Anonymous #37

Name (Individual/Organisation)

Anonymous #37

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 University agrees with the Consultation Paper that the current Act doesn’t adequately capture the full role of the ARC. The purpose of the ARC should be strengthened in the ARC Act including provisions for:

- Research funding for Australian Universities, including basic and applied research, in all research fields other than medical research which is eligible to be funded by the NHMRC and MRFF;
- The importance of peer review for the allocation of competitive research funding;
- Promoting national research excellence and impact;
- Providing national leadership in areas of research policy that impact on the quality and integrity of research funded by the ARC; and
- Providing high-quality advice to the Minister about matters relating to research.

The Act should not specify a balance between Discovery and Linkage Programs within the National Competitive Grants Program (NCGP), as these Programs should be open to periodic review.

The Act should state that both basic and applied research are funded to ensure that the ARC continues to fund pure and strategic basic research as well as applied research. Additionally, the important role the ARC plays in supporting and funding humanities, arts and social science research and the societal benefits that arise from these research disciplines should also be clearly articulated.

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.

The University is supportive of the proposed Board model outlined in the Consultation Paper, noting that the composition and appointment are crucial, as is the function of the Board. The University is supportive of the Board making recommendations to the Minister for the appointment of a CEO who has experienced in research and research management.

In implementing the proposed Board model, some key items which should be further considered are:

- Clear delineation of the role of the Board (advisory versus governance);
- The establishment of appropriate reporting advisory lines for the Chair of the Board and the CEO to the Minister; and
- Opportunities to connect this proposed Board with other relevant portfolios related to research, including the Department of Industry, Science and Resources and Office of the Chief Scientist.

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 University supports the proposal that the Board makes recommendations to the Minister for the appointment of the CEO who is experienced in research and research management. If the Board composition is well defined to ensure representation from research leaders, then this should be sufficient.

We support the continuation of the current appointment of Executive Directors in academic disciplines across the range of fields of ARC funded research and agree with the Consultation Paper that this enables the ARC to remain current on issues of disciplinary practice and industry needs pertinent to research funding, conduct and evaluation, across its fields of research. We don’t believe that the Act needs to specify that the ARC must appoint Executive Directors from various research fields. This is an operational detail which should be handled by the CEO, potentially reporting to the Board on ensuring representation across its fields of research.

The University is supportive of the Consultation Paper suggestion that the Act should include a statement on peer review for the allocation of competitive research funding, without specifying the process of this peer review. The current practice of appointment of College of Experts to support the peer review process is appropriate and an operational process which doesn’t need to be covered by the Act. The ARC, with consultation, should be able to modify the form of the peer review process to adapt to changing sector needs and best practice.

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 University is supportive of the Consultation paper suggestion that the Act should include a statement on the importance of peer review for the allocation of competitive research funding.

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 University supports the recent change announced by the ARC that the National Interest Test Statements (NITS) will be an input into the peer review process and that the content of what needs to be addressed within the NIT has been revised. The NITS should not be used by the Minister to decline a recommendation for funding.

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

The University welcomes the opportunity from the Panel to have input into process improvements which reduce administrative burdens for researchers, research offices, partners and the ARC. Administrative burdens which could be addressed include:

- The size of applications and duplication of information within applications which is a burden for applicants and the peer reviewers. The current Statement by Administering Organisation/Letters of Support in Fellowships and Linkage Projects are an example of such duplication and could be removed.

- Consideration on which ARC schemes require budgets within applications and then at what level. The NHMRC have successfully removed budgets from their Fellowship and Centre for Research Excellence applications. A similar approach could be taken for the ARC DECRA and Future Fellowship schemes where applicants identify the level of fellowship and then receive the full standard ARC project budget without providing a detailed budget within the application.

- The DECRA and Early Career Industry Fellowship Schemes should also cover the Fellow’s salary similar to that of the Future Fellowship scheme.

- For schemes with budgets, other than LIEF, we suggest removal of the cash contributions from universities. This is perceived as universities buying success or as a reason for lack of success. The peer review assessment shouldn’t include assessment on the ability of a university to contribute cash to a project. To avoid this for LIEF, the rules should be amended to specify the maximum percentage cash contribution from Australian universities. This percentage should be varied based on size of the University and whether it is a single or multi university bid.

- Introduction of a minimum data date within the application process to enable both the ARC and Institutions to have an idea of number of applications prior to the actual deadline. This will enable the ARC to consider demands on peer review and Institutions to ensure greater compliance with ARC and external requirements such as UFIT.

- Consideration for advising and removing ineligible applications earlier in the process. This would reduce the workload for the panels in assessing ineligible applications and for the applicants in responding to reviews. For those applications ruled ineligible due to the ARC Medical Research Policy, additional feedback how the application breached the Policy would assist applicants to ensure that they don’t submit future ineligible applications.

