Macquarie University

Name (Individual/Organisation)

Macquarie 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.

Macquarie believes that the aims of the ARC and the scope of research it supports should be included in the ARC Act. The wording of this scope must safeguard the interests of all researchers and disciplines (with the exception of health and medical research supported by the National Health and Medical Research Council). It also is important that the Act clearly defines the ARC’s role in growing and supporting the capacity of our research sector and workforce to conduct research. Finally, we suggest that the Act provides as much clarity as possible about the boundary between the ARC and National Health and Medical Research Council (NHMRC).

The ARC plays a central role in enabling fundamental research through its Discovery scheme. Macquarie strongly feels that this role should be protected within the Act. Fundamental research is not only valuable in and of itself but empowers intellectual entrepreneurs. The translation and commercialisation pipeline, which is critical for Australia’s future innovation and economic well-being, begins with and depends on basic research.

Many organisations fund translational research, and we welcome similar initiatives from the ARC such as the ARC Industry Fellowship program, which aims to foster relationships between universities and industry as part of the overall balance of the ARC’s research investment portfolio. But an increasing focus on industry engagement should not come at the cost of underfunding basic research. The ARC Act must recognise the unique and crucial role that the ARC plays in supporting fundamental research in Australia as well as its dual priorities of Discovery and Linkage agendas. Beyond the Act, how the ARC supports these dual priorities is an operational matter, one which we hope will be addressed after this Review.

The Act does not need to specify the exact balance between Discovery and Linkage schemes. The legislation should remain flexible so that the ARC can adjust funding arrangements to accommodate changing contexts (e.g., by introducing a new scheme or running a special purpose scheme). However, the Act should specify a minimum level of funding that must be dedicated to basic research via Discovery schemes. That figure should be higher than the current level. This will protect against over-prioritisation of schemes focused only on applied research and partnerships with industry as well as counteract recent tendencies to re-allocate significant funds to the Linkage scheme at the expense of the Discovery scheme.

The ARC Act should also reflect the expectation that the ARC engages with the broader research community to shape Australia’s research landscape. Macquarie strongly believes that the ARC does and must play an important role, working actively with universities, learned academies, and other representative groups, to inform, define, shape, and champion research in this country. The ARC is uniquely positioned to gather and share insights about funding and research with stakeholders, insights that will strengthen Australia’s research capacity, performance, and reputation. Thus, the Act should refer to the ARC’s role of engaging with the research community and working in partnership to foster research rather than to a more interventionist or agenda-setting role.

The ARC also has a crucial role to play in advocating for Australian research and researchers; by educating the public about the culturally and socially transformative nature of fundamental research, rather than shaping its research support agenda to reflect public misperceptions of a ‘lack of utility’. Colleagues in Macquarie’s HASS disciplines especially highlighted this responsibility given that public misperceptions appear to have decreased opportunities for much of Australia’s world-leading HASS research to attract funding support (including overturned funding outcomes). In addition, the ARC’s advocacy should include educating the public on the expertise of Australia’s research community, expertise that extends to the central role of academic expertise and peer review in assessing research (see also our response to Q3). In this way, the ARC will continue to support social transformation via research. This advocacy should take the form of regular targeted, high-impact, public-facing communications that showcase the benefits of funded research. Such storytelling exercises, when supported appropriately within the ARC’s budget, will strengthen the social licence for public funding of research (see also our response to Q5).

Most importantly, the ARC Act should protect against wholesale changes to research funding mechanisms that reflect competing agendas of outgoing and incoming governments. Any reference to shaping the research landscape should recognise the ARC’s responsibility to Australia’s research ecosystem and community.

Recommendation 1: Amend the ARC Act to reflect the scope of research the ARC supports and ensure the interests of all researchers and disciplines are represented.

Recommendation 2: Amend the ARC Act to reflect the ARC’s critical role in funding fundamental research. This includes setting a minimum level for Discovery funding above the current level.

Recommendation 3: Amend the ARC Act to reflect the ARC’s role in informing, defining, and championing research in Australia in partnership with stakeholders across the broader research community.

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.

