The Group of Eight

Name (Individual/Organisation)

The Group of Eight

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.

Introduction
The Group of Eight (Go8), which represents Australia’s leading research-intensive universities welcomes the opportunity to provide this submission to the Review of the Australian Research Council (ARC) consultation paper issued by the Department of Education. Please note that this submission represents the views of the Go8 network, and member universities may choose to make their own submissions.
Please also note that we are happy for this submission to be published and have no wish for any of it to be treated as confidential.
The Go8 is highly supportive of the work of the ARC as the major funder of non-health and medical university research in Australia and, in particular, basic research in these domains.
As you will be aware, the Go8 members undertake 70 per cent of Australia’s university-based research and collectively invest over $7.2 billion in research each year. The Go8 is the major stakeholder in ARC funded research having overall received 67 per cent of ARC National Competitive Grant Program (NCGP) funding commencing since 2002 and 69 per cent of funding for projects scheduled to commence in 2023 .
In framing this submission, the Go8 notes that this is one of a series of interconnected reviews operating in parallel.
This includes the Australian Universities Accord process, the ERA Transition Working Group, and the review of the ARC NCGP being conducted by ACIL-Allen.
In particular, the Go8 wishes to make clear that this submission responds to the ARC as situated in the current policy, legislative, regulatory and funding environment. While it may inform discussions during the Universities Accord process, this submission should not be interpreted as containing recommendations in the broader context of generational reform of the entire university research system that will be considered during the Australian Universities Accord process.
The exception to this is the consideration of research assessment.
While the participation of the Go8 in the ERA Transition Working Group is in the context of the expectations of the Group to provide an option for a transition from ERA to establish a modern data driven approach informed by expert review, this submission recommends that ERA be discontinued in its current form and a broader discussion on research assessment and research capability mapping be part of the Universities Accord.
Recommendations
The Go8 makes the following recommendations in response to the ARC Review consultation paper.
Recommendation 1: The governance of the ARC be strengthened by amending the ARC Act to
• Establish an ARC Board appointed by the Minister which includes an independent Chair and representation by senior academic, industry and public representatives to provide advice to the ARC CEO.
• Require that designated committees established by the Minister provide advice directly to the Board.
• Strengthen the role of the CEO by bringing the ARC Act into alignment with the NHMRC Act in terms of provisions relating to appointment, performance and termination of the CEO.
Recommendation 2: That ARC support for basic research be explicitly codified in the ARC Act by amending the ARC Act to
• Include an object of the Act to provide for the funding of research programs that support pure basic research, strategic basic research and applied research including through international collaboration.
• Explicitly legislate the balance of funding between basic research and applied research to provide an explicit commitment to basic research (in Part 7 of the current Act).
Recommendation 3: That the ARC Act be amended to adopt the international best practice Haldane Principle to ensure the allocation of public funding for individual research proposals are best taken following evaluation by an independent council of experts and not directly by a Government Department or Minister.
If the Haldane principle is not adopted, then the Go8 recommends that:
• The ARC Act be amended to require the Minister to table, in Parliament, within 15 days, the reasons, evidence and advice received for each instance when discretion is exercised veto an ARC recommended grant.
• The changes to the National Interest Test (NIT) for ARC applications announced on 30 November 2022 remain the basis of NIT assessments moving forward in order to ensure a fair and efficient process that protects the national interest and support basic research.
Recommendation 4: That Excellence in Research for Australia (ERA) be discontinued in its current form.
Recommendation 5: That the ARC increase the number and breadth of expertise in Executive Director positions and consider employment arrangements that will increase the pool of possible senior candidates for such positions.

