Council for the Humanities, Arts and Social Sciences

Name (Individual/Organisation)

Council for the Humanities, Arts and Social Sciences

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.) The ARC Act is unclear on the scope of research funding supported by the ARC. There are advantages to this model of legislation, allowing flexibility. There are, however, significant drawbacks. The most obvious is that resources are shifting away from basic research. We know from international evidence that basic research in HASS and STEM drives unexpected innovation across multiple spheres essential to the flourishing of social life. Without excluding support from applied research, consideration should be given to enshrining in the act the ARC's critical role in placing Australia at the forefront of advancing excellent and innovative pure and basic research.

b.) The principles articulated under a.) suggest the need to re-evaluate the function of Linkage grants. While Linkage grants can foster pure and basic research and important research partnerships that would only emerge with this grant support (particularly when the industry partner is a not for profit or otherwise unable to directly fund the research themselves), there is a risk that funding is primarily directed to areas with significant non-government investment in research and development and other sources of funding available without Linkage support. The Act might be amended to specify that only a percentage of ARC funding (such as 10 per cent) be directed towards Linkage grants, liberating funds to support essential Discovery programs. There is a need for a sustainable and diversified portfolio of grants beyond the limited number currently present in the Australian research landscape. A modification to the Act or alternative legislation to support a joint public-private research investment fund may be part of filling this gap.

c.) and d.) The ARC plays an important role in shaping research in the country. The ARC currently has limited resources to imagine long term, sustained clusters of research excellence beyond Centres of Excellence. But research in many fields simply does not progress in 3–4-year increments. Many successful DPs have outcomes which clearly point to the next phases of the research but at that point the applicants must start all over again with a new application that is treated by the process as an ab initio application and even penalised for a relative lack of innovation. The Act might be altered to specify that a variety of time-frames must be supported by ARC schemes, with proportions of funds allotted to short-term projects, from 1 to 5 years, with some avenues to support longer term work (e.g., 10–15 year).

We do not see any role for the ARC in large-scale research evaluation exercises which international and Australian experiences have shown are a costly and unreliable way of evaluating research excellence that encourage distortions across the HE sector. These roles should not be enshrined in the Act.

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.

CHASS endorses a lightly revised version of the Board advanced in the consultation model. As the Act is currently drafted there is significant scope for confusion between academic and political judgement. Including a board structure within the Act, with appropriate safeguards regarding expertise and independence from ministerial interference outside of reasonable ministerial oversight (this interference includes arbitrary veto after funding rules and criteria are set and have been met), would help to address major concerns with the functioning of the ARC process in recent years. One approach to supporting ARC's independence from the Minister would be to make certain positions on the ARC Board elected by members of the learned academies.

The Board structure should be articulated to codify requirements of meaningful consultation with the sector, including peak bodies, learned academies and universities, so that the board is trusted as representative of the country's most significant thinkers and academic leaders. In defining the composition of the board, a revised Act may also include clauses enshrining Indigenous expertise, disciplinary breadth (across HASS and STEM), and issues of diversity in the Board's composition.

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 formation of the Board should in part address these issues (as outlined in Q2 above). Other issues of process, including the appointment of the Colleges of Experts, should be via transparent application process, but left to the ultimate judgement of the ARC Board.

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 Act should be emended to remove the clauses that allow for unchecked ministerial veto of research funding recommended by the CEO (or, in the new revised Act, the Board) of the ARC. This will assist in addressing the major damage done to Australia's research reputation in recent years by arbitrary uses of veto powers.

In some extraordinary and rare situations, ministerial veto may be appropriate. These situations might be codified in the Act and the processes for Parliamentary oversight of these powers articulated. The veto should only be possible in certain bounded (and highly unusual) circumstances:

1. Where the Board has failed to follow the due process of independent peer review of proposals;

2. Where additional information about a grant or proposed grant holder has come to light that may require a grant to be reassessed by an independent panel of experts;

3. Where the project can be shown by an independent panel of security experts to pose a real threat to national security.

Ministerial justifications of grant veto must address at least one of the categories and be provided to Parliament within 14 days of the veto power being activated.

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 social license for public funding of research must be a collaboration between politicians, ARC, researchers, universities and sector and discipline groups. Structures such as the NIT are clearly not providing the kind of rich and detailed accounts of why research matters to a flourishing society. Some similar international bodies have a mission to advocate for research in a way that the ARC currently does not. The UKRI for example, through its disciplinary councils, has a mission not only to support research projects directly through funding but to also champion the creativity and vibrancy of research disciplines and the research priorities and network building capacity of different sectors, including HASS. The ARC might consider establishing research engagement funding that is a 'bolt-on' to existing grants, or funding a block grant to major research HE institutions, peak bodies and learned academies to enable experienced educators to work with local communities to undertake in the important task of partnering with communities and bringing the case for research and its benefits to wider publics. The ARC itself, through its officers and Board, as well as politicians, may wish to take a more active role in showing why research matters across a variety of domains – economic, social, cultural and so on.

