The University of Notre Dame Australia

Name (Individual/Organisation)

The University of Notre Dame Australia

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 of Notre Dame Australia (UNDA) welcomes the opportunity to contribute to the Independent Review of the Australian Research Council (ARC). The ARC is a vital, leading component of the Australian research landscape. The ARC’s assessment and decision process has influence beyond determining which individual research projects receive financial support. The prestige attached to ARC funding success for individuals, groups, and universities can have long term implications for careers, longevity of and institutional support for research clusters and collaborations, and for the ability for universities to attract future research success.

The ARC must play a key role in funding research prioritising and amplifying Indigenous priorities, practices, knowledges, and innovation. Indigenous-led research, either through Indigenous Chief Investigators or through research co-designed and co-produced with Indigenous peoples, must be recognised and supported. ARC processes, including peer review assessment and approval processes, must encourage and incentivise innovative research practice through Indigenous lenses. This support must extend through the Excellence in Research for Australia (ERA) and Engagement and Impact (EI) assessments, with evaluations recognising and incorporating different perspectives, practices, and end products.

The prestige attached to ARC funding success and the low success rate has led to budget creep, with projects seeking more funding and more ambitious research goals to stay competitive. This disadvantages disciplines where research is less resource intensive, as they can be interpreted as less impressive or less important fields because of the lower cost. The Review must consider the influence and accountability of the ARC across a wide range of factors, not limited to solely the provision for and administration of research funding.

UNDA supports formalising the balance of Discovery and Linkage programs to ensure that a range of research practices, disciplines, and foci are supported. Curiosity-led research, as well as research with fewer opportunities for commercialisation or industry engagement, is key to a vibrant and robust research sector, and should not be deprioritised in favour of impact- and commercialisation-oriented research. The Linkage program should also consider how to support partnerships through the funding rules with organisations less able to commit significant cash contributions, where the project is valuable and beneficial to the organisation’s but the current cost of participation is prohibitively high, for example community groups and not for profit organisations. This would help widen the scope of research engagement and beneficial outcomes funded by the ARC and help smaller universities partner and innovate with different types of partners.

The ARC Review should propose that the ARC fund the full costs of research.
With Excellence in Research Australian (ERA) results now explicitly linked to the higher education provider standards through TEQSA, the ARC’s influence to shape the research landscape is extended even further. The assessment rules and processes of the ERA, as well as universities’ capacity to devote resources towards the assessment exercises, will have direct consequences for some institutions. Within this broad context of the ARC’s wide-reaching influence on the Australian research landscape, the ARC Review is timely, and the outcomes will be hugely significant for years to come.

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.

UNDA supports the establishment of a governance Board to provide additional oversight over ARC functions and performance. The Board membership should require representation from across the sector, ensuring that smaller, emerging, and discipline-focused universities are represented alongside more well-established comprehensive research universities. The Board membership must also include Indigenous representation, as well as representation from sectors outside of academia, to ensure Indigenous research and industry and community perspectives and needs are included.

The UNDA is generally supportive of ensuring ARC leadership and governance structures can draw upon adequate academic research expertise and experience. One option is to require the CEO of the ARC to have recent research and lead investigator experience and a significant research track record. However, the need for research experience should be balanced against expertise sufficient to lead a large administrative body. It may be sufficient to ensure that the ARC Act requires a range of skills and experience in its governance structures.

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?

There has been a strong indication from the sector that grant assessment and decision making must be founded in academic expertise. UNDA supports the principle that grant applications should be assessed and granted based on expert academic peer evaluation. The ARC must take steps to ensure that the pool of expertise includes diverse voices and perspectives to mitigate for unconscious bias and movement towards status quo. Innovative or paradigm shifting research proposals, for example those utilising Indigenous research practice and methodology or intending to primarily produce non-traditional research outputs, should not be disadvantaged for seeking to work outside of accepted norms.

There may be opportunities to expand the pool of expertise beyond academia where appropriate and as needed. For Linkage program schemes, assessment panels may benefit from industry, community, or government expertise in assessing the viability or potential benefits for those groups. However, the decision making should prioritise the academic and scientific rigour, feasibility, and likelihood of success.

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.

Peer review is an essential component of research assessment and evaluation. UNDA supports the principle that the allocation of investment in research should primarily rely on the evaluation of the quality and likely impact of the proposals, and that evaluation and decision making should be based on expertise peer assessment. If Ministerial intervention is required, it should only occur in genuine and extreme cases with full transparency to Parliament, the research community, and the general public. It is vital to support the ARC’s independence and ensure the academic community is confident in its decision making and administration, and the public is confident in the processes supporting public spending on research are underpinned by scientific rigour and accountability. This public and research sector confidence would also strengthen the ARC’s social licence for funding research.

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

It is appropriate and necessary to communicate the public value of research and development and draw connections between public spending on research to the benefits we enjoy as a result of research and innovation. It is not clear that the National Interest Test (NIT) is the best way to communicate those ideas, or to assess for benefit in schemes where direct benefits or impacts are anticipated.