Macquarie does not believe that the current ARC governance model is adequate for the ARC to perform its functions. Macquarie strongly supports a revision of the ARC Act to reinstate a Board that oversees the operation of the ARC and to which the Senior Management team reports. The Board’s role should be consistent with the Consultation Paper (p. 7), to recommend the appointment of the ARC’s CEO and the College of Experts, and with whom the CEO can consult on the sound development and application of ARC policy. It is important that the Board is not too large or cumbersome so that it can operate with agility in a complex environment.

The governance model currently in use by the ARC allows the CEO and Deputy CEO to make decisions about research funding largely without expert advice from either the academic research sector (apart from peer review of applications) or research professionals working in the sector. Moreover, the CEO is currently, ultimately, a political appointment. In contrast, the priority for a governance model should be to minimise political interference by ensuring the independence of the ARC’s Board and CEO. The views of the Board and College of Experts should be enshrined in legislation as having more weight of expertise than that of the relevant Minister.

To protect this weight of expertise, the appointment process for the Board should ensure that membership is based on expertise in research, research translation, and research administration, consistent with the Consultation Paper (p. 7). All members of the Board must be independent of the incumbent government and have a deep understanding of the processes and value of fundamental research as well as be respected by the research community. The Board must include an appropriate mix of discipline expertise and diversity in its membership. The Board also must be appropriately connected and sync with the operational structure of the ARC, such as the Executive Directors who manage the ARC’s funding programs and Selection Advisory Committees.

Care should be taken in the design of both the Board and criteria for appointments such that it is difficult for governments to compromise the Board’s function through politicised appointments. Macquarie recognises the potential tension that may arise between the Board, the ARC Executive, and the Minister so the framework for their appointment and relationship should be clearly articulated in the ARC Act.

A key current issue for Australia’s research community is that decision making by the ARC appears to be opaque even following periods of consultation (or decisions are taken during periods of consultation). In addition, at times the ARC appears to be distant from the research community, making decisions that may not reflect the research community's interests. A Board will instil greater confidence in the ARC’s decisions and its decision-making processes.

Recommendation 4: Amend the ARC Act to include an ARC Board, with the functions and composition outlined in the Consultation Paper (p. 7). The Act also should be amended to clearly document the expertise and diversity of experience expected of Board members and their relationship with the Minister and CEO.

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 ARC Act should be amended in at least three ways to ensure that academic and research expertise are obtained and maintained to support the ARC: (1) in decision making, (2) in the breadth of expertise, and (3) in greater diversity.

In terms of decision making, the Act should reflect that academic expertise and peer review are the pre-eminent basis for funding decisions. The Act and the ARC should ensure that wherever relevant, expertise from outside the academy is included or consulted; for example, via membership of the new Board (see also our response to Q2) or when industry schemes are considered. However, the foundational expertise guiding funding decisions must always be academic. Additional expertise should not override academic, disciplinary expertise, and the Act should reflect this priority.

In terms of breadth of expertise, given that members of the College of Experts (CoE) often are asked to review applications not within their domain of expertise, the ARC Act should be amended to state that the basis of appointment to the CoE considers the breadth of experience of potential members in addition to their specific expertise. Further, the ARC should consider expanding the number of CoE appointments to ensure that disciplines are appropriately represented. This would ensure a larger and more dynamic cohort who share the burden of assessment. Alternatively, or additionally, the ARC should consider appointing to the CoE people with strong interdisciplinary expertise. Successful discovery is increasingly driven by interdisciplinary collaborations, so it would be useful to reconsider the current silo-based approach and seek academics who understand and can assess interdisciplinary research.

In terms of greater diversity, the makeup of the CoE must be more diverse to avoid insularity and to redress disadvantage for researchers in fields that are small in Australia. The ARC Act should stipulate that membership reflects a significant proportion of the research sector, both socially and geographically (including some international representation), and that all types of universities (small/large, rural/urban) are represented. The Act and the ARC should also ensure that Indigenous academics are appointed more frequently and in greater number than at present.

When grant applications centre on research and dissemination of research that takes place outside Australia, it would be useful to include an assessor from that jurisdiction to judge the likelihood that the resulting research will be impactful in that nation.

Recommendation 5: Amend the ARC Act to ensure that academic expertise and peer review are prioritised in funding decisions and the operations of the ARC, and that other expertise is included in ARC processes and decisions where relevant.

Recommendation 6: Amend the ARC Act to ensure greater breadth of expertise and diversity in the composition of the College of Experts. This includes social and geographic diversity (including international representation), diversity of affiliation, and diversity of expertise including interdisciplinary expertise.

