University of Southern Queensland

Name (Individual/Organisation)

University of Southern Queensland

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.

Overall, the ARC Act should not be onerously prescriptive. There should be a level of flexibility in its scope to enable it to adapt and respond to the changing Australian research landscape.

Specifically, the ARC Act should:
• Maintain the scope of research funding to support fundamental and applied research funding.
• Clearly distinguish between the role of the National Health and Medical Research Council (NHMRC), Medical Research Future Fund, and the ARC.

It is suggested that guiding principles are developed to ensure the funding program best supports and promotes research excellence.

Discovery and Linkage research programs
Over the past 25 years, the funding for research from industry (Category 3) has remained largely static (with some ups and downs) as a proportion of overall university funding, while the funding in Category 1 has steadily declined as a proportion of overall funding. The only category to increase is Government funding. There could be a re-balance of funding between Discovery and Linkage (more to Linkage) to incentivise industry engagement with universities and to increase industry investment in research. To be most effective this would probably require an overall increase in Category 1 funding.

The role of the ARC in actively shaping the research landscape in Australia
Universities play a critical role in the development of researchers, and they invest heavily in research, including significant research infrastructure, to achieve high quality outcomes. The ARC (and other research funding agencies) also has an important role in supporting research excellence in Australia.
The ARC should support, develop, and improve research excellence and maintaining this role of the ARC is critical.

The ARC’s research funding programs should deliver researchers the best quality feedback possible (within available resources). Researchers benefit from the experience of peer review and independent assessment to develop and inform their project methodological design, and articulate and demonstrate benefit and outcomes.

To date, the ARC has taken a more ‘transactional’ approach. How could we move the ARC to be more enabling?

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.

Overall, there needs to be transparency, visibility, and accountability in terms of the ARC governance model. If a Board is the most suitable mechanism, it would need to:
• Have a clear scope and mandate.
• Be an enabling body with appropriate size and membership that is representative of key stakeholders.
• Have defined and transparent timeframes.
• Add real value.

The Board should not create another level of bureaucracy that delays decisions. The proposed membership is problematic as it is not representative of all research organisations. However, we are mindful that the Board cannot be too large (it needs to be a reasonable size to ensure its agility) but it also needs to balance this against the requirement for adequate representation of all universities, including regionals.

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 is recommended that guiding principles are developed that reflect the ARC Act, rather than overly prescriptive functions.

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.

No, we don’t believe this needs to be a separate component in the Act. It’s part of the broader picture in regards to enabling research excellence and how it is measured. Including it would be too prescriptive for legislation.

The importance of peer review should be captured in the overarching guiding principles around supporting and enabling high quality research excellence across all disciplines.

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 ARC should focus on providing simple and clear evidence that speaks to the quality and benefit of research being conducted in Australia. The Chief Executive Officer (CEO) should have a demonstrated track record in effectively lobbying for the best interests of the research sector. Ideally, the CEO should be an eminent researcher and effective research manager and leader who can articulate the benefits of research through personal experience.

Through the National Interest Test (NIT) and the National Benefit selection criteria in funding scheme application requirements, the ARC has sought for benefit to be articulated by researchers. The national interest and national benefit criteria are ways for researchers to demonstrate benefit to assessors, the ARC and the Minister. The responses to the criteria do not increase public understanding of, and support for, research.

The Excellence in Research for Australia (ERA) National reports and Research Outputs (available via the ARC data portal) are not easily understood by the public and industry, and they lack the critical analysis that would benefit universities to improve their future research performance. Outcomes are also not easily understood and have no value outside an academic setting – i.e., they influence university decision making and are used in grant applications to speak to the quality of research in a discipline at the administering and participating organisations. The ARC’s proposal to modify future rounds of ERA (released in 2022) would make the outcomes of ERA even more inaccessible and irrelevant to the public and to industry. The strength of the sector is more important than being able to identify the best in a narrow discipline.

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

Overall, we believe the review of the Linkage program is heading in a positive direction.