- The post-award process with the ARC has a high administrative burden for researchers, partners, research offices and the ARC. There needs to be a more balanced approach to the management of successful research projects, determining when the ARC should be the decision maker or whether the University notifies the ARC of the change via the current annual reporting. Currently most changes go to the ARC for formal approval. Examples include moving awarded funds between budget categories, Fellowship suspension or change to FTE due to maternity leave, seeking ARC approval when a CI moves from one Australian University to another. Further, Fellowship holders should be required to remain at their award Universities unless there are exceptional circumstances.

- A specific post-award process which is problematic is extensions to end dates. This occurs in the End of Year reporting process and the ARC will allow up to a 12-month extension to the end date, when the end date is not beyond the assessment year. If a researcher is already aware that they require an extension beyond the 31 December of the current year, then this can only be requested in March of the following year when the end date has passed. This results in universities allowing expenditure beyond the end date as the ARC will not consider the extension request. If there have been delays during the project which will impact on the end date, then institutions should be able to report this and request end date extensions at the time and at the very least before the end date has passed.

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.

The University believes the ARC plays an important role in supporting research innovation and excellence wherever it occurs across the sector. The current distribution of funding outcomes across the sector (50% of funding shared with 6 Universities over the last 18 years) fails to take advantage of the opportunity to develop Australia’s full research capability and capacity, and support and incentivise-sector engagement. We would warmly welcome the implementation of new strategies and processes which focus more on addressing these missed opportunities and lift the excellence and impact of Australian research.

The ARC should consider re-introducing a ‘Fellowship’ salary for Early Career Researchers (ECR) within project type schemes such as Discovery Projects and Linkage Projects. The ARC currently doesn’t allow for researchers named as a Chief Investigator (CI) on an application to receive a salary. This could result in Early Career Researchers who haven’t yet obtained ongoing appointments being prevented from being named as a CI even though they had significant intellectual input into the proposed project. If they are not named as a CI, they can receive a salary, but they no longer have the CI recognition needed to progress their career.

The support for ECR and MCR could be further expanded to have funding specifically for teams of MRC and ECR only applications to ensure that the ARC is supporting the researchers of the future where team-based research, rather than CI-centric research is increasingly important.

These measures would support the development of ECRs as part of a team with experienced researchers or as a team of ECR/MCRs.

The University supports the suggestion in the Consultation Paper of introducing a dedicated travel fund. This would support Australian researchers in international collaboration with leading researchers, including participating in other Global travel schemes which require funding from both countries.

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?

Overall, the University’s view is that Excellence in Research for Australia (ERA) has performed well in shifting the mindset and practices from research quantity to research quality since its inception. Similarly, the Engagement and Impact Assessment (EI) has created increasing awareness on the importance of research translation and impact to the end-user. However, at this stage, with numerous international ranking systems available (QS, THE world and subject rankings, THE Impact rankings), the value of ERA and EI in their current form remains unclear given the significant resources required to complete this exercise. We recommend pausing this assessment until the Australian Universities Accord process has been completed.

The University does not believe the Act should be amended to reference a research quality, engagement and impact assessment function.

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?

The University is supportive of the approach suggested in the Consultation Paper which involves the development of an explicit program of work to take the existing ARC capability into a new phase. Developing this program of work in conjunction with, or parallel to, the Australian Universities Accord will ensure consistent alignment and enable a holistic approach to be taken to driving research and Higher education excellence and impact.

It is important that in developing this program of works, the University sector, Government, and End Users are regularly engaged and consulted to ensure that the outcome is one that meets all stakeholders’ needs and actively facilitates research collaboration.

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?

- An ARC that engages researchers as applicants and assessors, College members and other panellists, and that engages the institutions that employ researchers, the public, and other stakeholders is vital for Australia’s future.

- ARC applications and grants are important targets to structure individual and collaborative research at different career stages. The different ARC schemes aid research planning and publication strategy. They encourage new collaborations and new networks. Researchers benefit by developing a competitive (and coherent) track record, by writing about the significance of their research, by situating their ideas in disciplines and fields. Skills developed through competitive grant applications transfer into promotion applications, job applications and, later, in mentoring others.

- The Linkage Infrastructure, Equipment and Facilities (LIEF) scheme should specify that the maximum percentage for combined cash contribution from Australian universities towards the total cost of the infrastructure/equipment. This percentage should be varied based on size of the University and whether it is a single or multi university bid. This will enable excellent infrastructure for all.

- We propose that unspent Linkage Program funding could be directed towards a near-miss seed fund. This would enable to researchers, in particular Early and Mid-Career researchers, to further build and foster the relationship with industry partner(s) and progress past the Proof-of-Concept phase, potentially enabling successful Linkage applications in following rounds or via other external sources.

- Research is more often than not a collaborative rather than individual endeavour, and
team-based interdisciplinary research should be encouraged and rewarded as a change to the practice of Chief Investigator-funded research. This could be supported via a Discovery Project scheme focused on interdisciplinary research projects driven by teams of promising Early and Mid-Career researchers.

- Equity and diversity warrants greater focus for the ARC in the future, in terms of setting equity and diversity goals, principles; realising these within a set time timeframe; and the actions and direction that will be required in order to do so.

Submission received

14 December 2022

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