Walter and Eliza Hall Institute of Medical Research

Name (Individual/Organisation)

Walter and Eliza Hall Institute of Medical Research

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.

Australian Government funding is a critical enabler of scientific discovery in Australia, and advancement of these discoveries towards community benefit. Australian taxpayers, who contribute these funds, expect the Government to distribute research funding through a fair, efficient and transparent process, and to enable the best research – whether that be the most outstanding discovery-based research or the most impactful applied research. Whilst we recognise the rationale for separating the administration of funding for health and medical research from other research, limiting the eligibility for ARC grants to university applicants undermines this process.

We strongly believe that the ARC is limited in its ability to fund the best non-medical research occurring in Australia, because its stated purpose is restricted to funding research within Australia’s university system, led by researchers employed by universities. This is despite equivalent, fundamental, non-medical research occurring at a world-class calibre at a range of independent, not-for-profit (non-commercial) organisations around Australia including independent medical research institutes as well as botanic gardens and herbaria, zoos and museums. Many researchers at these ARC funding-ineligible organisations (including WEHI) are recognised by the ARC as international experts in fields of research that are part of the scope of research funded by the ARC – and as such are called upon for peer review of ARC funding applications yet they cannot submit applications through their own organisations.

Some non-university not-for-profit research organisations (currently ineligible organisations) have developed approaches to circumvent the ARC’s restrictions – such as establishing convoluted employment relationships for researchers within universities, enabling these researchers to apply directly for ARC funding as a chief investigator rather than being a partner investigator on a university-led grant. However, we argue that if a researcher based at an Australian not-for-profit research organisation is undertaking world-class fundamental research that falls within the scope of ARC’s research funding, they should be able to apply for taxpayer funding for their research, and this research funding should be awarded based on the merit of the application irrespective of whether the applicant’s employer is a university or not.

RECOMMENDATION 1: The ARC should broaden its provision of research funding which is currently restricted to Australian universities to all Australian non-governmental, not-for-profit research organisations undertaking non-medical research.

Whilst we recognise the rationale for separating the administration of funding for health and medical research from other research, the exclusion of independent medical research institutes from accessing ARC funding for the fundamental research they undertake fails to support and recognise the important contributions made by researchers in these organisations.

WEHI is one of Australia’s pre-eminent, not-for-profit independent medical research institutes, which is not eligible to apply for ARC funding. WEHI’s research spans fundamental discovery-based research through to clinical translation, and we take a collaborative approach to tackling important scientific challenges. WEHI’s research workforce includes medicinal chemists, bioinformaticians and physicists, as well as biologists, who focus on discovery research, as well as developing analytical tools and technologies – areas of research that are directly relevant to ARC’s goals. Four case studies are included below as examples of these. These fundamental research programs often struggle to secure funding from NHMRC and MRFF because they are far removed from clinical application – and we note that these research areas would be clearly eligible for ARC funding rather than NHMRC or MRFF funding if conducted within an Australian university.

Researchers at WEHI who undertake fundamental research which is eligible for funding under the ARC’s medical research policy can access ARC funding as partners on university-led ARC grants. While this enables them to advance critical research programs, it denies WEHI and its researchers the opportunity to independently initiate and lead these research projects. Thus, by not enabling all not-for-profit, non-government research organisations within Australia to apply for research funding, the ARC has created an inequitable research landscape that prevents the best non-medical research from being fairly funded.

In contrast to the ARC, the NHMRC and MRFF have very broad criteria for funding health and medical research within Australia, which is inclusive of the diversity of organisations where health and medical research occurs: hospitals, community health organisations, medical research institutes, universities etc. While the ARC does not fund medical research, it is not uncommon for researchers at universities or university-affiliated medical research institutes to be awarded ARC funding for fundamental biology research, while also holding NHMRC funding for the health and medical applications of their research program. NHMRC and MRFF provide a model of broad organisational eligibility for enabling the best medical research within Australia, and we believe that eligibility to apply for ARC funding should be similarly broadened to ensure the best non-medical researchers can access critical government funding support.