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.

Macquarie strongly supports amendment of the ARC Act to protect the pre-eminence of expert peer review (as outlined in response to Q3) and to limit ministerial capacity to override the expert assessment process by vetoing approved research funding. Provision could be made in the Act for vetos in exceptional circumstances, such as a threat to national security or other major national initiatives. However, in such instances, the Minister should be expected to justify their decision to both Parliament and the public. This legislative reform would ensure that funding outcomes are heavily weighted towards the recommendations of academic reviewers with disciplinary expertise.

Macquarie acknowledges that the Minister can and should establish publicly announced funding priorities, ideally prior to an election. However, only CoE members and peer reviewers have the expertise needed to evaluate the quality of research proposals, research teams, and the relevance of grant applications to specified ministerial priorities. Any interventions by the Minister that appear not clearly motivated or explained would further undermine the integrity and international credibility of the ARC.

It is worth noting that our HASS colleagues in particular expressed concern that HASS disciplines have been disproportionately impacted in the past by the exercise of Ministerial discretion.

Macquarie suggests that the ARC consider best practice examples of legislative and non-legislative measures to manage the allocation of grant funding, for example the NHMRC.

Recommendation 7: Amend the ARC Act to protect the pre-eminence of expert peer review and limit ministerial capacity to override the expert assessment process by vetoing approved research funding, aside from exceptional circumstances. The Act should include provision for Parliamentary and public justification of any vetoed decisions.

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 welcome the ARC’s recent announcement outlining improvements to the requirements and implementation of the National Interest Test (NIT). Our research community held significant concerns about the administrative burden, application, and interpretation of the NIT and recent improvements have addressed many of these. Sector-wide concerns about the NIT have been well-canvassed so instead, we focus our response on broader recommendations for preserving and strengthening the social licence for public funding.

We acknowledge that strengthening the social licence for public funding of research is a sector-wide responsibility. Universities and funding bodies have not, traditionally, achieved this very successfully. We believe that the ARC, alongside universities, learned academies and others, has a responsibility to actively identify and showcase the outcomes and positive impacts of the research it funds. All stakeholders, including the community, should have access to information about publicly funded research so there is broader comprehension of the social value of the ARC’s investment in research.

To date, the NIT has not furthered these aims, in part because NIT statements have never been easily available to the public. Other ARC initiatives, such as ARC Ways and Making a Difference, have furthered these aims to some extent by showcasing the impact of individual projects. We suggest instead focusing on the benefits of research at the scheme or portfolio level where there is a wealth of evidence for public value. Such information might be gathered via the Outcomes and Impacts sections of final grant reports to generate sets of data and narratives that foreground the social benefits of each scheme, as well as the accumulation of these benefits over time. It is important that the ARC consider methods to capture this information (or to leverage already captured information) in ways that minimise administrative burden for researchers and research organisations (see also our response to Q6).

Another way to strengthen the social licence for public funding of research is to upskill the community on the “research impact pathway”. In recent years, the ARC has worked hard to introduce and guide universities around the trajectory of outputs, outcomes, and impact. Likewise at Macquarie, we have been upskilling our workforce on the importance of planning for and documenting research impact. We believe that extending this education to the public, about the steps and time needed to progress from fundamental research to translation in the world in different disciplines, would be another effective way to strengthen the social licence for research.

To achieve this, we recommend that the ARC first unpack what is meant by ‘National Benefit’ and the various ways this can be measured across a project, scheme, or portfolio of research investment. For example, does National Benefit include return on investment, value, and benefits to Australia, and/or value and benefits to the international community? Is it measured only in terms of impacts on society, culture, the environment, and the economy or are knowledge impacts also considered? Is it measured soon after the completion of a project, or can it be measured years and decades later?

Any of the excellent, well-rated impact case studies submitted in EI 2018 could be used as exemplars to draw these distinctions and educate the public about the research impact pathway. For example, Macquarie submitted a case study to the EI assessment in 2018 showcasing how our engineers collaborated with the CSIRO to develop and commercialise wi-fi communications. This led to transformational benefits to industry such as telecommunication providers, medical providers, and defence. At the time of developing this fundamental technology, our researchers could not have imagined the revolutionary impact of their work across every part of society.

