Monash University

Name (Individual/Organisation)

Monash University

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.

14 December 2022

Monash University welcomes the opportunity to make a submission to the Independent Review of the Australian Research Council (ARC). We note the recent work by the Minister and the ARC CEO to make improvements to ARC processes ahead of this review.

Monash University is Australia’s largest University in terms of student enrolments, academic staff numbers and the comprehensiveness of our research profile. As a truly global, research-intensive university, Monash is delivering education and research excellence and impact in Australia, our region and across the world. Our vibrant and diverse community of 86,000 students, 17,000 staff, and more than 440,000 alumni are working together to create real change in three challenges of global significance: mitigating the consequences of climate change, achieving geopolitical security, and supporting thriving communities.

Our research strengths, measured as assessable units of evaluation rated ‘above or well above world standard’ in ERA18, cover 98 4-digit fields and 21 2-digit divisions of research. The University is a major participant in ARC competitive schemes (regularly placed in the Top 3 institutions nationally in ARC grant performance, with over $580 million in ARC grants under active management) as well as taking an active role in consultation and working groups on the research policy matters overseen by the Council.

This submission makes six principal recommendations:
1. Governance: strengthen formal governance of the ARC in legislation, including through the amendment of the ARC Act to introduce an ARC Board or Council.

2. ERA/EI: ERA and EI have served their original purpose and should now be discontinued. Several reputable existing international rankings evaluate specific aspects of research quality and impact, span our existing 2 digit divisions of research, and use transparent, field specific methodology. These rankings have the advantage of placing research performance in Australian institutions in a comparative international context. Supplementary information can be provided to Government through annual HERDC submissions.

3. Purpose and functions of the ARC: application, assessment and award processes for ARC administered competitive grants be streamlined according to best international practice.

4. Staffing skills and attributes: As a way of strengthening academic expertise at the ARC, the review considers 1) expanding the number of Executive Director positions; and 2) including a strong research track record as one of the selection criteria for the position of ARC CEO.

5. NIT: attention needs to be given to the best way to communicate the value of competitively funded research to non-academic audiences, and the ARC must ensure that if the NIT is retained for this purpose it will be administratively efficient.

6. Ministerial veto: the ARC Act be amended to ensure there are reporting requirements, and clear and transparent criteria for the exercise of Ministerial veto power over funding outcomes for individual project grants.

Question 1

Scope

The Act should remain high level so it is not subject to ongoing changes. However, the ARC Act would benefit from a statement that the ARC is the primary source of public research funding (excluding medical) and has particular importance in the national research funding landscape for the funding of basic/fundamental research.

Balance of Discovery and Linkage

The specification in legislation of a particular balance between Discovery and Linkage research programs is not something Monash supports. Such specification risks constraining the ARC’s flexibility to respond to future research needs. However, the legislative specification of the funding scope of the ARC (above) as well as a statement in the Act endorsing the ratio that favours Discovery over Linkage (i.e., the current ratio is 60/40) would ensure the role of the ARC in supporting basic/fundamental research was protected from future politicisation, allay concerns in the research community regarding support for basic research and avoid hindering future flexibility in operational decisions of the Council regarding funding priorities.

Role of ARC in the national funding landscape

In August, the Minister for Education stated in his Letter of Expectations to the ARC CEO that ‘countries that produce the highest quality research have effective research councils that do not just manage funding allocation processes but also play a role in providing the feedback that shapes their research policy landscape’. He noted that the ARC has a key role in ‘facilitating world class Australian university research, including as the only Commonwealth research agency funding … basic research in all areas (excluding medical).’

Our view is that the ARC must renew its role in the national funding landscape for promoting the value of basic research across all fields of research (excluding medical) and in working with stakeholders to shape relevant research policy settings that enable and support a world class research environment. A central way the ARC can shape an environment that encourages the highest quality research is through the integrity and efficiency of its grant processes (see responses to questions 7-10).

Other functions

The ARC has an advocacy role in communicating the value of basic research to non-academic audiences, including the public, and government departments and ministerial portfolios. This role requires the attention and responsibility of senior office holders (with research expertise) in the ARC (see responses to Q.5).

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.

Monash believes that a new governance model for the ARC is required. We recommend that the ARC Act be amended such that a properly constituted ARC Board or Council (as used in the NHMRC) makes recommendations for the appointment of the CEO who in turn reports to the Board. Such a mechanism would provide appropriate oversight, transparency, and accountability for ARC operations. The Chair of the Board must have research exposure, either as a researcher or leader of a research organisation, or as a significant commissioner/user of research of the nature enabled by the ARC.

