Alison Downham Moore

Name (Individual/Organisation)

Alison Downham Moore

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.

a) There should no change to the scope of funding supported.

b) The ARC Act should specify the balance of Discovery and Linkage programs to protect basic research from the whims of changing ideological commitments of different governments. Basic research is the foundation on which all other research relies and is the kind of research that specifically requires state funding the most because it is less immediately translatable to industry.

c) The ARC has attempted to shape the research landscape significantly since 2010. The purpose of the ARC should focus solely on research grants and not on research quality assessment of institutions such as the ERA. There is currently too much overlap in the personnel involved in the assessment of grants and evaluating institutions, producing a strata of academics with far too much power over the fate of all the others. Numerous successful researchers working at international standards of excellence are shut out of ARC funding and are also located in institutions where their disciplines are defunded following ERA under 4 or 5. This both reduces the openness needed for the highest quality innovation and creates a proto-caste system that is only partially merit-based.

d) Evaluation of research quality in institutions needs to work similarly to the model of the evaluation of curriculum, teaching and learning used by TEQSA in which minimum standards must be met, with specific, measurable and transparent developmental guidance for improvement provided. The ERA has historically provided only crude ratings of institutions' research fields, in a largely non-transparent and insufficiently criteria-based system that measures only time-lagging downstream indicators. The ERA has also not taken sufficient account of its own impact on institutional investment and on academic and professional staff within institutions.

Q2. Do you consider the current ARC governance model is adequate for the ARC to perform its functions?

If not, how could governance of the ARC be improved? For example, should the ARC Act be amended to incorporate a new governance model that establishes a Board on the model outlined in the consultation paper, or another model.

Please expand on your reasoning and/or provide alternative suggestions to enhance the governance, if you consider this to be important.

The ARC Board structure outlined in the consultation paper would be a significant improvement on the current governance structure.

The ARC Act should be amended to require this new governance structure.
The proposed stipulation of a Chair as someone “who is a prominent member of the Australian community held in high regard by the research community” is insufficiently imprecise. The law might be more precisely formulated to require a Chair whose expertise as a research leader is evidenced by their career trajectory in a relevant research and research management domain. The chair should be a very specific kind of individual with substantial research management expertise and previous experience, not merely someone from a general business management background. The board members too should be individuals with specific expertise in research and research management.

The Board should make recommendations for the appointment of the CEO and this individual too should be a manager experienced in the research sector specifically.

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?

n 34 (2) which states that “The Minister must not appoint a person as CEO unless the Minister has considered the person’s record in research and management”, should be strengthened to ensure that only individuals with a substantial record of research and research management may be appointed as CEO.

Appropriate expertise does not currently appear to be available among the expert reviewers of grants, with reference to individuals with experience of interdisciplinary collaborative research in the humanities. Interdisciplinarity is widely valued for its potential to produce innovation and researchers are asked to designate in the application if their project is interdisciplinary and in what sense. It is also widely recognised that interdisciplinary humanities collaborations constitute another variety of scholarship altogether and represent more the sum of their parts. Nonetheless, the practice of the Council appears to be to assign discipline specialist peer-assessors from each of the disciplines contained within interdisciplinary projects, regardless of whether these assessors have expertise in interdisciplinary collaboration per se. The risk with single-discipline-based reviewers is that they will automatically doubt the feasibility of all interdisciplinary projects and score them lower, reflecting their own unconscious biases toward single-discipline projects. This variety of peer-assessment is widely reported in anecdotal reports of researchers proposing projects of this kind. This situation is unlikely to change without a deliberate intervention. Single discipline scholars with no experience of collaborating in interdisciplinary teams should not be assessing interdisciplinary collaborative projects at all.

The act should be prescriptive in assuring an adequately qualified CEO and Chair. The Council of Experts should include members in each of the Discipline sectors (BSB, EIC, HCA etc…) who have substantial interdisciplinary collaborative experience.

Q4. Should the ARC Act be amended to consolidate the pre-eminence or importance of peer review?

Please provide any specific suggestions you may have for amendment of the Act, and/or for non-legislative measures.

The current privilege of the Education Minister to censor grants that have been recommended for funding following a nine-months-long and rigorous expert peer-review process is grossly out of step with international benchmarks of independent research councils in the UK, EU, US and many other countries. No rationale has been presented for why Australia should permit this unusual form of potential political inference in any form. The Ministerial veto should be eliminated altogether.

Because Australia’s aberrant permissiveness in enabling political interference in research funding decisions is now well known globally, there is a very real danger that it may already be acting as a deterrent to talented researchers and scientists to move to Australia, or collaborate with Australian researchers, or for higher degree international candidates to enroll in Australian university programs, due to the perception that our higher education system lacks the common global standard of open academic inquiry, protected from political interference, that is cherished in all other democratic countries.