Our wi-fi case study highlights the importance of sharing impact stories based on fundamental research and demonstrates how such research underpins translation and commercialisation pipelines (see our response to Q1). In EI 2018, universities could not submit case studies where the impact was solely contribution to knowledge. However, an improved EI-like assessment should allow universities to showcase contributions to knowledge. The ARC also could look to the NHMRC’s definition of research impact as well as other best practice definitions in Australia and the world in shaping a nuanced conceptualisation of research impact.

Recommendation 8: That the ARC actively promote the outcomes and positive impacts of the research it funds across schemes and portfolios. It should extend education about research impact and the impact pathway to stakeholders beyond academia, in particular the public, including emphasising the value of contributions to knowledge.

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

We gathered a significant volume of feedback from Macquarie’s research community in response to this question. We capture the main themes here, supported by some detailed examples. We share more examples in an attachment to the end of this submission and welcome the opportunity to provide further feedback to the ARC as future opportunities allow.

Overall, our research community believes that all elements of ARC processes and practices create administrative burden and/or duplication of effort for researchers, research offices, and research partners. We are concerned that this burden distracts from the strategic intent of research proposals. We acknowledge the progress that the ARC has made towards process improvements, and we welcome further and comprehensive reform.

ARC grant schemes are onerous. They require an excessive investment of time and effort, especially given success rates less than 20%. ROPEs are especially burdensome and, for many Partner Investigators (PI), difficult to complete. The ROPE section presents a significant roadblock for some researchers considering applying for ARC grant funding. The automated reference list is complex and difficult to use. It could be removed entirely and replaced with a PDF upload. The "research load" question in ROPEs is confusing for applicants and adds little value to the assessment process. ROPEs also duplicate the Project Description to some extent. This is one of many areas of duplication in grant applications, both between and within questions. Another example is Letters of Support for Fellowships, which duplicate other areas of the application.

The length of grant applications also serves as a disincentive, dissuading Australian researchers from recruiting international PIs as collaborators. The ARC should explore other mechanisms to include international PIs as legitimate project partners without requiring them to complete lengthy applications. Similarly, industry partners are asked to commit to a project before knowing the outcome, which is often many months after an application is submitted. Small industries whose incomes rely on much faster turnarounds cannot afford a lengthy wait for grants to be approved and contracted.

The limitations of RMS create further burden. For example, RMS does not allow Primary Chief Investigators (PCI) to complete reports and variations. This restriction on access adds to the administrative burden for Research Office staff. For the End of Year Report, Research Offices are responsible for entering all PCI information into RMS, creating a sizeable administrative load and the potential for human error.

Timeliness is another problem area that Macquarie has identified. It is crucial that the ARC adhere wherever possible to its calendar of events; for example, announcements of funding outcomes. If a proposal is not assessed to be competitive and does not proceed to panel consideration (as is the case with Linkage Projects), applicants should be notified as soon as possible instead of waiting over six months for the outcome. Academics on contract appointments are particularly disadvantaged by delays; delays are a huge source of stress and result in potential financial insecurity. In addition, when the delay is imposed on industry partners, this wastes time that could be better employed strengthening the project for resubmission. Delays often also undermine the partnership and future opportunities to collaborate.

Beyond grant applications, the level of detail that must be reported at every stage of a project and the documentation and approval that are required even for small changes create a significant administrative burden for researchers and research support staff. Rather than always require onerous detail, we suggest reducing the level of reporting detail currently mandated for every funded project (and concomitantly increase the ARC’s trust in the operations of universities) and then audit universities.

Any moves to decrease administrative burden should not be implemented at the expense of disciplinary nuances. For example, efforts to streamline and automate the harvesting of outputs for grant applications and/or ERA and EI (see our response to Q8) may disadvantage HASS disciplines that have a higher proportion of non-traditional research outputs (NTROs), since NTROs generally are less discoverable.

Administrative burden could be significantly minimised by the appointment of ARC staff with a deep understanding of on-the-ground processes of research management in Australian universities. These staff can lead efforts, in collaboration with universities and the research management peak body ARMS, to streamline elements of ARC grant processes and practices. We also recommend that the ARC considers implementing best practice examples from successful research funding organisations in Australia and globally such as the NHMRC, and UK and European Councils.

Recommendation 9: That the ARC employ staff with a deep understanding of research management in Australian universities to lead efforts to streamline various elements of the grant process and practices to reduce administrative burden.

