Griffith University

Name (Individual/Organisation)

Griffith 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.

Griffith University welcomes the opportunity to provide input to this Review and has based its response on the Terms of Reference which seek advice on amendments to the ARC Act with respect to the role and purpose, governance and management, administrative and legislative burden, and the breadth of function. Clearly the ARC Act does not currently describe the full remit of activities undertaken by the ARC and in this regard, Griffith supports the Innovative Research Universities (IRU) response which takes into account the important role of the ARC as a primary funder of nationally competitive grants across the range of non-medical fields while acknowledging the range of unlegislated functions and seeking their inclusion in the ARC Act. Griffith University supports the recognition of these functions in the ARC Act, but without necessarily specifying the detail or form of how these functions should be operationalised.

Griffith University therefore supports legislative approaches which enable and support:
- a strong and independent ARC which recognises and rewards excellence in research;
- the ARC’s role in supporting research across the HASS and STEM disciplines; and
- the broader remit of the ARC for assessing research excellence, engagement and impact, and research integrity.

The University also recognises and endorses the need for process improvements in grants administration, reductions in administrative burden such as those imposed by introduction of the National Interest Test statement and excessive Postaward documentation such as Risk Management and Data Management plans for every project grant, the potential for streamlining the ERA/EI initiatives, and the overreach by the ARC and consequential excessive reporting requirements.
There is also deep concern across the sector that the ARC’s funding and influence has been reduced in relative terms due to the erosion of Research Block Grants as a proportion of total funding and the dilution of the Commonwealth funding envelope due to the introduction of new schemes such as MRFF – driving the sector to subsidise ARC-funded research from other means. This wider issue cannot be ignored within the context of this Review and in the Universities Accord Process.

1. Scope and purpose of the ARC
As pointed out by the IRU, the ARC is the main funder of basic/discovery research in Australian universities. However, total government support has shifted in recent times in favour of schemes directed at applied research and experimental development and while this support is welcome it does have the potential over time to reduce Australia’s commitment to basic and strategic basic research, which accounts for only one-third of Government Expenditure on R&D in 2020-2021, but which is essential to maintaining the pipeline of research and innovation.

A strong and independent ARC will be able to monitor this balance in a non-partisan manner to “shape the Australian research system for the benefit of the nation” (ARC Strategy 2022-2025). The consultation paper outlines a range of other functions not captured within the Act such as demonstrating academic excellence and leadership, provide leadership in national policy development, refining programs to manage career disruptions, and support for Aboriginal and Torres Strait Islander research. Statutory definition of these functions within the Act will provide the ARC with the legal authority and independence to deliver against its stated purpose – for example, funding rules could be developed and approved internally without requiring Ministerial approval.
The ARC also has a special role to play in championing research disciplines, fostering research quality, translation and impact, and safeguarding research integrity as outlined in the ARC Strategy 2022-2025. Griffith University supports the recognition of these functions in the ARC Act, but without specifying the detail or form of how these functions should be operationalised.

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.

Re-establishment of the ARC Board, reporting to the Minister, has merit subject to the Act being amended to recognise the ARC’s wider remit and provided the Board is empowered to support the ARC in delivering on its purpose. The Board would have responsibility for recommending appointment of the ARC CEO, members of the College of Experts, and other committees related to the effective functioning of the ARC. It should ensure that the ARC is carrying out its functions efficiently and effectively, including provision of advice on application policy and the balance between pure and applied research (Discovery and Linkage) ensuring that the needs of specific disciplines are considered.

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?

An effective measure to ensure academic and research expertise is obtained and maintained to support the ARC is to adopt a provision like the UK Higher Education and Research Act 2017 (s.103(3)) – The Haldane Principle.

The “Haldane principle” is the principle that decisions on individual research proposals are best taken following an evaluation of the quality and likely impact of the proposals (such as a peer review process).

That UK Act also introduces the “balanced funding principle” which is the principle that it is necessary to ensure that a reasonable balance is achieved in the allocation of funding. This legislates the principle that balance should be achieved between the funding councils and the Department (and Minister). This enables government to set strategic research priorities but is balanced by the Council’s authority to make scheme level decisions informed by peer review.

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.

Griffith University acknowledges that Ministerial discretion is required in exceptional circumstances but that this should be done in a transparent manner. The question posed is whether the Act should be amended to consolidate the pre-eminence of peer review, and incorporation of the Haldane Principle (see 3 above) achieves this. The UK Act also clearly prescribes the powers granted to the Secretary of State to direct the funding councils in relation to allocations, but the legislation is quite complex. For this reason, it is proposed that non-legislative measures (as suggested within the consultation paper) might work better, clearly defining the process for Ministerial intervention and transparency about the process and sharing of outcomes.