Interference with independent expertise determinations of research spending are, on the other hand, very much in tune with procedures in several current non-democratic regimes that have emerged in recent years. Changes to Hungarian law in 2011 and 2013 removed protections on the autonomy of higher education, such that in 2018, under Viktor Orbán, the Minister of Innovation and Technology, László Palkovics, without consulting research leaders and top scientists, removed the funding normally provided to the 15 independent research institutions and 130 research groups via the Hungarian Academy of Sciences, diverting it to a novel Ministry-overseen call for proposals lacking any kind of proper process of evaluation and selection (Abbott 2019). It also banned the teaching of gender studies in public universities (Abbott 2018). A new Lendülat grant scheme offered by the Ministry supports only conservative historical research projects that reflect the ideological values of Orbán’s regime (Nolan, 2018), and the Veritas Institute funded by the Ministry generates right-wing ‘correctives’ to the work of respected independent historians (Körtvélyesi, 2020).

As specialist researchers in the field of academic censorship observe, direct forms of censorship such as banning of publications or targeted dismissal of academic staff are not the most common form of censure documented in non-democratic states, whereas ‘refusal of funding’ constitutes one of the more common ways regimes seek to discourage research that is inconvenient to them politically (Väliverronnen & Saikkonen 2020). Similarly to Hungary under Orban, the US under the former President Donald Trump, whose disrespect of democratic principles and administrative due process is well known, a 2016 House of Representatives spending bill amendment was passed which categorically denied funding to scholarship in political science, and awarded it only to those projects which the President viewed as being ‘in the national interest’ (Pells 2019).

The Australian Research Council has established and fit-for-purpose governance structures that should be trusted to perform the duties assigned to them, according to the common global norm of independent research councils. The European Commission recognises trust as one of three ‘key underpinning elements’ of a robust research funding system through the autonomy of research and scientific councils, referring to the state’s ‘confidence in the ability, integrity, and reliability of another party - where that party has demonstrated its capacity to be trusted - and entails acceptance of that party’s ability to operate without undue investigation or control’ (European Commission 2010, p.2). Similarly, the British Haldane principle refers the importance of decisions about research funding being determined only be experts and not by unqualified political figures, and the view that ‘researchers are best placed to determine detailed priorities; that the Government's role is to set the over-arching strategy; and that the research councils are guardians of the independence of science' (UK Parliament 2009).

The view that some additional measure of public or national interest is required to be exercised by the Minister of Education is false and without foundation. The National Competitive Grants Program (NCGP) is defined by national science and research priorities and grant applications are already judged by experts in part through the measure of the degree to which they meet those priorities. This is the functional system through which publicly-funded research is already shaped by government priorities.

References:

Abbott, Alison (2019), ‘Hungary’s Scientists Outraged by Government Budget Grab’, Nature, News, February 15th.

Abbott, Alison (2018), ‘Hungary’s Government Throws Science Academy into Turmoil’, Nature, News, December 17th.

European Commission (2010), EURAXESS - Researchers in Motion, ‘Common Principles Governing External Funding of Research, Executive Summary’. https://cdn1.euraxess.org/sites/default/files/policy_library/common_principles_14_october_2010.pdf

Körtvélyesi, Zsolt, ‘Fear and (Self)-Censorship in Academia,’ Verfassungsblog: On Matters Constitutional, sept. 16th. https://verfassungsblog.de/fear-and-self-censorship-in-academia/.

Nolan, Dan (2018), ‘Hungary’s Unscientific Swivel: First They Came for the Humanities and now Hungary’s Government is After the Sciences,’ Index on Censorship 47, issue 3. Doi: 10.1177/0306422018800258

Pells, Rachael (2019), ‘Is the Haldane Principle Obsolete?’ Times Higher Education, June 13th. https://www.timeshighereducation.com/features/haldane-principle-obsolete

UK Parliament (2009), Publications & Records, ‘Putting Science and Engineering at the Heart of Government Policy - Innovation, Universities, Science and Skills Committee, Annex 1: Extract from John Denham’s Speech to the Royal Academy of Engineering, London, April 29th 2008. https://publications.parliament.uk/pa/cm200809/cmselect/cmdius/168/168we03.htm

Väliverronnen, Esa & Sampsa Saikkonen (2021), ‘Freedom of Expression Challenged: Scientist’ Perpsectives on Hidden Forms of Censorship and Self-Censorship,’ Science, Technology & Human Values 46, issue 6: 1172–1200. Doi: 10.1177/0162243920978303