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.

To address the overall problem of administrative burden, Macquarie recommends that the ARC considers a re-think of the entire research ecosystem. We recommend that an agile, flexible, responsive, and unified research agency be created by merging with other significant Australian funding bodies (see also our response to Q10). We strongly recommend that the NCGS be fully reviewed under this unified model or, if this model is not currently viable in the Australian context, that the ARC review the NCGS to address equity and diversity issues as well as the considerable administrative burden outlined in our response to Q6.

Many specific recommendations were made by our research community to improve ARC processes. We outline five of these below, which would deliver process improvements and fairer outcomes, and include more in the attachment at the end of this submission. We welcome further opportunities to provide feedback to the ARC about process improvements as the consultation process continues.

First, where information is not required for assessment, Macquarie recommends that it not be requested in a proposal. Such information (as detailed in our response to Q6) can be requested and provided post-award for those proposals that are funded (while being mindful of shifting the burden from pre-award to post-award both for the ARC and universities). We recommend that the ARC consider and adopt best practice international models for grant applications. For example, the European Research Council Synergy Grants require just a five-page summary for the general panel's review and a fifteen-page summary for the expert reviewers submitted simultaneously. This compares very favourably with our much longer ARC grant applications.

Second, a two-stage funding application model could be introduced where a short EOI is required, and, if successful, a more extended grant application is then requested. The Marsden Grants program in New Zealand follows this model. Such an approach would significantly reduce workload for those 80-85% of applicants who are unsuccessful, especially in preparing very detailed budgets and ROPEs. Although a two-stage model may increase workloads and timelines if not implemented well, such an approach could be pilot tested in particular schemes in the first instance.

Besides reducing administrative burden, another advantage of a two-stage model could be that a larger number of expert assessors are encouraged to become involved, including international assessors. This leads to our third suggestion of increasing the number of members in the College of Experts (as noted also in our response to Q3) and incorporating more international, disciplinary experts as peer reviewers.

The current responsibilities of CoE members are extremely significant and time-consuming due to the large volume of applications and the length of each application. This could be reduced (when combined with more streamlined applications) by increasing the selection of academic peers, and extending this internationally, with members then employed, on average, less often over the three-year cycle. Implementing such a suggestion, of course, is not straightforward while also managing conflicts of interest but we suggest that the ARC looks to international models of best practice for effective solutions.

Fourth, consideration should be given to the nature of feedback from different expert reviewers within ARC application and assessment processes. Applicants sometimes receive highly discrepant feedback within and across assessor reports, band rankings, and outcomes. Such feedback (e.g., extremely positive and consistent assessor reports yet extremely low band rankings) confuses researchers, especially ECRs, and a more informative approach would be highly valuable. We suggest that the ARC considers best practice examples of peer review and feedback such as the US National Institutes of Health, which allows unsuccessful applications to be resubmitted once to the same Panel following detailed feedback.

Finally, Macquarie’s research community identified important gaps in the ARC’s portfolio of current funding schemes, which we believe could be filled through the introduction of more flexible funding depending on aims, needs, and disciplines. Such a scheme or schemes could support early career researchers, encourage academic mobility (both between Australian universities and internationally, as included in a number of UK schemes), and support multidisciplinary research. Targeted micro schemes could reduce risk in the Australian research ecosystem, increase diversity and equality, and encourage greater agility and responsiveness. Although smaller schemes have the potential to increase administrative burden, if scheme/s were streamlined to avoid this, potential benefit to the Australian research community would be significant. Some international funding bodies have ensured the viability of similar schemes by introducing a lottery system to award smaller, agile funding following a rigorous EoI assessment.

Overall, a new ARC Board should have responsibility for ensuring that process improvements are embedded as business-as-usual, and this responsibility should be reflected in the ARC Act. To ensure that the risks and implications of any changes on researchers, universities, and other stakeholders are well understood and considered, the Board should consult with a community of research administration professionals.

Recommendation 10: That the ARC benchmark their processes against national and international examples of best practice to address administrative burden and pilot these in a number of funding schemes collaboratively with the sector.

Recommendation 11: That the new ARC Board be responsible for ensuring that process improvements are embedded as BAU practice; this responsibility should be reflected in the ARC Act.

