sciences and Creative Arts researchers. For instance, when the Canadian government provided additional funding to SSHRC in 2018, they set up a new grant scheme called Insight Development Grants. Valued at between $7,000 to $75,000, they are described as follows: ‘Insight Development Grants support research in its initial stages. The grants enable the development of new research questions, as well as experimentation with new methods, theoretical approaches and/or ideas. Funding is provided for short-term research development projects of up to two years that are proposed by individuals or teams’ (https://www.sshrc-crsh.gc.ca/funding-financement/programs-programmes/insight_development_grants-subventions_de_developpement_savoir-eng.aspx).

We recommend that the adoption of similar seed grant schemes in Australia would contribute substantially to the nation’s innovation agenda and provide cultural, economic, social and environmental benefits to Australia. It would also provide ECRs with access to small research grant funding, with potentially large returns to the nation and to scholarship.

Q8. With respect to ERA and EI:

(a) Do you believe there is a need for a highly rigorous, retrospective excellence and impact assessment exercise, particularly in the absence of a link to funding?

(b) What other evaluation measures or approaches (e.g. data driven approaches) could be deployed to inform research standards and future academic capability that are relevant to all disciplines, without increasing the administrative burden?

(c) Should the ARC Act be amended to reference a research quality, engagement and impact assessment function, however conducted?

(d) If so, should that reference include the function of developing new methods in research assessment and keeping up with best practice and global insights?

InASA advocates for the complete scrapping of ERA and EI. These exercises originally emerged as a response to criticism that Australian university research and researchers were not of sufficient quality or having relevance to the community. The first EI showed this definitively not to be the case, and the various ERA outcomes over the years have also suggested this to be the case. Yet, what is more worrying is how Universities have used these evaluations – especially ERA, which is more established – to drive hiring, promotions and publishing practices within universities. While the extent of these practices have varied depending on the institution, we know that the following have occurred:

1. Using publisher as proxy for research quality. This means relying either on the outdated and repealed 2010 ERA journal rankings, Scimago, professional association rankings and judgements based on the prestige of an institutional press.

2. Hiring practices have changed, where only those candidates who have track records aligned with the above, often unspoken publishing parameters, are considered. This has disproportionately and adversely impacted on the opportunities for ECRs.

3. Reclassifying staff whose outputs were not in top tier publications, as defined by ranking schemes outlined above as teaching focussed so that their outputs would no longer be counted in ERA.

4. Focus on hiring research-only staff in permanent and/or contract positions, which has accelerated the casualisation of the teaching workforce.

There is a common trend towards universities implementing workload policies which allocate research hours or points to staff. The requirements in HASS disciplines focus heavily on where they publish – some universities use a carrot approach, incentivising publication in Scimago Q1 or formerly ERA 2010 A*/A ranked journals. Others use a stick, reducing workload allocations when people publish in journals or publishers not ranked as highly. Some universities have developed their own journal rankings or publisher lists (often heavily based on the repealed ERA 2010 journal rankings).

Finally, there is the gaming of ERA through multiple means. This has had a range of deleterious outcomes, including university hiring and especially affecting the most vulnerable workers in the Higher Education system, our ECRs.

As a scholarly association representing HASS and Creative Arts, we are also concerned by sector “talk” about how improved metrics could produce a simplified ERA. The datasets, data providers, and university dashboards that have been used in ERA Mark 1 do not provide reliable data about our disciplines and are incapable of making quality decisions and assessments. Peer review has been the only positive attribute for HASS in ERA Mark 1, and the bracket creep that is widespread only in metrics-dominated fields of research is indicative of how research metric data can be used strategically, or mischievously.

Moreover, we do not see ERA or EI influencing industry, government or community expectations or understandings around the excellence of Australian research. Stakeholders like the government or end users do not tend to refer to ERA or EI in their public statements or in their choice of institutions for research partnerships. It is primarily only the university sector that takes an interest in ERA and EI and the outcomes. Universities aim to reinforce the scores that are already high rather than develop in new areas. If anything, universities worry about getting a low score, which makes them less likely to develop new areas of research and more risk averse. Universities try not to submit in fields perceived as scoring weakly, and universities may even abandon those fields as research areas. Many end users/stakeholders are baffled by the over-determined approach to EI which creates more paperwork (e.g. documentation of engagement and impact activities) and obscures the actual collaboration and their real-world impact. Moreover, the fact that EI measures past activities means it is hard to assess how the assessment is meeting the ‘future needs’ of stakeholders.