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

Current ARC processes have significant strengths but can be refined in a number of directions. CHASS welcomes the articulation of problems in the ARC Consultation Paper. We include the following is a list of areas that have been identified by CHASS members to provide further support for practical reforms to ARC processes.

1. The low success rates, and the enormous expense of academic labour across the country (and the world) for very limited rewards. Possible solutions to this problem are a.) increase the funding to improve success rates; and b.) reduce the length of applications, and duplication of information across the application; c) insert an EOI stage which allows certain grants less likely to succeed to be identified at an early phase before weeks or months are spent in the drafting process.

2. Confusing rule changes. There have been positive movements here in recent times, but there is a simple fix here: state the rules clearly without multiple confusing revisions.

3. Calendar issues. Again, there have been positive movements here in recent times, but it should be standard to fix the dates for rule releases, applications and announcements and stick to these dates.

4. International collaboration is difficult given the lengthy requirements of the application not only for the team but for each investigator, including international partners (the ROPE for example). The ROPE plays an important role in applications, but often duplicates sections of the applications given over to investigator capability. Reducing the length of the ROPE may be an advantage here, alongside removing duplication with the investigator/capability sections from early in the application.

5. Budgets are currently cumbersome and should be simplified where possible. The tools on the RMS are not fit for purpose and should be replaced.

6. Non-traditional outputs are hard to track and insufficiently valued in ARC application processes. This difficulty can be addressed by clearer guidelines to applicants and assessors about these important facets of academic life. A consultation of the sector may be required to develop these guidelines.

7. Australia's Science and Research Priorities are often narrow and risk alienating international collaborators. Broad Research Priorities may have a role in the ARC's processes, but risk being politicized if they are not developed by an independent board of research experts from across sectors. If Research Priorities are maintained, they should never be used to crowd out novel ideas which often emerge unexpectedly without reference to strategic directions or goals.

8. Funding for minority disciplines. Several important areas of research, including in HASS, that risk being crowded out by larger disciplines with larger research communities and consistent ARC success. The ARC may wish to target some funding or funding schemes towards certain at-risk fields of knowledge, where investment is necessary to maintain expertise.

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.

1. The ARC may wish to institute a small fund for networks that allows international collaboration to develop towards larger grants. This has been a highly successful method of research funding in a variety of European contexts.

2. The DECRA scheme is clearly not fulfilling its purpose as an early career award. CHASS does not advocate for its abolition. The DECRA should remain, as a valuable means of attracting major international talent and for supporting emerging researcher leaders. But a further scheme should be established: a genuine postdoctoral award, to be held one or two years after the award of a doctorate. A requirement of the award should be that the recipient not hold a continuing academic post. This will allow the retention of a group of scholars who often disappear from academia or Australia. Future Fellowships may also need to be recalibrated as the current number is not enough to support mid-career excellence and progression (investment and support for mid-career academics is often missing within and outside of HE institutions, with a greater focus on ECRs and senior research leaders).

3. The ARC may wish to re-institute a smaller grant scheme of the kind covered by various other research funding schemes in international contexts. Grant proposals are sometimes overblown or given an extended timeline simply to match the scheme funding rules and accessor expectations and may be better served by other funding configurations.

4. The transfer of grants between institutions should not require elaborate justification or unnecessary and lengthy delays. Grants are not a form of debt bondage, but rather a means to foster research excellence, and thus should follow researchers as they develop their careers.

5. CHASS believes that these kinds of procedural issues about new funding schemes and their rules are best decided by the newly constituted Board.

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?

CHASS does not believe the ARC Act should be amended to include an assessment function of any kind. There is no need for elaborate reviews of research impact and assessment if there is adequate reporting and review of ARC of grant outcomes at the conclusion of funding periods. Experience of these elaborate reviews, e.g., REF in the UK, and the ERA in Australia, suggests that these exercises are costly, often gamed by institutions, and waste resources that would be better deployed elsewhere. They are a drag on research and innovation.

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?

The ARC should have an oversight role in making sure that the grants which it funds have been carried out in accordance with their terms. There is also a need to support the necessary data collection and articulation of benefit that can underpin successful advocacy for research to the Australian public. The ARC may play a direct or indirect role in this. However, as outlined in section 8 we do not see the benefit of a larger role as adjudicator of research excellence in the form of an ERA type exercise.

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?

CHASS welcomes this opportunity to contribute to recalibrating the ARC's structure and function. We are hopeful that the future of the ARC will allow further avenues for peak bodies such as ours to contribute to its success.

Submission received

14 December 2022

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