Discussion
The ARC funds research through a series of programs to support research activity across the spectrum of basic research, applied research and including research in collaboration with industry partners.
According to the ARC NCGP database , in 2021 there were 1,126 commencing projects funded to the total value of $673 million. The primary research field for these projects included all 22 two-digit Fields of Research and across 115 of the 157 more detailed four-digit Fields of Research . Of those 42 detailed Fields of Research not with commencing funding in 2021, 27 had received funding in the five years prior to 2021.
In short, this reflects not only the responsibility of the ARC in fostering Australia’s non-health and medical research capacity and capability but also the complexity – both operationally and conceptually - of doing so across so many distinct fields of research. This complexity will only increase in the future with the implementation of a new classification of Fields of Research by the ABS and the requirement of the Australian research effort to be strategically aligned with Government initiatives such as the National Reconstruction Fund.
Given this complexity, the ARC currently does not have the formal governance and advice structures properly to support the CEO. This was particularly evident throughout the height of the COVID pandemic.
The Go8 acknowledges that on 31 March 2022 the Minister for Education established the ARC Advisory Committee as a designated committee under the ARC Act with an independent Chair – a significant improvement over the previous non-designated status of the former ARC Advisory Council.
However, there is a need for the peak governance group of the ARC to be both independent and have its existence ensured and codified by the ARC Act, rather than at the discretion of the Minister. This follows the best practice of other Australian Government research funds and funding agencies such as the Medical Research Future Fund (MRFF) with advice provided by the Australian Medical Research Advisory Board (AMRAB) and the National Health and Medical Research Council (NHMRC) which has a governing council.
Similarly, provisions in the ARC Act relating to the appointment, performance and termination of the CEO should be updated to strengthen the role of the CEO and align with best practice in Australian research funding agencies such as the NHMRC.
In order to support the work of the ARC peak governance body, the ARC Act should continue to include the capacity for the Minister to create designated committees reporting directly to the body, which is also in alignment with the arrangements for the NHMRC.
Recommendation 1: The governance of the ARC be strengthened by amending the ARC Act to
• Establish an ARC Board appointed by the Minister which includes an independent Chair and representation by senior academic, industry and public representatives to provide advice to the ARC CEO.
• Require that designated committees established by the Minister provide advice directly to the Board.
• Strengthen the role of the CEO by bringing the ARC Act into alignment with the NHMRC Act in terms of provisions relating to appointment, performance and termination of the CEO.


Basic research that adds to the stock of knowledge (and does not necessarily immediately lead to tangible products or services) is critical because it can deliver the pipeline of ideas, technologies and processes that can be built upon in the future. Basic research is often also a necessary precursor to applied research and/or commercialisation.
At a time that the OECD suggests “We need to keep pushing out the global innovation frontier. This requires significantly more public investment in basic research to support the continued emergence of breakthrough innovations”, Australia’s research effort is largely moving away from all-important basic research.
Higher Education expenditure on basic research has been in relative decline in Australia for the last three decades dropping from 63.6 per cent of total Higher Education expenditure on R&D (HERD) in 1992 to 37.1 per cent in 2020.
As noted already, the ARC funds research through a series of programs to support research activity across the spectrum of basic research, applied research and including research in collaboration with industry partners.
However, the core role of the ARC in Australia’s research system is as the largest Government funder of basic non-health and medical research which comprises both pure basic and strategic basic research. Over the last decade real funding by the ARC has declined with an estimated cumulative shortfall of $1.25 billion against 2012-13 funding levels, putting further pressure on the ability of universities to undertake basic research.
Given the critical nature of basic research the Go8 recommends that the ARC Act explicitly articulate the role of the ARC in supporting basic research.
Recommendation 2: That ARC support for basic research be explicitly codified in the ARC Act by amending the ARC Act to
• Include an object of the Act to provide for the funding of research programs that support pure basic research, strategic basic research and applied research including through international collaboration.
• Explicitly legislate the balance of funding between basic research and applied research to provide an explicit commitment to basic research (in Part 7 of the current Act).
It is the responsibility of the Minister to ensure that funding allocations within the portfolio meet rigorous and appropriate standards and deliver value for money for the Australian taxpayer. A lack of substantive information regarding the reasons for the rejection of ARC CEO recommended projects over the past 20 years has created a perception of the potential for bias or political interference.
While there has been no report or suggestion of Ministerial rejection of recommended projects in ARC grant round announcements in 2022, the Go8 recommends that this be guaranteed by adopting the Haldane Principle in the ARC Act and, failing that, to ensure greater legislated transparency in how the Minister reports on what is the exercise of an effective veto power.
Recommendation 3: That the ARC Act be amended to adopt the international best practice Haldane Principle to ensure the allocation of public funding for individual research proposals are best taken following evaluation by an independent council of experts and not directly by a Government Department or Minister.
If the Haldane principle is not adopted, then the Go8 recommends that:
• The ARC Act be amended to require the Minister to table, in Parliament, within 15 days, the reasons, evidence and advice received for each instance when discretion is exercised veto an ARC recommended grant.
• The changes to the National Interest Test (NIT) for ARC applications announced on 30 November 2022 remain the basis of NIT assessments moving forward in order to ensure a fair and efficient process that protects the national interest and support basic research.