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

Griffith University supports the role of the ARC in championing the public benefit of research undertaken in all disciplines. As pointed out in the IRU submission, “Benefit” is already a criterion for ARC funding and is appropriately assessed through peer review. In that regard the National Interest Test statement is redundant but were it to remain then its purpose should be to outline the public benefit rather than be seen as part of the assessment. The ARC could then play a much more constructive role in supporting researchers to articulate the public benefit of their research to a non-academic audience, potentially as part of a wider Pathways to Impact program (see response to Q.9).

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

The Panel has already identified administrative challenges such as duplication of requests for information, unexpected changes to grant rules and deadlines, delays to announcements, onerous requirements on international partners who receive no funding, delays in advising appeal outcomes, duplication of national security requirements, prescriptive financial requirements and so on. These present very real challenges and should be reviewed as a priority. The National Interest Test statements have also created an unnecessary burden for both the ARC and the university sector.

The ARC imposes other unnecessary processes in cases where the university sector already (and very effectively) manages a wide range of compliance expectations around foreign engagement, export controls and sanctions, due diligence, conflicts of interest, data management, risk management, research ethics and integrity and other compliance obligations. Therefore, an overlay of additional requirements imposed by the ARC is often unnecessary and especially so in cases where another government department has primary responsibility for compliance in a particular area.

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.

Griffith supports several high value-add process improvements flagged including:

- The Minister’s request for grant rounds to be delivered on time and to a pre-determined timeframe which will allow universities to plan and provide appropriate resourcing.

- Providing outcomes to institutions under embargo in advance of announcements would be greatly appreciated to prevent the scrambling that goes on following surprise announcements (e.g., Christmas Eve 2021).

- Use of an Expression of Interest stage more widely than at present.

- Making selection report data available to administering institutions and applicants would be of immense value. This should happen at all stages, for example, allow applicants in the bottom half of applications at the time of rejoinders to be advised that they were unsuccessful so they can consider alternative funding sources.

- Although not a process improvement as such, we support the restoration of the ARC Research Networks Scheme and (more important than ever post-COVID) for those fields without large-scale infrastructure.

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?

In the absence of a link to funding it is very hard to see any justification for the administrative effort, resources, and burden on productive researchers, that goes into ERA and EI under the current framework. It is also questionable whether anyone outside of the university sector and sections of government ever uses ERA and EI outcomes in a meaningful way, especially given its retrospective nature (i.e. data from 2011-2016 for ERA 2018). Even the university sector has become ambivalent about ERA given the availability of research analytics tools which provide close to real-time data. The world has moved on and the ERA framework is redundant – therefore a data-driven approach to ERA, as close to real-time as possible, would certainly seem feasible and the ERA / EI Transition Working Group is advising on this matter. Placing aside the cost and administrative burden, stakeholders will continue to demand evidence of the effectiveness and quality of research undertaken by Australian universities and this poses the question of what would fill the vacuum. Stakeholders lack access to the advanced analytics tools available in universities and in the absence of ERA most Australians would be guided solely by rankings and reputation for their assessment of the research performance of individual universities.

In this light, the ARC is well placed to build on the ERA legacy to develop an entirely new, modern and world-leading approach to research assessment that is aligned with global best practice, and which can provide global insights that will inform Australian research strategy and priorities and provide information that is useful for external stakeholders. Consistent with our response to question 1, Griffith University recommends that the ARC Act should reference a research quality, engagement and impact assessment function however conducted.

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?

We agree that ERA’s legacy is an impressive capability within the ARC which can be deployed across the sector in evaluating research excellence and impact to demonstrate value to government, industry and community stakeholders. Suggested ways in which this impressive capability could be deployed include:

- The ARC playing a leadership role in the development of new capabilities across the sector (e.g. use of researcher IDs and persistent identifiers for outputs, open access, Pathways to Impact approaches).

- Analysis of emerging research fronts in areas of national interest (e.g., quantum technologies, cybersecurity, energy, new materials) and assessment of Australia’s standing and competitiveness internationally.

- Ensuring Australia continues to drive global best practice by continuing to work with commercial data providers to improve their product, for example driving refinements in AI to better align research outputs to Field of Research codes.

- Griffith also endorses the IRU proposal for the ARC to apply its existing capabilities “to the development of a new national program to evaluate the long-term benefits arising from government investment in university research”. This should include “creating a community of practice, helping to develop capabilities within universities and developing an evaluative framework that includes economic impacts as well as broader public good impacts”.

Submission received

14 December 2022

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