RECOMMENDATION 2: Amend the ARC Act to specify that the ARC’s purpose is to support all non-medical research occurring at any non-governmental, not-for-profit organisation within Australia. We believe this will enable the ARC to achieve its stated purpose of benefiting the nation by enabling world-leading research, whether this research occurs within or beyond the university sector.

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CASE STUDIES: Examples of world-class researchers based at WEHI, an organisation that is ineligible for ARC funding, despite undertaking research that is within the scope of ARC and would be highly competitive for ARC funding if it were undertaken at a university.

Professor Gordon Smyth FAA is one of Australia’s leading statisticians. His work on statistical computing and statistical modelling has led to the development of new analytical techniques, which have particularly been applied to improve the analysis of ‘big data’ across a broad range of fields of biology, including many non-medical fields. Reflecting this, tools developed by Professor Smyth have been cited by thousands of published research papers. The high calibre of Professor Smyth’s work at the national and international level has also been recognised by the Clarivate Web of Science Highly Cited Researcher awards every year since 2013 to 2022, as well as his appointment to the Australian Academy of Science in 2021.

Associate Professor Kelly Rogers heads WEHI’s Centre for Dynamic Imaging, which enables scientists to use advanced imaging technology and powerful computational resources to design, perform and analyse experiments that provide unique insights into a range of complex biological questions. Associate Professor Rogers’ team includes researchers with expertise in biology, physics, mathematics, engineering and software development. The Centre builds, enhances and maintains a combination of bespoke and commercial imaging instruments. Much of Associate Professor Rogers’ team’s research is fundamental in nature, focusing on how to optimise imaging equipment, analysis and workflows to improve experimental outcomes. Among the Centre’s achievements was the construction of one of the first lattice light sheet microscopes outside the United States, which has allowed real-time, high-resolution analyses of complex cellular processes. It should be noted that analysing cellular processes is a field that is clearly within the scope of research funded by the ARC.

Reflecting the high calibre and transformative research undertaken at the Centre, it received funding from the global Chan Zuckerberg Initiative in 2021 for developing new software packages for analysing complex data generated by lattice light sheet microscopy. Again, development of analytical systems is an area of research funded by ARC.

Associate Professor Ethan Goddard-Borger is a world leader in the field of glycobiology – understanding the complex system by which proteins in all forms of life, from bacteria to plants and humans, are modified by the addition of sugars. This research leverages Associate Professor Goddard-Borger’s expertise in chemical biology and has involved studies relevant to agriculture and evolutionary biology as well as disease-causing pathogens and human disease biology and drug development and has led to numerous publications in high-impact scientific journals.

Associate Professor Isabelle Lucet investigates protein kinases, key proteins in all life forms that transmit signals within cells. Her research focuses on a subset of these called 'pseudokinases' that appear to function as a scaffold for signalling rather than catalysing biochemical reactions themselves. Associate Professor Lucet leads a multidisciplinary team spanning biochemistry, structural biology, assay development, chemical biology, proteomics and imaging, generating high-resolution insights into kinase and pseudokinase signalling. The relevance of Associate Professor Lucet's research to the scope of ARC has been reflected by her involvement (while employed by WEHI) as a partner investigator in successful ARC grants led by Monash University and the University of Melbourne, through the Linkage Infrastructure, Equipment and Facilities (2020, 2022), Industrial Transformation Training Centre (2020) and Discovery Project (2014) 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.

WEHI believes that the current ARC governance model is adequate for its purpose, although we are supportive of the ARC being fully independent of ministerial involvement in the selection of funding recipients. Any changes to ARC governance should maintain the independence of the ARC, as well as ensuring nimbleness to respond to changes in the research environment.

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?

Members of the ARC’s College of Experts are currently appointed by organisations that are eligible to receive ARC funding (predominantly universities). Thus, non-university employed researchers with world-class academic and research expertise are largely excluded from contributing to ARC’s governance and oversight of the peer review process. We recommend that by expanding the eligibility for ARC funding to all non-government, not-for-profit research organisations within Australia, the ARC would access a wider pool of talent and leadership for the critical functions performed by the College of Experts.

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.

