RMIT University

Name (Individual/Organisation)

RMIT 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.

In alignment with the ATN’s submission, our contributors noted that little is specified in the Act at present, apart from the total funding available and the relationship between the Minister and the CEO, with the role of the ARC limited to the making of high-quality recommendations, administration of financial regimes and provision of high-quality advice.

They suggested that the Act itself should remain high-level to avoid unnecessary legislative complexity and potential inflexibility in the face of a rapidly shifting research landscape. That is, the Act should focus upon outcomes only, with potential to mandate consultation around strategies to achieve those outcomes.

They also suggested that the role of the ARC would benefit by revision leading to a more principles-based approach and a focus on the core role and responsibilities of a major Commonwealth funding agency, as well as in proactively promoting and fostering ethical, excellent and responsible research in Australia. With respect to the latter, stakeholders emphasised that this is a shared responsibility across all relevant Commonwealth agencies, bodies and entities, as well as research institutions and researchers.

However, our contributors also noted that there are some areas requiring clarification, either by inclusion within the Act or via policy / guidelines. These are:

• Scope
It may be more effective to focus upon what is excluded in the Act, rather than what is included. There were a number of requests to tighten the definition of health and medical research and clarify its exclusion from ARC programs. For example, while clinical and health service research is excluded, it is unclear whether foundational health and medical research may be funded under the Discovery program.
• Balance between Discovery and Linkage research programs
Our contributors felt that maintaining the balance of the two research programs is essential. This is because the emphasis on translational benefit, while necessary, was perceived to conflict with the need to support and protect fundamental “blue-sky” research. For the most part, they agreed that this balance is not something that should be prescribed within the Act; rather, it should be covered in policy and practice documents and guidelines.
• Career pathways
Retaining researchers can be achieved via the establishment of a clear career path between the Future Fellowships scheme, Laureate fellowships, and Centres of Excellence. To realise this pathway, gaps need to be filled with new programs between Future Fellowships and Laureates, and between Laureates and Centres of Excellence. It may also be an advantage to allow consecutive Future Fellowships.
• International collaboration
Enabling and supporting international collaboration should also be one of the outcomes enshrined in the Act, although how this is achieved should remain outside of it.

Our stakeholders also emphasised the importance of considering any revisions in the context of legislation for other Commonwealth agencies, bodies and entities relevant to research, including the Tertiary Education Quality and Standards Act 2011, Higher Education Standards Framework (Threshold Standards) 2021, and National Health and Medical Research Council Act 1992. This is with a view to better articulating and clarifying the individual role and responsibilities of the ARC and reducing any duplication of function.

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.

Our contributors were unanimously in favour of re-appointing a Board. The general view was that the current model has been largely effective, but the appointment of a Board is better aligned to principles of good governance and would provide greater consistency, stability and transparency to the ARC’s decisions and actions.

While there is strong support for the re-establishment of a Board, on the question of the Board’s model, and who should be responsible for appointing it, opinions differed. Some supported the model proposed in the consultation paper as being appropriate and fit for purpose. In this model, the CEO is responsible to the ministerially-appointed Board. However, the relationship between the CEO and the Minister would also depend upon the Minister’s capacity to veto funding decisions, as addressed in question four below. In that case, the CEO should be responsible to the Minister, and the Minister answerable to Parliament.

Others did not support the model proposed, largely based on concerns relating to transparency and accountability as above. No alternative models were proposed.

However, in either case, it was felt that the Board should be more participatory and inclusive. For example, the Board should include members of the community (both research and non-research) as well as experienced non-sitting members of the College of Experts.

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?

It was felt that academic and research-informed practice could be one of the outcomes or principles enshrined in the Act, as discussed in question one. This would require oversight by the newly appointed Board and / or the ARC Advisory Committee. This focus and oversight must ensure that the arrangements in place support academic expertise as paramount. A communications campaign could also be launched at the same time, to inform and reassure the public and the research community.
Our contributors commended the current approach to the College of Experts, and suggested that greater input from the research community on appointments to the College would be welcomed.