We support the functions of the Board outlined in the consultation paper, including its role in making recommendations for the appointment of the Chief Executive Officer, and we also think a Board will provide a valuable mechanism to ensure open lines of communication with the research community are incorporated in ARC governance.

We would encourage the ARC Board to ensure gender and discipline balance, early career researcher membership, and appropriate inclusion of Indigenous researchers alongside industry and community representatives with experience in the type of research enabled by the ARC. Such membership will help to address some of the challenges associated with equity and inclusiveness (e.g., Indigenous research, gender equity, and early career research opportunity) that have attracted public criticism of ARC practices in recent years.

In line with the imperative to restore trust and confidence in the ARC, we would encourage sector consultation on the design of an appropriate and transparent process for appointment of Board members.

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?

The Review may want to consider amending the Act so as to require a strong research track record as a criterion for the position of ARC Chief Executive Officer. This would bring the ARC in line with the expertise required to helm other peak national bodies without being overly prescriptive about the nature of the expertise or staffing profile required within the organisation, which could be left to the Chief Executive Officer in consultation with the Board.

An expansion of the number of Executive Director roles at the ARC would also strengthen academic expertise within the organisation, and such an expansion would not require changes to the Act.
We note that the recent appointment of an academic to the position of Chief Research Officer has helped strengthen the place of academic expertise at the Council.

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.

The politicisation of ARC funding outcomes through the exercise of ministerial veto on vague national interest grounds has compromised the standing of the ARC within the research community and hampered its capacity to advocate for the value of research.

Monash believes the ARC Act should be amended to define the appropriate scope for ministerial veto of individual project grants: any intervention must meet clear criteria (specified by the ARC Board) and entail reporting obligations to Parliament to ensure public accountability and transparency as to the rationale used in such decisions. The Minister’s Office and the ARC should not be able to claim exemption from Freedom of Information laws in the event of such intervention.

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

Monash would support a coordinated national communication campaign run by the ARC on an annual basis to promote the value of outcomes from ARC funded research. Such a campaign should be focused towards non-researcher communities and could be creative and engaging in nature, using research demonstrations, exhibitions and annual awards to showcase the social and community benefits of research.

The Executive Director (ED) roles at the ARC should have appropriate media training to enable the use of their research expertise and national standing to develop annual advocacy programs for project outcomes funded in their areas. The assigning of such responsibilities to the ED roles would help rebuild and develop senior capacity at the ARC for promoting the core research functions of the Council.

Universities currently acquit their responsibility to build the social licence for the public funding of research through enterprise, alumni and community engagement activities and this should continue.

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

We welcome recent attempts to improve the administrative burdens of ARC processes by the Minister and the ARC CEO. However, a number of problems remain, including:

Uncertainty regarding grant scheme opening, closing and announcement dates;

Dissatisfaction with the applications of rules and compliance that affect eligibility;

Unnecessarily lengthy, repetitive and complicated applications;

Requirements for manually entered research track record details, including for international partner investigators, which discourages international collaboration;

Overly detailed requirements for descriptions of research opportunities;

Duplication of investigator track record details across different sections of applications;

Pre-award paperwork that creates bureaucratic hurdles for collaboration with industry partners;

Lengthy, cumbersome and controversial assessment processes (i.e., there is a lack of researcher confidence in particular aspects of the process: e.g., the process of assessment for multi and interdisciplinary proposals, lack of depth in the Australian peer review pool in some research fields, assessor fatigue and lack of returned assessments and poor behaviour in assessment and review (such as, undeclared CoIs)); and

Lack of transparency in outcomes with banding reports providing insufficient detail to inform competitive resubmissions.

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.

ARC Processes

Although we think existing ARC schemes and application processes should be reviewed, it is important that the ARC maintain schemes with shorter time periods to test new areas of fundamental research (i.e. a researcher with a bright idea) and to enable ECRs to establish track record.

The ARC should look to international best practice in rationalising application processes and ensuring equity (see below for examples). Furthermore, care should be given to transparently report on participation and success rates by gender, to identify and remove barriers to gender equity in grant applications and awards and to devise processes that are sensitive to the circumstances of our research community (including primary carers and researchers with disabilities).