We are fully supportive of peer review being embedded in the ARC’s decision-making process, and that this should be independent of ministerial involvement. We recommend the Act reinforces the independence of the ARC in making decisions about funding allocation.

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

Through paying taxes, members of our community expect that governments will spend these funds for the optimal benefit of the community. Given the competitive nature of research funding, our community expects that government research funding will be allocated to the best researchers to support their fundamental research programs – whether that occurs within universities or within other not-for-profit, non-government organisations. The ineligibility for ARC funding of world-class and impactful non-medical research from some of Australia’s best recognised independent organisations, such as WEHI and the Royal Botanic Gardens Victoria, simply because they are not universities, is at odds with this social licence for public funding of research. In short, the public would expect that the government will use taxpayer dollars allocated to the ARC to fund the best non-medical research within Australia – and this research is not limited to Australia’s universities.

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

WEHI advocates for transparency and predictability in all government research funding systems, and for processes and practices to be regularly evaluated for efficiencies that enable researchers to focus on their research rather than overly onerous research administration tasks.

For researchers within the university system who lead programs spanning both ARC- and NHMRC-relevant fields, there is the potential for duplication of effort in maintaining researcher profiles (such as their curriculum vitae) within two research administration systems (RMS and Sapphire). In the long-term, we would hope that the Australian Government may be able to find ways to prevent such duplication of effort, such as use of a shared portal for applications to schemes overseen by various research funding agencies including the ARC, NHMRC and MRFF.

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.

We fully support the enhancement of ARC programs that foster global collaboration. The NHMRC has a number of joint funding opportunities with international funding bodies, which are an important mechanism for supporting Australian medical researchers to participate in collaborative research projects with international colleagues Similar improvements to the ARC would serve to increase Australia’s research competitiveness internationally, as well as increasing the visibility of Australia’s research sector on the global stage – enhancing Australia’s attractiveness as a destination for international students, as well as potentially enhancing collaboration and investment in our research and development sector. One such enhancement that could be made by ARC would be to more strongly encourage (or even mandate) that data generated from ARC-funded projects is deposited in relevant international databases. This would cement Australia’s place as a global research partner and ensures maximal benefit can be derived from data generated with the support of ARC.

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?

WEHI is supportive of a rigorous, fair and transparent method of evaluating research excellence and impact, that adequately accommodates the diversity of disciplines of research undertaken within Australia.

We note that a number of funding bodies already require reporting of measures of research excellence and impact, and that this can place a large administrative burden on research organisations.

We suggest that if ARC revises its own system of assessment of research excellence and impact, that this is designed to harmonises with other systems where possible, in order to reduce duplication of effort and administrative burden.

We note that the Association of Australian Medical Research Institutes (AAMRI) has recently developed a Research Impact Framework (2021) through an extensive international consultation process. This framework has been well received by medical research institutes and could be adaptable to the diversity of research that is funded by the ARC.

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?

We reiterate that as the Australia Government’s peak body for disbursing funding for non-medical research, the ARC has an unstated contract with Australian taxpayers to spend their money on the best research being undertaken in Australia.

In relation to the ARC Act, the current restriction of ARC funding to universities overlooks the significant and globally competitive non-medical research being undertaken at other not-for-profit, non-commercial organisations in Australia – including fundamental research undertaken at independent medical research institutes, botanical gardens, herbaria, museums and libraries. We believe that the ARC Act should reflect this diversity of organisations that are important parts of the Australian research landscape. This would better meet the needs of Australia’s research community – ensuring funding is fairly allocated to the best research within the scope of the ARC, and avoiding the potentially convoluted arrangements and complex administration that some researchers working at non-university organisations currently use to access ARC funding via joint university appointments.

Ensuring the best research in Australia is funded through a fair, transparent and merit-based process strengthens the ARC’s social licence for public funding of research, and enables and promotes Australia’s competitiveness on the global stage, and builds opportunities for global partnerships. This can only be achieved if the ARC’s purpose is inclusive of all non-medical research underway in Australia, whether that be within universities, or at other non-government, not-for-profit organisations conducting world-class, impactful research within Australia.

Submission received

13 December 2022

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