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 feedback from Macquarie’s research community about ERA (especially) and EI was varied. Some believed that ERA has served its purpose in motivating improvements in research quality and identifying, building, and supporting our research strengths. However, others felt that international rankings have now overtaken ERA as a means for universities to benchmark their performance and motivate improvements. Still others agreed that there is a continuing need for rigorous assessment of research outcomes to help shape the research landscape in Australia (see our response to Q1) and strengthen social licence (see our response to Q5) but urge the ARC to look towards prospective rather than retrospective approaches.

There was strong consensus that ERA’s value is compromised by its burdensome and flawed methodology. We acknowledge that the ARC is developing a more data-driven, automated methodology and strongly recommend that this be co-created with the sector and thoroughly piloted to confirm its validity and usefulness over the long-term. Our community made three suggestions to assist the ARC in this work.

First, an ERA-like assessment could adopt more sophisticated network modelling to reveal patterns of research strengths across disciplines and across Australia. Rather than (somewhat overlapping) audits of quantum within universities, which can encourage competition and process ‘gaming’, a more nationally focused capability audit could report on the scale, depth, and strength of research expertise, quantum, and success across institutions, within and across disciplines. This would help the sector to identify the best opportunities for partnership and investment, whether for problems, topics or geographic areas, thus informing Australia’s research strategy.

Second, the administrative and workload burden of an ERA-like exercise could be minimised by evaluating specific research areas in different years. This kind of evaluation would enable universities to plan and manage submissions of a more controlled size and in a more targeted way. However, this would be challenged by the interdisciplinary nature of much research.

Third, an ERA-like exercise could streamline and automate collection and evaluation processes using data already available from university research management systems (such as PURE, which Macquarie and many other universities use) as well as public databases to create a lighter touch approach. The ARC already is working on the latter approach although one key challenge is fairly measuring the quality and success of peer review disciplines.

Over time, flaws in the current methodology have led to increasingly divergent ERA ratings between HASS and STEM disciplines. We are concerned that any new, automated methodology reliant on public databases will continue to disadvantage HASS disciplines due to the discoverability of their publication sources and outputs. There is a genuine danger that much of this research would not be captured, and the already static rankings of HASS disciplines would decline. Instead, we recommend that the ARC explore data available within universities much like annual TCSI student reporting submissions in the learning and teaching domain.

We strongly recommend that the ARC consults closely with universities when designing the new ERA methodology, and that the ARC closely considers hybrid assessment approaches appropriate to different disciplines.

In terms of EI, Macquarie believes there is a strong need for identifying and celebrating best practice in research impact. This will reveal the ways in which universities support impactful research, build and mentor Australia’s research workforce, encourage opportunities for collaboration between researchers and other stakeholders, and help preserve and strengthen the social licence for research (see our response to Q5). An EI-like assessment, when performed well, should evaluate the nation’s capacity to contribute to new knowledge (see our response to Q5) as well as to improve the lives of everyday Australians. It should deliver valuable information on the ARC’s return on its research investment, especially over the longer term. It also should demonstrate best practice principles of research impact planning in program and project design. The impact of the assessments themselves should be an improved and more efficient research funding system with greater benefits for Australia.

The Office of the NSW Chief Scientist and Engineer follows a model worth investigating. They undertake economic impact assessments of their work in consultation with the university sector. These impact assessments are a non-competitive process and provide valuable information about the true cost of research including ARC and university administration overheads.

An important point to consider is that EI has been conducted only once in full. A broad-ranging, cross-institution consultation was not conducted post-evaluation to assess EI’s success in meeting its goals. There is scope for significant improvement, and we look forward to providing feedback to relevant consultations prior to the next EI or EI-like assessment.

Overall, Macquarie recommends that, if the ARC continues to conduct quality and impact assessments, this should be referenced in the ARC Act. The Act should also include a function for the ARC of developing new methods of research assessment and keeping up with best practice and global insights. This would provide more certainty about evaluation exercises, which is greatly needed in the sector, and will reduce the scope for continual review and change as has been the case over recent years.

Recommendation 12: That ERA-like assessments focus on identifying, in a non-competitive way, the prospective capabilities of the Australian research sector to assesses the scale, depth, and strength of research expertise, quantum, and success. Data should be sourced from university internal research management systems and external databases.