Desirable reforms to existing processes include shorter project descriptions (i.e., 5 rather than 10 pages), shorter ROPES sections with page limits for publication records aimed at including only the most significant/impactful publications. Publication records able to be sourced from publicly available research repositories such as ORCID rather than entered manually. EOI processes (currently in use for Centres of Excellence and CRC’s) could be used for any additional schemes that have 5+ year funding cycles. Introduction of an interview stage for senior fellowships and major investments (FL, ITRP).

Reforms to encourage greater transparency in assessment processes would be welcomed, including access to scores for unsuccessful applications and potential SAC feedback for near miss applications. Revise and resubmission process for near-miss applications is used well in NIH and could provide a model for ARC schemes: actionable feedback is provided to near miss applications with a shortened resubmission accepted in the next round with high chance of funding.

ARC Act

Changes to the ARC Act are not needed to ensure effective administrative reforms to make application processes more efficient and aligned with best international practice. Such changes can be overseen by the ARC Board in collaboration with the ARC CEO.

Best Practice Examples

Canada’s Social Sciences and Humanities Research Council (SSHRC) provides support materials and requirements around Equity and Diversity. It is currently working on a comprehensive accessibility plan, and already accommodates adaptations to specific individual needs including:

● one-on-one phone or video appointments to clarify funding program information on the application process, or receive technical support;
● alternative formats of online materials to enable access using assistive technology;
● submission of the application (in full or part) through alternate means or format (e.g., hard copy, voice recording, or data entry by SSHRC staff on the applicant’s behalf).

The ARC should conduct a review of how current processes impact people with various disabilities (making sure to speak to people who are unable to submit under current processes) and make other modes of completion and submission available to improve equity.

The Royal Society (NZ) Marsden Fund has two stage applications even for the introductory-level grants. The first stage is a one-page description of the research and CVs for all named researchers.

The Arts and Humanities Research Council (AHRC) in the UK allows researchers to submit a remit query form to confirm that research is suitable for funding, or be directed to the more appropriate funding body. A system like this would be highly valuable for researchers proposing projects that are at risk of being deemed ineligible, particularly research with tangential health implications, allowing for a significant reduction in wasted effort.

UK Research and Innovation (UKRI) are implementing the Resume for Research and Innovation (R4RI) - an inclusive, single narrative format for CVs across UKRI opportunities that require track record information (this would be equivalent to a single format across ARC, NHMRC and MRFF).

The German Research Foundation (DFG) sets aside funding modules to address equity issues, e.g. monthly child allowances for fellowship applicants with children and funding for care of children and relatives during conference or research trips; special processes to support applicants who are refugees, with the aim of integrating them into the academic system in Germany; a module to request funds for targeted measures to promote gender equality in science and academia. Importantly, funding for equity measures is generally applied for through separate modules, rather than being part of the overall pot of grant money, meaning that funding for equity is not directly in competition with funding for research.

The Irish Research Council has recently invested in ‘curiosity driven research’.

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?

Excellence and Impact Assessment Exercises

We strongly recommend the discontinuation of ERA and EI.

These exercises have served their initial purpose and have now become burdensome administrative exercises which add very little to existing knowledge of the general state of research strengths and performance in different 2 digit divisions and 4 digit fields of research.

There are several reputable international rankings that evaluate specific aspects of research quality and impact, which span our existing 2 digit divisions, and whose methodology is transparent and field specific. Furthermore, these rankings have the advantage of placing Australian institutions in a comparative international context, whereas ERA and EI are limited to the measurement of national comparisons, assessed locally by Australian panels, despite the vocabulary of ‘world standard’ used in the exercise. Competition between institutions to hire research stars for the ERA census period also undermines efforts to build collaborative, cross-institutional consortia to tackle significant research problems. In this respect, the behaviours encouraged by ERA are in conflict with the strategic objectives of our national prestige research schemes, such as CRCs and Centres of Excellence, and undermine collaborative focus on addressing national research priorities. Assessments of research quality and impact should be measured against international benchmarks, and staff at local institutions encouraged to collaborate in research consortia, rather than compete with one another in fragmented silos. Collaboration is the best way to build our national research capacity, but incentives that build it often conflict with the strategies used to optimise institutional ERA submissions.