Excellence in Research for Australia (ERA) – which provides a comprehensive assessment of the excellence of Australian university by Field of Research (FoR) – has been a valuable tool for the for the Australian research sector. Its introduction in 2010 required universities to modernise and systematise research management systems to track all research outputs by staff members and to report this research activity as a coherent portfolio by Field of Research.
It has also led to a robust assurance of the quality of the research produced by Australian universities for both the Australian Government and the Australian public more broadly. In doing so, it also confirmed that research funding distributed by the ARC was supporting excellent research. In the latest round of ERA (2018) over 99 per cent of all ratings for Go8 members were at world class (standard) or above.
However, there have also been shortcomings to ERA and its use. By design, it provides a rating of excellence without reporting the volume of research being undertaken at that excellence rating. Consequently, ERA does not report publicly on the critical mass of excellent research and distribution throughout Australia by institution.
Despite the wealth of data available from four iterations of ERA comprehensively assessing Australia’s university research - and this often being cited as a strength of ERA – there is little publicly available analysis known to the Go8 that uses ERA data to provide a strategic research capability mapping for the nation and to underpin strategic decision making by Government. Indeed, ERA results have not even been used to direct Government funding for research since the reform to the Research Block Grants (RBG) following the 2015 Watt Review of Research Policy and Funding Arrangements saw the Sustainable Research Excellence RBG ended after its 2016 allocations.
At the same time, ERA has seen diminishing returns for universities as strategic and robust research management – facilitated in many cases by the introduction of ERA – have largely been implemented across the sector. This, however, does not reduce the significant resource implications for a university preparing a submission for ERA. In its submission to the 2019 ARC Review of Excellence in Research for Australia (ERA) and Engagement and Impact (EI) measures, the Go8 submission noted that the cost of preparing an ERA submission at one Go8 member was estimated to be $1 million – a significant cost.

While streamlining ERA processes and reporting requirements potentially reduces the cost for universities to conduct ERA, it does not necessarily increase the value of the exercise. Nor does it provide the type of detailed and strategic research capability mapping (including research infrastructure) that Australia needs to underpin increasing sovereign capability in areas such as quantum, AI or in critical technology areas that will underpin the National Reconstruction Fund and strategic international partnerships such as the AUKUS alliance.