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 support the ATN’s suggestion that ARC Act could require peer review practice to be a legislated outcome (see question one). We also received considerable feedback on the topic of ministerial intervention, which remains a concern for the wider research community.

Our contributors noted that the ARC review process already includes detailed consideration of the national interest alongside expert assessments of research excellence. The decisions made by the ARC are therefore well considered. Many of our contributors were against any form of ministerial intervention in the grant allocation process for this reason. However, it was also acknowledged that there may sometimes be relevant information available to the Minister that is unavailable to the ARC (on a limited range of matters such as national security). Accordingly, it was suggested that section 51 of the Act be amended such that, instead of final approval, the Minister has the capacity to intervene in funding decisions on the basis of such information. This could complement the establishment of an ARC Board (see question two), in that the Minister could be required to cite concerns relevant to the ARC Act, Grant Guidelines and Funding Agreement for Board review. The Minister should also be required to explain the rationale for any intervention to Parliament.

This process would give greater confidence to the research community, and could be coupled with a communications plan to help raise the public awareness of how funding decisions are made.

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

We recognise the importance of clearly and simply articulating the national benefits resulting from all research programs. We recognise, then, that the requirement to make such a statement will remain, and agree with the ATN’s assertion that our focus should therefore settle upon formalising and publicising a process around the National Interest Test (NIT).

Our contributors offered several suggestions:
• There should be differences between a NIT supplied for a Discovery grant, and one for a Linkage grant. For Discovery grants, there should be scope to explain how fundamental research may inform future applied research and development, as there may not be the immediate connections to industry that a Linkage grant might produce
• The NIT should be longer to enable clearer descriptions of the research and its benefits
• A template should be supplied, along with stylistic guides and examples to show researchers how to write a NIT.

The limitations of the NIT and importance of ensuring integrity more broadly in research were also noted with respect to preserving and strengthening the social licence for public funding of research.
Our stakeholders understand the imperative to communicate the benefits of research to the public, but feel that we also need to acknowledge that not all researchers are expert communicators. There is an institutional and governmental responsibility to support them in this, and to engage in promotion of the public benefits of research on the researchers’ behalf.

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

A common theme in the feedback we received was around duplication in collecting information, notifications and reporting across Commonwealth agencies, including the ARC.
We appreciate the ARCs ongoing efforts to streamline administrative processes and minimise duplication. An additional suggestion in this regard was that researchers store some of the required documents in online profiles, with these profiles accessible to the ARC and other relevant Commonwealth agencies (for example, the NHMRC).

Our ERA / EI collection team offered the following more detailed points:

1. Collection of research outputs already available in public/commercial databases should not be required
2. Collection of research outputs not already available in public/commercial databases could be supported as a national project by providing extra support to public/commercial databases to include additional quality research outputs (incl. creative outputs) or implementing a public national repository (to be turned into an international repository)
3. Point 2 above could remove the need of each institution hosting a separate research repository/publication repository for open access requirements, further reducing institution burdens
4. Data reported to the ARC should be shared with other government agencies to reduce reporting burden, e.g. Research Service Provider Registration: https://business.gov.au/grants-and-programs/research-and-development-tax-incentive/apply-to-become-a-research-service-provider
5. Establish national-level analytics capability on research quality and activity, supporting researchers and research organisations in research prioritisation and collaboration.

On a similar theme, we also endorse the ATN’s recommendation that there be a whole-of-Government, cross-agency review of administrative and regulatory burden, including:

• Academic freedom model code (Education)
• Australia’s sanctions regime (Foreign Affairs and Trade)
• Critical Infrastructure protections (Home Affairs)
• Critical Technologies list (Industry, Science and Resources)
• Defence Trade Controls (Defence)
• ESOS and CRICOS (Education)
• Foreign Arrangements Scheme (Foreign Affairs and Trade)
• Foreign Influence Transparency Scheme (Attorney-General)
• Research Integrity breach management (ARC and ARIC)
• Threshold Standards (Education)
• UFIT Guidelines (multi-agency).

Such a review could identify points of duplication between agencies, and potentially reduce the administrative load for researchers, institutions and governmental bodies alike.