Regarding impact: national competitive grant schemes, and other categories of funders seek social benefits from the research they fund. Institutions value impact through prizes and professional staff appointments and support. These integrated features of the higher education funding, professional support and prize cycle make a national exercise designed to incentivise impact redundant. It is more efficient to allow institutions to pursue research impact in collaboration with funders as these are appropriate to their specific institutional strategies and strengths. Like excellence, impact is already part of University culture, it is also measured and evaluated through international rankings, and should not be a focus of our national Research Council’s activities.

Data driven approaches

One of the purposes of ERA/EI is to provide information to the Government on areas of research capability and strength, including for TEQSA accreditation of Universities. The current HERDC submission provides detailed information on research income, which is generally considered a reliable proxy for publication research quality across all fields of research and used as such (alongside HDR completion data) in government block grant funding formulas. This data is not available in fine grained detail to international ranking agencies, but can provide data rich information on national research capacity and performance to government agencies. Similarly, existing international university rankings can provide information to TEQSA on the quality of research undertaken at Universities. A cut off point in international ranking places for a threshold of disciplines relative to institution size, may provide a similarly reliable flag for accreditation for new institutions as TEQSA’s current ERA ‘at world standard’ benchmark for performance.

The ARC Act and Assessment Exercises

The ARC Act should not be amended to reference research quality, engagement and impact assessment functions. The sector is saturated with international rankings and it is a distraction from the core functions of the ARC to oversee national research assessment exercises.

International rankings weight citation performance as a proxy for research quality according to disciplinary practices and employ field weighted methodologies. These are reasonably reliable and transparent ways for assessing research quality when used in conjunction with other indicators (publication volume, research income and income mix, etc.). They are also preferable to the ERA peer review process which, despite being designed to prevent inappropriate use of citation data to measure research quality in peer review fields, oversaw a marked deflation in the rankings of peer reviewed fields compared to round by round strengthening performance for the citation fields assessed through successive ERA exercises.

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?

ARC expertise and capability in evaluating the outcomes and benefits of research

The ARC has access to years of competitive grant scheme data, which it could use to provide more detailed information on its website about relative institutional performance across gender, seniority and research fields. Currently the ARC only provides such information in terms of a general picture of national trends. The ARC scheme data could also provide retrospective insights about the trends in disciplinary funding and, through project reporting information, the value of past projects in addressing fundamental research problems and building national research capacity. However, it is not clear that potential collaborators and end-users would look to the ARC to understand research capability in their areas of interest. Such collaborators usually commence partnerships through their relations with researchers or institutions. It is also unlikely that an evaluation of national research capabilities by the ARC would be able to extend beyond retrospective insights to those projects funded under its schemes. The research funding landscape is much broader than the ARC and much national capacity is likely to be missed through ARC-focused evaluations of research disciplines and problems.

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?

1. A valuable way to restore confidence and improve participation in ARC schemes would be to lift success rates across schemes to 20%. When success rates fall below 20% internationally excellent, fundable projects miss out and this corrodes confidence in the system, including from assessors who are discouraged when projects they rate as fundable are unsuccessful. EoI processes may help ensure that the success rate at full application stage can be held to a consistent level without reducing award amounts to facilitate secure, base level success.

2. The National Interest Test needs to be reviewed in relation to its potential duplication of currently scored areas of grant applications, such as National Benefit, as well as in terms of the best approach to ensuring accessible, plain language descriptions of research benefit and impact are available at the point of award announcements. The current reforms of the NIT should not stop at integrating the test into peer review evaluation, but must address the core questions of its function and utility.

3. The ARC's support for ECRs needs to be reviewed and improved. Special sub-streams of project grants should be designed to provide opportunities for ECRs to catalyse their research programs or build collaboration with partners/industry. Currently, only ARC DECRA fellowships are designed for ECRs. These have low success rates, and are not designed to help researchers develop their teams. The current high weighting in the DECRA scheme for the Investigator criterion also needs review given the slender research performance opportunities that can be assessed for this early career stage. Opportunities should be provided for ECRs to lead and manage projects under the mentorship of senior or established researchers as in the old APD model. This type of scheme design has been successfully implemented in many major funders (including the Natural Sciences and Engineering Research Council of Canada) where fellowships within funded projects are a staple.

4. Attention needs to be given as to whether grant scheme types for particular fields/clusters of fields (e.g., HASS) would be appropriate and valuable. This investigation needs to be informed by a robust review of existing Australian research capability and national research needs.

Submission received

12 December 2022

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