For these reasons, the Go8 welcomed the announcement of the Minister to discontinue preparations for ERA 2023.
Notwithstanding the Go8 participation in the ERA Transition Working Group to provide an option for a transition to a streamlined ERA, the Go8 recommends discontinuing ERA in its current form.
The questions of the design of a fit-for-purpose national research capability mapping and how that should intersect with a quality assessment of university research sit more properly with the upcoming Universities Accord process.
Recommendation 4: That Excellence in Research for Australia (ERA) be discontinued in its current form.
As noted in the discussion before Recommendation 1, given the complexity of the research sector the ARC CEO requires extensive support in their role. This is not the only the case for the formal governance arrangements for the ARC but also for the expert academic advice within the ARC staff cohort. This is currently obtained by employing Executive Directors who are senior and well-credentialled academics.
While the current incumbents of these positions in the ARC are of high-standing there is a need for a greater variety of expertise to account for emerging research fields, multidisciplinary research and fields of increasing important such as IT and computing.
The Go8 recommends an increased number of Executive Director positions and also that the ARC ensures flexible work options to facilitate part-time and remote working arrangements. In addition, remuneration should be competitive with a Professorial position. Taken together these measures could widen the potential pool of candidates for Executive Director positions – in particular the option of maintaining an academic career while concurrently with the duties of an Executive Director.
Recommendation 5: That the ARC increase the number and breadth of expertise in Executive Director positions and consider employment arrangements that will increase the pool of possible senior candidates for such positions.

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?

Recommendations
The Go8 makes the following recommendations in response to the ARC Review consultation paper.
Recommendation 1: The governance of the ARC be strengthened by amending the ARC Act to
• Establish an ARC Board appointed by the Minister which includes an independent Chair and representation by senior academic, industry and public representatives to provide advice to the ARC CEO.
• Require that designated committees established by the Minister provide advice directly to the Board.
• Strengthen the role of the CEO by bringing the ARC Act into alignment with the NHMRC Act in terms of provisions relating to appointment, performance and termination of the CEO.
Recommendation 2: That ARC support for basic research be explicitly codified in the ARC Act by amending the ARC Act to
• Include an object of the Act to provide for the funding of research programs that support pure basic research, strategic basic research and applied research including through international collaboration.
• Explicitly legislate the balance of funding between basic research and applied research to provide an explicit commitment to basic research (in Part 7 of the current Act).
Recommendation 3: That the ARC Act be amended to adopt the international best practice Haldane Principle to ensure the allocation of public funding for individual research proposals are best taken following evaluation by an independent council of experts and not directly by a Government Department or Minister.
If the Haldane principle is not adopted, then the Go8 recommends that:
• The ARC Act be amended to require the Minister to table, in Parliament, within 15 days, the reasons, evidence and advice received for each instance when discretion is exercised veto an ARC recommended grant.
• The changes to the National Interest Test (NIT) for ARC applications announced on 30 November 2022 remain the basis of NIT assessments moving forward in order to ensure a fair and efficient process that protects the national interest and support basic research.
Recommendation 4: That Excellence in Research for Australia (ERA) be discontinued in its current form.
Recommendation 5: That the ARC increase the number and breadth of expertise in Executive Director positions and consider employment arrangements that will increase the pool of possible senior candidates for such positions.

Discussion
The ARC funds research through a series of programs to support research activity across the spectrum of basic research, applied research and including research in collaboration with industry partners.
According to the ARC NCGP database , in 2021 there were 1,126 commencing projects funded to the total value of $673 million. The primary research field for these projects included all 22 two-digit Fields of Research and across 115 of the 157 more detailed four-digit Fields of Research . Of those 42 detailed Fields of Research not with commencing funding in 2021, 27 had received funding in the five years prior to 2021.
In short, this reflects not only the responsibility of the ARC in fostering Australia’s non-health and medical research capacity and capability but also the complexity – both operationally and conceptually - of doing so across so many distinct fields of research. This complexity will only increase in the future with the implementation of a new classification of Fields of Research by the ABS and the requirement of the Australian research effort to be strategically aligned with Government initiatives such as the National Reconstruction Fund.
Given this complexity, the ARC currently does not have the formal governance and advice structures properly to support the CEO. This was particularly evident throughout the height of the COVID pandemic.
The Go8 acknowledges that on 31 March 2022 the Minister for Education established the ARC Advisory Committee as a designated committee under the ARC Act with an independent Chair – a significant improvement over the previous non-designated status of the former ARC Advisory Council.
However, there is a need for the peak governance group of the ARC to be both independent and have its existence ensured and codified by the ARC Act, rather than at the discretion of the Minister. This follows the best practice of other Australian Government research funds and funding agencies such as the Medical Research Future Fund (MRFF) with advice provided by the Australian Medical Research Advisory Board (AMRAB) and the National Health and Medical Research Council (NHMRC) which has a governing council.
Similarly, provisions in the ARC Act relating to the appointment, performance and termination of the CEO should be updated to strengthen the role of the CEO and align with best practice in Australian research funding agencies such as the NHMRC.
In order to support the work of the ARC peak governance body, the ARC Act should continue to include the capacity for the Minister to create designated committees reporting directly to the body, which is also in alignment with the arrangements for the NHMRC.
Recommendation 1: The governance of the ARC be strengthened by amending the ARC Act to
• Establish an ARC Board appointed by the Minister which includes an independent Chair and representation by senior academic, industry and public representatives to provide advice to the ARC CEO.
• Require that designated committees established by the Minister provide advice directly to the Board.
• Strengthen the role of the CEO by bringing the ARC Act into alignment with the NHMRC Act in terms of provisions relating to appointment, performance and termination of the CEO.