Impact statements are a useful part of the assessment process for some grant schemes. Where research is expected to have some direct benefit or outcome, and where the funding is directly related to achieving those benefits/outcomes, they should be assessed alongside the other aspects of the grant application by the assessors. Non-academic expertise could be sought if required to supplement the academic assessment into the feasibility, significance, and the beneficiaries’ need for the intended impacts. The benefit statements could be aligned with a range of priorities depending on the research discipline and intended outcomes, e.g. the Science and Research Priorities, the Manufacturing priorities, the National Reconstruction Fund priorities, and Indigenous-led priorities.

For schemes where the research is more likely to be pure basic, curiosity-led, or without a clear near-future product or commercialisation outcome, public benefits or applied uses are not necessarily immediately apparent or accessible without significant additional research, development, and financial support. Research of this kind should not be assessed as fundable solely on the basis of whether the general public would be able to see a clear outcome or benefit – or rather whether the researcher is able to concisely articulate a clear outcome or benefit.

To address the NIT’s role of communicating about public spending on research transparent and accountable, the ARC could require impact/benefit reporting for completed research grants as a condition of the grant. The reporting could fulfil the role of public information on research spending and increase the public face of research. Statements for completed grants would reduce the burden on applicants to articulate potential benefits of research that has not yet happened, would increase the onus on researchers to capture and evaluate information about the impact of their research, and would also showcase the actual benefits of researcher rather than the potential aspirational benefits.

The NIT is focused on the national interest in the research, limiting its scope and its utility for different kinds of collaborators. Since 2002, 61% of ARC funded projects involve an international collaborator, including over 10,900 Discovery Projects and 2,500 Linkage Projects. A focus on the national level is potentially misaligned with research addressing regionally significant problems as well as research with an international motivation. If the ARC process removes the NIT and expands the impact/benefit statement in the application process, the assessment process must respond to the different needs of different beneficiaries regionally, nationally, and internationally.

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

With limited resources, the ARC successfully administers large grant schemes requiring significant oversight, management, and communication components. The significant demands on the ARC should not be understated. However, there are areas of potential improvement to processes that could help alleviate duplication of effort or unnecessary work. More streamlined application processes would also help reduce barriers to collaboration with non-academic funding and research partners and increase opportunities for less well-funded research offices to provide more extensive research development and quality control functions.

The ARC could consider introducing a multi-step approval process, with early exclusion points to reduce the burden on the system of completing and assessing applications that are not competitive. The process might involve an EOI or short application stage with invitations for full applications for successful EOIs. This would reduce the number of full applications going through the full peer review assessment process and ensure that the applications that do go forward are more likely to be assessed as fundable.

The process for securing university support letters for applications creates additional burdens for researchers. The requirements for the letter of support are extensive and often overlap with or duplicate information already in the application itself. This process also can disadvantage smaller, less well-funded universities with fewer resources to devote to specialised writing expertise to work on the letters. This is particularly relevant to fellowships with external applicants, where the applicant does not have an existing relationship with the research office or knowledge of how to navigate the process. One way to reduce the effort whilst still capturing the required information is to simplify the support process to a short, structured form or a simple sign off by research executive to indicate support for the application.

Lengthy approval timelines and contract negotiations can create barriers to international and industry collaborations. These partners may be less willing to enter into a long application process with complicated and in-depth requirements or may not be able to commit to contributing funds without firm timelines. A streamlined application and approval process with shorter timelines would help universities build enduring, successful partnerships with non-academic groups.

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 ARC could consider a multi-step application process to help reduce administrative burden for researchers, research offices, assessors, and the ARC, as well as to reduce wait times for outcomes for unsuccessful applicants. This sort of approach has been adopted successfully elsewhere, including the European Research Council (ERC) and the Marsden Fund in New Zealand. The application process could start with an EOI or short application round to assess the proposal feasibility and competitiveness from the discipline perspective. Successful EOIs would be invited to submit an expanded application with the full budget, rationale, and collaborative information, to go through the full peer review assessment. Unsuccessful EOIs would be notified earlier in the process, which would allow them to pursue other methods of funding, start development work towards a more competitive application for future rounds, and seek secure employment for those on short term or temporary contracts.

Track record is important for ARC grant success. However, for emerging disciplines or university departments growing in capacity, it can be difficult to demonstrate competitive track record when compared against well established and well-funded disciplines or departments. The ARC could consider a small grants program aimed at building track record and growing capacity for areas that are traditionally not competitive for the larger schemes. This could help address unintentional institutional prestige bias, minority and marginalised group bias, and barriers to emerging research disciplines and practices receiving funding. A small grants scheme could also help address the issue of budget and scope bloat, giving more opportunities for grants success to low-cost research areas and disciplines with traditionally lower rates of academic collaboration. These issues can disproportionately impact on smaller universities with research foci in low-cost areas, as their research strengths are less likely to achieve ARC grant success through larger schemes dominated by high-cost research disciplines.