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.

In line with the ATN recommendation, we agree that processes should not be enshrined in the Act to ensure flexibility and adaptability. As stated earlier, we recommend instead that higher-level values such as transparency, communication and consultation are enshrined in the Act.

Our contributors made a number of suggestions towards improving processes outside of the Act for the ARC’s consideration. These include:

• trialling an Expression of Interest stage, which has been widely adopted globally. Not only does this assist in the review stage, it also reduces the burden on researchers
• linking ARC schemes to equivalent overseas schemes to encourage global collaboration, eg UKRC, Horizon Europe
• trialling an open call to the Discovery program, as is done with the EPSRC’s Standard Research scheme. Proposals are sent out for review as they are received, and evaluated through panels convened periodically when a critical number of reviews have been returned
• the Canadian SSHRC (Social Sciences and Humanities Research Council), has streamlined some processes and procedures. For example, grant project descriptions are half the ARC’s length at five pages
• trialling a 2-step application process, similar to the NISDRG (National Intelligence and Security Discovery Research Grants) program, and consulting with universities on resulting reductions in the administrative load.

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?

Our contributors agreed that ERA and EI should only be enshrined in legislation if they are explicitly linked to funding. If these exercises are not linked to funding, then the Act should be amended to reference a general research quality, engagement and impact assessment function as suggested in point c above.
Accordingly, the responses to the sub-questions are detailed below.

a. While we acknowledge that ERA and EI have been benchmarks for our measurement of research excellence and impact, our contributors did not see the need for a highly rigorous, retrospective excellence and impact assessment exercise in the absence of a link to funding. They felt that there are existing public / commercial data sets representing research quality by institution that do not require enhancement; and researchers are more reluctant to engage with the exercise without the motivation of funding benefits. Impact case studies in particular were seen to be time-intensive.

b. Data-driven approaches were cautiously endorsed, as long as there was no diminishment of the importance of peer review. It was also noted that a data-driven approach is well suited to STEM research, but in HASS areas, evidence-based narratives are more effective measures of excellence and impact as social and cultural dimensions can be captured. Another suggestion was to establish national analytics capability, and take the lead in plugging data gaps with a national database (or clear guiding information) to support existing public/commercial databases. The evaluation can be made transparent based on comprehensive data and robust metrics for promoting Australian research, guiding research directions, encouraging quality research, and allocating research funding.

c. Yes, as noted above.

d. Yes, this was supported.

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?

Again, our contributors cautiously endorsed a data-driven methodology, recognising the difficulties in developing meaningful measures of excellence and impact, and on condition that there was no diminishment of the peer-review process. Further suggestions included:

a. The ARC can best use its expertise and capability by:
• providing clear guidance to support researchers and research organisations in articulating and evidencing their research excellence and impact and acknowledging the nexus between integrity and excellence
• providing on-going expert guidance to data providers on plugging data gaps and quality evaluation
• considering clear indicators of research excellence in the form of publications, patents or similar research outcomes, as well as student completions for each funded grant. These lead to commercialisation and workforce build up, which would naturally evolve from the research outcomes.

b. The important elements within this capability would be the development of a platform for showcasing to the world not only our research excellence and impact, but also integrity and opportunities for collaboration (eg in a national database of expertise). On-going automated maintenance of the skills database would also be useful, and should be based on existing ORCID / Google Scholar data.

c. It was felt that a data-driven methodology would assist (with the above caveat). The ARC would also need to plug data gaps and provide on-going research quality assessment guidance and tools to assist data providers.

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 ARC is a critical agency in the Australian research landscape, and we encourage this review to revisit the role of the ARC in promoting and fostering responsible, ethical research, with honesty and integrity, both nationally and globally. Inherent in this is a revision of the Objects of the Act, along with the functions of the ARC. We ask that the Board be reinstated, a principles-based approach be adopted, evidence-based decision making and peer review be paramount, and promotion of excellence in research be proactively pursued.

Thank you for the opportunity to provide feedback. We welcome requests for further information or discussion.

Submission received

14 December 2022

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