The ARC can ensure high quality impactful research by ensuring the importance of these are embedded in the grant application process, and this would have the desired impact (i.e motivate researchers to focus on quality and impact). The money and time spent on administering ERA and EI - both within the ARC and universities - could be diverted to research and supporting researchers.

Q9. With respect to the ARC’s capability to evaluate research excellence and impact:

(a) How can the ARC best use its expertise and capability in evaluating the outcomes and benefits of research to demonstrate the ongoing value and excellence of Australian research in different disciplines and/or in response to perceived problems?

(b) What elements would be important so that such a capability could inform potential collaborators and end-users, share best practice, and identify national gaps and opportunities?

(c) Would a data-driven methodology assist in fulfilling this purpose?

As outlined in the previous question, the track record of ERA and EI suggests that collaborators and end-users are more often driven to particular researchers or institutional departments by virtue of their professional networks or reputations. They are not generally accessing EI or ERA data to influence these decisions, and we do not see any replacement evaluation of research excellence and impact as influencing them either.

In addition to the problems outlined above, there is also a significant cost borne by both the ARC and universities due to ERA, EI and any potential replacement evaluation. The ARC already allocates research funds, through peer review, on the basis of benefit, quality and EI, and this should be continued and would be sufficient to ensure the ongoing value and excellence of Australian research. This system is already sensitive to disciplinary differences. The recent decision to postpone ERA was made after numerous universities were already well advanced in the preparation of their submissions, constituting a substantial waste of time and expertise. Furthermore, the substantial cost associated with administering the ERA and EI schemes could instead be utilised in service of the ARC’s core aims: supporting research and researchers.

Q10. Having regard to the Review’s Terms of Reference, the ARC Act itself, the function, structure and operation of the ARC, and the current and potential role of the ARC in fostering excellent Australian research of global significance, do you have any other comments or suggestions?

Recommendation: Amend the rules for the DECRA Awards to oblige universities to offer an ongoing position to any successful DECRA recipient.

The guidelines for the ARC Discovery Early Career Research Award (DECRA) program indicate that the scheme’s objectives are to:
a. support excellent basic and applied research by early career researchers;
b. support national and international research collaboration;
c. enhance the scale and focus of research in Australian Government priority areas;
d. advance promising early career researchers and promote enhanced opportunities for diverse career pathways; and
e. enable research and research training in high quality and supportive environments.

DECRA grants are highly competitive with a success rate of 15% in the most recent 2023 round. The recipients are fully funded with a salary and research costs for three years. As the objectives suggest, the idea is to attract and reward promising ECRs. However, many DECRA recipients face uncertainty about their careers after completion of the grants. Many must spend the final year going through job application processes with no certainty as to the outcomes. While a DECRA grant is prestigious and recipients are competitive, not all DECRA recipients have a continuing job when their project finishes. Some leave the sector because of this—a waste of human talent, excellent training, and Government investment.

Recipients of ARC Future Fellowships – which fund salary and research costs for mid-career researchers – used to face similar challenges. There were cases of Future Fellows being unemployed upon completion of their fellowship, which contradicted the aims of the scheme. Commencing in 2014, though, the ARC Future Fellowship rules were updated: universities were now obliged to offer a continuing position to any successful Future Fellowship recipient. This was a welcome change, and we recommend that the ARC extend the same logic to DECRA recipients to oblige universities to offer continuing positions to any successful DECRA applicant.

We also note that the DECRA fellowships originally were designed as a successor to replace the Australian Postdoctoral Fellowships (APD). Yet, the DECRA outcomes have tended to favour academic staff towards the latter end of their DECRA eligibility period, disadvantaging ECRs who have more recently completed their PhDs. This is yet another reason why we see a small grants scheme as outlined earlier as being an opportunity for ECRs to win competitive grants.

Submission received

08 December 2022

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