Basic research that adds to the stock of knowledge (and does not necessarily immediately lead to tangible products or services) is critical because it can deliver the pipeline of ideas, technologies and processes that can be built upon in the future. Basic research is often also a necessary precursor to applied research and/or commercialisation.
At a time that the OECD suggests “We need to keep pushing out the global innovation frontier. This requires significantly more public investment in basic research to support the continued emergence of breakthrough innovations”, Australia’s research effort is largely moving away from all-important basic research.
Higher Education expenditure on basic research has been in relative decline in Australia for the last three decades dropping from 63.6 per cent of total Higher Education expenditure on R&D (HERD) in 1992 to 37.1 per cent in 2020.
As noted already, the ARC funds research through a series of programs to support research activity across the spectrum of basic research, applied research and including research in collaboration with industry partners.
However, the core role of the ARC in Australia’s research system is as the largest Government funder of basic non-health and medical research which comprises both pure basic and strategic basic research. Over the last decade real funding by the ARC has declined with an estimated cumulative shortfall of $1.25 billion against 2012-13 funding levels, putting further pressure on the ability of universities to undertake basic research.
Given the critical nature of basic research the Go8 recommends that the ARC Act explicitly articulate the role of the ARC in supporting basic research.
Recommendation 2: That ARC support for basic research be explicitly codified in the ARC Act by amending the ARC Act to
• Include an object of the Act to provide for the funding of research programs that support pure basic research, strategic basic research and applied research including through international collaboration.
• Explicitly legislate the balance of funding between basic research and applied research to provide an explicit commitment to basic research (in Part 7 of the current Act).
It is the responsibility of the Minister to ensure that funding allocations within the portfolio meet rigorous and appropriate standards and deliver value for money for the Australian taxpayer. A lack of substantive information regarding the reasons for the rejection of ARC CEO recommended projects over the past 20 years has created a perception of the potential for bias or political interference.
While there has been no report or suggestion of Ministerial rejection of recommended projects in ARC grant round announcements in 2022, the Go8 recommends that this be guaranteed by adopting the Haldane Principle in the ARC Act and, failing that, to ensure greater legislated transparency in how the Minister reports on what is the exercise of an effective veto power.
Recommendation 3: That the ARC Act be amended to adopt the international best practice Haldane Principle to ensure the allocation of public funding for individual research proposals are best taken following evaluation by an independent council of experts and not directly by a Government Department or Minister.
If the Haldane principle is not adopted, then the Go8 recommends that:
• The ARC Act be amended to require the Minister to table, in Parliament, within 15 days, the reasons, evidence and advice received for each instance when discretion is exercised veto an ARC recommended grant.
• The changes to the National Interest Test (NIT) for ARC applications announced on 30 November 2022 remain the basis of NIT assessments moving forward in order to ensure a fair and efficient process that protects the national interest and support basic research.