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

There is already a benefit section built in the assessment criteria of all ARC grants, even in the Discovery scheme which focuses on basic research. An additional national interest statement may help to preserve the social licence for publicly funded research by providing a plan language explanation of what the public is paying for and why. However, an NIT can be assessed during the expert review and during Council of Expert rankings, without need for additional cost in subjecting these to a separate vetting exercise. Under no circumstances should the Minister intervene on the basis of NITs to deny funding to applications that have recommended for funding by the Council of Experts. There is no research council in the democratic world that permits this sort of potential political abuse. Discipline experts are also appropriately qualified to judge when a research field may be unfairly jeopardised by low estimation of the NIT (eg. by focusing on the culture or society of another country) but should be made explicitly aware of this risk. International research is crucial for the global reach and academic influence of Australian scholars and should not be disadvantaged relative to Australian-focused projects, as is currently the tendency in HCA.

The ARC should also publish lists of grants that have not been funded. The public has a right to know what research has not been supported or encouraged by the state, not only what has been funded.

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

The most obvious cost saving reform of the ARC that would remove an enormous administrative burden would be to separate those disciplines that typically require only small amounts of funding to facilitate research from those that require vast amounts. Numerous humanities, social science, education, and creative practice disciplines should be permitted to apply for a separate small grants scheme, requiring a shorter application, which is simply vetted by Discipline experts on basic criteria with reference to the project being in their area of the researcher’s substantial expertise, it being a substantially new project, it having a well justified budget, and it having a clearly defined benefit. This is widespread practice in the European and Canadian systems.

The cost-saving of this change would permit the ARC to fund a much larger pool of researchers, reducing the current enormous waste of time of thousands of perfectly excellent researchers who are every year applying for large grants they do not necessarily need, and receiving nothing. The smaller amounts of funding requested and lower threshold for funding success would permit a reduced wastage of applicant labour and assessor labour.

Repeated unsuccessful applications come at the cost of researchers' actual productivity, reducing productivity across the sector as a whole. Currently, this wasted labour and reduced productivity is not factored into the cost-calculations of grant assessment processes, but it should be, since university researchers are already partly funded by the state via Federal block funding to the university that employs them.

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.

If the ARC wishes to see more interdisciplinary collaborative research occurring, it will need to restore Research Networks funding scheme or something similar, while assuring sufficient expertise in evaluating such projects among the Council of Experts and among the expert reviewer pool.

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 do not need to be ranked against one another in a separate, expensive, retrospective impact or quality assessment exercise that is not tied to funding but with reinforces both competition (over cooperation) and elitism (over equity). Research and research impact evaluations do need to be accountable, but this might be assured other ways.

Peer-review in the ERA in HASS disciplines has resulted in perverse internal effects such as cuts to many disciplines, denial of promotion to scholars in small fields, and has sometimes reflected competitive biases among peer-reviewers. Critical mass in disciplinary fields is a major correlate of high ERA ratings but current ERA assessment practices do not appear to take adequate account of discipline size..

Bibliometrics remain a poor proxy for quality and are particularly inappropriate for judging either the quality or impact of humanities research on account of Scopus and Web of Science grossly under-detecting humanities publications and citations.

TEQSA already conducts evaluations of HE institutions and could be expanded to assess research quality and impact as well, triangulating diverse metrics, including altmetrics and libmetrics, evidence of public engagement activities and international collaboration, and considering both lead and lag measures of research impact. This could be easily funded from the cost saving of eliminating the ERA and EI altogether, leaving the ARC purely to assess grant applications and therefore better able to manage timely procedures (as occurred in 2022 once the ERA was suspended).

Other quality criteria should include evaluation of universities' research management practices and the extent of investment in each of the discipline FORs being assessed. Managers are currently unaccountable for austerity practices, while nonetheless expecting ever higher targets of publication output, quality, impact and grant success from their staff.

The bifurcation of external quality assurance in Australian higher education along the research vs. teaching divide has only entrenched the existing cultural separation between a largely teaching-focused workforce (majority women) who are mostly denied promotion and held at the lower paid salary levels and a research elite (majority men) who enjoy repeated ACR grants. The holistic scholar who is a both an excellent researcher and teacher in equal measure is nowhere acknowledged in their crucial value to the enterprise of higher education. The role of TEQSA in evaluating the holistic provision of universities (teaching, research and the management of both) should be restored and properly resourced.

Evaluations of research quality and impact both need to be developmental in approach, addressing what an institution can do to improve, with specific, transparent, constructive, measurable and feasible recommended actions. Developmental schemes could then by tied to modest Federal funding bonuses to enable further improvements and encourage sustainable internal investment by institutions in their perceived areas of need, as well as areas of existing strength which they may wish to grow.

Submission received

13 December 2022

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