Reducing barriers to engaging with and contracting with international and industry partners is a key concern across the sector. Suggestions for streamlining processes include:
• allowing non-academic partners to be listed as Partner Investigators. This would help universities build enduring successful research partnerships with end-users through co-design and collaborative research, increase research capacity, and formalise hybrid research teams.
• Revise the ROPE statement requirements for industry. The ROPE statement is geared towards traditional academic career progression and does not necessarily explain non-academic opportunity and performance.
• Simplifying adding named research partners on RMS

The new Industry Fellowships require a simpler budget than the other schemes. The ARC could consider rolling the new budget template out to the other schemes to simplify the budgeting process across the programs.

The implementation of ORCID as a data source for publications in grant applications has encouraged the uptake of ORCID and has the potential to reduce double handling of publications data between systems. However, ORCID does not cover all research output types. The humanities and social sciences, particularly creative practice disciplines, are not well covered by third party citation databases, and ORCID does not distinguish between non-traditional research outputs.

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?

The ERA has succeeded in changing research behaviours in Australia to prioritise research quality over quantity of output. Future iterations of ERA should respond to new challenges and opportunities in the research sector and incentivise those behaviours that will uplift Australian research internationally. There are no funding outcomes directly attached to ERA, however it is now explicitly linked with the new higher education provider standards. The criticisms of the ERA methodology and the reliability of its outcomes across STEMM and HASS disciplines, as well as the lack of transparency of assessment and of institutional data, suggest that the current iteration of the ERA has served its purpose, the administrative burdens now outweigh the benefits, and the exercise should be retired. The EI exercise has only had one full round, and its benefits are not yet clear. A new vision for research evaluation and comparison could be beneficial.

Currently, the ERA and EI are separate exercises driving potentially contradictory behaviours. The ERA incentivises pure basic research aimed at an international research audience, as this is the best way to drive citation performance. Industry engagement, translational and sector-focused research work, and non-traditional research communication are disincentivised through the ERA assessment, as these activities are less likely to lead to traditional indicators of research quality – citations and research peer recognition. The EI incentivises industry engagement and investment in activities that are unlikely to lead to academic impact. The ERA/EI dynamic requires a one-way relationship between academic excellence and research impact, implying that research impact must be underpinned by research excellence, but research excellence does not necessarily have to lead to research impact. Future research and impact evaluation exercises should reconsider how to frame research excellence and how to incentivise the research community to achieve quality in multiple spheres, not solely focusing on academic impact, but also considering the contribution, significance, and reach of translational research work aimed at a range of audiences.

Excellence in Indigenous studies is not well covered by ERA/EI. Comparing Australian Indigenous Studies to a world benchmark is challenging, the evaluation does not distinguish between Indigenous-led research and Indigenous-topic research. This means that it will not identify or describe the Indigenous research workforce or the opportunities, challenges, or achievements of the workforce. As the ERA/EI assessments are being developed, the process needs to consult about how to centre Indigenous perspectives on how to quantify and evaluate Indigenous-led research.

The responsibility for the administration of the ERA/EI, and the RQF before it, has sat with the ARC for over a decade. In reviewing the ARC’s scope and role, the panel should consider whether the responsibility for independent evaluation of research in Australia should fall to an independent body, rather than a funding council.

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?

If the ERA/EI exercises were cancelled or deferred indefinitely, the existing evaluation expertise within the ARC itself, the Research Evaluation Committees and peer reviewers, and other areas could be leveraged to continue to monitor and evaluate research activity and performance outside of ERA/EI processes.

For example, the ARC could develop and administer a database of Australian-authored research publications to uplift discoverability of and access to research. An example of this approach is the Research Portal Denmark established by the National Open Research Analytics and funded by the Danish Agency for Higher Education and Science (https://forskningsportal.dk/about-research-portal/). Shifting the focus of research evaluation away from abstract performance and towards encouraging collaboration, increasing discoverability, and facilitating opportunities could be a useful way to refocus the existing expertise into capacity and capability building across the Australian research landscape. A centralised dataset of research inputs, outputs, and outcomes would reduce duplication of effort across the sector, and reduce the noise in the data from trying to compare different universities’ datasets. It would also serve as a powerful source of information about Australian research activity and performance. It would require significant investment to create and maintain. However, each university is currently investing in separate, similar but different, datasets, and it is feasible that this investment could be redirected towards shared benefits and goals.

Any redirection of the ARC’s existing evaluation resources towards providing data or assistance to universities, collaborators, or end users, would need to carefully consider whether the data or assistance constitutes an unfair advantage over other groups. The ARC must maintain neutrality in the grants space, and any other function the ARC performs must maintain that neutrality.

Data-driven methodologies potentially disadvantage HASS disciplines. There are no robust and reliable third-party sources of information covering the breadth of publishing practices, and no reliable metrics that can be used as proxies for quality. Future research performance evaluation must respond to discipline norms, align with best practice in the responsible use of metrics, and not preference numbers and data-driven methods over appropriate context in interpreting activity and performance.

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?

The Review should consider proposing ways to discourage or disallow “poaching” successful grant recipients following scheme outcome announcements. The Review should look into whether there is a widespread practice of universities targeting and courting recent grant recipients, and what could be done to reduce the practice. Research environment is a key component of the application assessment. If projects can move institutions following a successful outcome, this calls into question whether research environment is key factor in grant success. This is potentially an issue felt by smaller Universities with limited resources for research investment.

Submission received

14 December 2022

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