Excellence in Research for Australia (ERA) – which provides a comprehensive assessment of the excellence of Australian university by Field of Research (FoR) – has been a valuable tool for the for the Australian research sector. Its introduction in 2010 required universities to modernise and systematise research management systems to track all research outputs by staff members and to report this research activity as a coherent portfolio by Field of Research.
It has also led to a robust assurance of the quality of the research produced by Australian universities for both the Australian Government and the Australian public more broadly. In doing so, it also confirmed that research funding distributed by the ARC was supporting excellent research. In the latest round of ERA (2018) over 99 per cent of all ratings for Go8 members were at world class (standard) or above.
However, there have also been shortcomings to ERA and its use. By design, it provides a rating of excellence without reporting the volume of research being undertaken at that excellence rating. Consequently, ERA does not report publicly on the critical mass of excellent research and distribution throughout Australia by institution.
Despite the wealth of data available from four iterations of ERA comprehensively assessing Australia’s university research - and this often being cited as a strength of ERA – there is little publicly available analysis known to the Go8 that uses ERA data to provide a strategic research capability mapping for the nation and to underpin strategic decision making by Government. Indeed, ERA results have not even been used to direct Government funding for research since the reform to the Research Block Grants (RBG) following the 2015 Watt Review of Research Policy and Funding Arrangements saw the Sustainable Research Excellence RBG ended after its 2016 allocations.
At the same time, ERA has seen diminishing returns for universities as strategic and robust research management – facilitated in many cases by the introduction of ERA – have largely been implemented across the sector. This, however, does not reduce the significant resource implications for a university preparing a submission for ERA. In its submission to the 2019 ARC Review of Excellence in Research for Australia (ERA) and Engagement and Impact (EI) measures, the Go8 submission noted that the cost of preparing an ERA submission at one Go8 member was estimated to be $1 million – a significant cost.

While streamlining ERA processes and reporting requirements potentially reduces the cost for universities to conduct ERA, it does not necessarily increase the value of the exercise. Nor does it provide the type of detailed and strategic research capability mapping (including research infrastructure) that Australia needs to underpin increasing sovereign capability in areas such as quantum, AI or in critical technology areas that will underpin the National Reconstruction Fund and strategic international partnerships such as the AUKUS alliance.

For these reasons, the Go8 welcomed the announcement of the Minister to discontinue preparations for ERA 2023.
Notwithstanding the Go8 participation in the ERA Transition Working Group to provide an option for a transition to a streamlined ERA, the Go8 recommends discontinuing ERA in its current form.
The questions of the design of a fit-for-purpose national research capability mapping and how that should intersect with a quality assessment of university research sit more properly with the upcoming Universities Accord process.
Recommendation 4: That Excellence in Research for Australia (ERA) be discontinued in its current form.
As noted in the discussion before Recommendation 1, given the complexity of the research sector the ARC CEO requires extensive support in their role. This is not the only the case for the formal governance arrangements for the ARC but also for the expert academic advice within the ARC staff cohort. This is currently obtained by employing Executive Directors who are senior and well-credentialled academics.
While the current incumbents of these positions in the ARC are of high-standing there is a need for a greater variety of expertise to account for emerging research fields, multidisciplinary research and fields of increasing important such as IT and computing.
The Go8 recommends an increased number of Executive Director positions and also that the ARC ensures flexible work options to facilitate part-time and remote working arrangements. In addition, remuneration should be competitive with a Professorial position. Taken together these measures could widen the potential pool of candidates for Executive Director positions – in particular the option of maintaining an academic career while concurrently with the duties of an Executive Director.
Recommendation 5: That the ARC increase the number and breadth of expertise in Executive Director positions and consider employment arrangements that will increase the pool of possible senior candidates for such positions.

Submission received

14 December 2022

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