Grant guidelines and instructions to applicants do adequately support researchers and universities to complete grant applications but it is queried whether the current format suits the purpose of the grant schemes. For example:

• Research Opportunity and Performance Evidence (ROPE) Statements are repetitive and onerous, particularly for international Partner Investigators (PIs). The Project Description sections request investigators detail the quality of the team and then the ROPE section again asks these questions. Investigators end up repeating themselves and assessors end up reading the same information twice. This is a waste of valuable time.
• The Publications section is unnecessarily long and time-consuming. The ARC has made some improvements in the integration of publications into the Research Management System, but the system is cumbersome and needs to be easier to use. Many assessors already skim over the long publications list (noting focus should be on quality not quantity) and focus on the top publications list. In some respects, the publications sections would be just as effective (even more so) if it just focused on the top 10 publications (in the researchers’ career) and the top 10 publications in the last five years. With more room for researchers to talk about why those outputs are significant and relevant to the project they are proposing.

There is currently limited guidance around alignment with Government Policy - further support here would be welcome.

The foreign interference disclosures are confusing for international PIs in the way in which they are phrased. They should be rephrased so that the required responses are provided to the ARC.

The NIT (particularly the new requirement for Deputy Vice-Chancellor approval of all NITs) is an additional workload for universities. While it is an improvement from the previous process (with the ARC CEO reviewing and requesting multiple revisions), the change has only served to transfer the ARC process to the institution. For grant schemes, this has further added to the administrative burden. The concept of establishing user end groups internally at each university to assess NITs prior to submission is a further unnecessary workload.

It is recommended that the benchmarking currently being undertaken by the ARC Independent Review Panel in regard to international exemplars should be shared with the sector and comment invited. Other countries seem to be more sophisticated in their administration of research funding and there are many researchers and research managers in our sector who could offer their perspectives and contribute to transformation (and cost efficiencies) in the ARC grant process/es.

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.

Process improvements are operational, and we suggest that this should not sit within the purview of the legislation, which is focused on governance. Rather the legislation should reflect guiding principles, one of which may include the need for the ARC’s function to be agile and responsive.

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?

Universities submit to many research assessments each year:
• Quacquarelli Symonds (QS).
• Times Higher Education (THE).
• Clarivate Analytics Institutional Profiles (which inform rankings that use Web of Science as the provider – such as Shanghai Rankings).

The results of these research assessments are published online and widely communicated globally. They are easily understood globally and reported on much more extensively than ERA and Engagement and Impact.

They use publications data available via citation providers and have many metrics to try and measure other components of research and teaching quality. Although it is acknowledged that these league tables share the same issue with ERA – how to adequately cover the Humanities, Arts and Social Sciences disciplines to provide an accurate representation of the quality in a discipline. ERA tried to achieve this with peer review, but the last few rounds of ERA have demonstrated that this method is subjective and does not accurately provide an assessment of a discipline’s quality of research.

We believe the need for ERA to review retrospective performance is no longer needed. It has served its purpose and other assessments serve the purpose of evaluating, ranking and promoting research excellence.

In terms of reportable information to the Australian Government, universities provide data on staffing and income to the Australian Government and report on expenditure on research and development every second year to the Australian Bureau of Statistics in an involved and substantial submission. There are also expectations around reporting to TEQSA on research as part of the process of accreditation as a university.

If there are ways to include additional fields in these existing collections that ensured key metrics were captured, this should be explored through consultations on those relevant guidelines.

The ARC Act should focus on the high level function of supporting the creation of an internationally competitive and quality research system. References to specific measures of quality and impact should not be included in the Act.

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?

Expertise developed in the ARC could be deployed or shared with TEQSA to ensure that they can successfully implement requirements that were outlined in the Quality of Research Determination 2021:
https://www.legislation.gov.au/Details/F2021L00989.

This could include development of guidance for universities on how to present research quality and a role in the individual evaluation process to provide recommendations to TEQSA.

Submission received

14 December 2022

Publishing statement

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