Recommendation 13: That EI-like assessments are undertaken in a collaborative way between the ARC and universities to evaluate and demonstrate the benefits and returns of research, and to showcase best practice principles of research impact planning in project design.

Recommendation 14: That the ARC Act reference quality and impact assessments, the function of developing new methods in research assessment, and keeping up with best practice and global insights.

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?

Macquarie acknowledges that the ARC holds considerable data and knowledge about the research ecosystem in Australia although we are not familiar with the full extent of it. We urge the ARC to share insights into their expertise and capabilities with universities and partner in using these skills to demonstrate the ongoing excellence and value of Australian research.

One of the most powerful ways that the ARC could inform potential collaborators and end-users, share best practice, and identify national gaps and opportunities is through showcasing, in near-real-time, our research outcomes and impacts. This should be in collaboration with universities in a non-competitive environment and be aimed at sharing the best good news stories from within and across disciplines to stakeholders such as government, industry, and the public (as discussed in our responses to Q5 and Q8). The Engineering and Physical Sciences Research Council in the UK offers a good example of this approach implemented well. Such an approach would do more to preserve and strengthen social licence, share best practice, and identify national gaps and opportunities than comparing universities against each other and applying a rating scale that most members of the public do not understand.

Recommendation 15: That the ARC shares an understanding of their expertise and capabilities in research evaluation with universities, and that the ARC and universities partner in demonstrating the ongoing excellence and value of Australian research.

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?

Macquarie strongly recommends a re-think of the entire research funding ecosystem in Australia, which may include the formation of a unified research agency that brings together the ARC, NHMRC, and other significant funding bodies. Such reform would need to be supported by the Federal Government and the university sector. The timing for such reform is perfect given parallel processes currently underway with the Australian Universities Accord and National Science and Research Priorities Refresh.

A unified research agency would have many advantages such as introducing the opportunity for increased agility, flexibility, and responsiveness in the research funding system and a significant decrease in administrative burden. A unified research agency would also foster greater capacity for interdisciplinary research. Importantly, it must support equity and diversity in the research sector.

Our colleagues in HASS did, however, caution that support for fundamental research in all disciplines including HASS should be safeguarded under a merged model and not decreased due to the introduction of competition with medical research. We recommend that the ARC examines the flexibility of international comparator agencies such as the ERC and UKRI, which fund research across the full breadth of disciplines.

Whether or not a full review of the Australian research funding ecosystem is undertaken, we also recommend a comprehensive review and reform of the NCGP. While we acknowledge that individual schemes are routinely reviewed by the ARC, and there is a finite pool of funding on which to draw, there are many examples where the function, structure, and operation of the NCGP disproportionately impacts various groups such as women and ECRs. Review and reform of the NCGP could address these gaps and issues of equity as well as build skills and capabilities across all disciplines and researchers at all stages of their career. We provide just four of many examples here:

1. The number of women who are successful in gaining fellowships is traditionally low. The ARC could consider how other countries approach this challenge. For example, one research funding agency requires no more than half of the candidates from a given organisation to be men, with the maximum number capped. This could lead to eligible organisations being more selective in the candidates they encourage to submit proposals and also would ensure that eligible women are more likely to be supported.

2. The continued dominance of Level Es in Discovery Projects means that less diversity of career stages is represented and there is reduced opportunity for EMCRs. Could a metric be developed to better assess research outputs relative to opportunity? The qualitative way that it is currently considered is perceived as relying solely on subjective decisions by grant assessors.

3. We acknowledge that the ARC tries to recognise disruption to careers through ill health or carer responsibilities, but this is still subject to individual reviewers assessing the ROPE section appropriately. Our research community is concerned about unconscious bias and about the gender balance of reviewers (in some disciplines) in the review process.

4. The standard timing of ARC Discovery Project applications discriminates against applicants and research administration staff with families and school children because many deadlines fall during or close to summer school holidays in all states in Australia.

We have included here some examples of how the current research funding environment disproportionately impacts various groups. We welcome the opportunity to share more details when appropriate.

Recommendation 16: That the ARC considers forming a unified research agency to support the full gamut of research and researchers in Australia.

Recommendation 17: That the ARC reviews the entire NCGP to address issues of equity and diversity in the research funding landscape of Australia, and that principles of equity and diversity are captured in the ARC Act.

Submission received

14 December 2022

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