La Trobe University

Name (Individual/Organisation)

La Trobe 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.

La Trobe University thanks the Review Panel for the opportunity to respond to the consultation paper, and for its undertaking to refer overlapping matters to other review activities as appropriate.

The Australian Research Council is a critical component of the Australian research system. Although it is a minority funder, it has a unique role as the main funder of pure and basic discovery research, and as a funder across the breadth of disciplines. It also has a unique level of engagement with Australia’s university research community, including a College of Experts that represents a significant concentration of expertise.

National research context
However, it sits within a system facing significant challenges and in need of systemic review and resourcing: as a share of GDP Australia’s research and development expenditure is well below international comparators, with a declining proportion of resources focused on the fundamental discovery research that is precursor for later stage translation and development. There are well documented gaps in the pipeline towards translational and developmental research, including the integration of university research, company R&D and mechanisms to deliver research in sectors dominated by small and medium enterprises. Across the Commonwealth Government, competitive funding of research and the evaluation of outcomes is distributed across Departments including Industry, Education, Health, Agriculture, Defence. Some, but not many, shared systems or strategies are in place to co-ordinate processes and priorities.

University research context
Within this national system, the funding system for university research is facing particular constraints. These include further dilution of already significantly below cost Research Block Grant support for the unfunded indirect and systemic costs of research as medical and industry-sponsored research grows in scale, and the foreclosure of the historical reliance by the university research sector on cross subsidies from teaching revenues by provisions of the Job Ready Graduates package and pandemic-related disruptions to international student enrolments. Further, these cross-subsidies were structures of convenience and did not always allocate research funds between institutions and disciplines in areas of emerging need.

Australian Research Council
These pressures have placed considerable strain on the Australian Research Council, with challenges including low success rates, underfunding of the full costs of research, reduced funding to individual proposals, costly and time-consuming processes, and difficulties in sustaining internal capability and capacity. These challenges have been compounded by a lack of clarity between stakeholders about the purpose and function of the ARC.

This combination has driven an apparent loss of confidence by key stakeholders, including components of the Australian research community. Without clear confidence from the research community, it is difficult to envisage broader public support for the sorts of investment initiatives that would be needed to address more fundamental challenges.

Therefore, while significant review of the University and broader Australian research ecosystem will still be required, increasing the clarity and purpose of the ARC via amendment of its legislative foundation, and a statement of reform priorities will make a major contribution to restoring confidence and public support in the research system Australia requires for an advanced economy and highly skilled workforce.

1. Scope and purpose
Increasing the clarity and purpose of the ARC via amendment of its legislative foundation and a statement of reform priorities will make a major contribution to restoring confidence and public support in the research system Australia requires for an advanced economy and high skill workforce.

1.1. Scope of research funding
We therefore recommend the ARC Act be amended to clarify that the purpose and function of the ARC is to fund pure basic, strategic basic and applied research in Australia’s universities and with their partners, and to help shape the Australian research system for the benefit of the nation by enabling world-leading research, fostering research quality, translation and impact, and safeguarding research integrity.

The definitions of pure basic, strategic basic and applied research derive from the ABS’ variation of the Frascati definitions in place since 2008 and have been revalidated following their review in 2020.

While we agree that the ARC’s purpose should not include funding of medical research given the scale of programs operated by the NHMRC and MRFF, any inclusion of this principle in legislation requires improved clarity of what constitutes medical research as current procedures are unclear and have led in cases of practical application to the exclusion from funding of basic biochemical and cell biology research from both NHMRC and ARC schemes. Similarly, the boundaries are not clear between community-based health studies and sociological research with health implications, and of emerging research areas in data analytics and health devices. This distinction should be applied only with confidence in an ability to apply the distinction. Reciprocal implementation of the criteria NHMRC uses to exclude is a potential means towards this.

1.2. Balance of Discovery and Linkage
The ARC’s unique role as the main funder of basic research across the disciplines should be recognised with a simplified statement that at least 60% of funding should be directed to programs that do not require industry partners, such as the Discovery program. This should however not preclude additional special initiatives or the administration of funding programs from other Departments (such as Defence) via ARC processes, but recognise the distinct mission of the ARC in comparison to Industry or Health funding.
Role of the ARC and other functions

The Act should provide for a process for the definition of funding priorities by Government and/or a governing council, and for the ARC’s autonomy in translating these priorities into managed funding schemes that enables the ARC to manage timelines and guidelines without excessive reliance on ministerial approval for administrative processes.

The Act should specifically define the ARC’s role in supporting the research of Aboriginal and Torres Strait Islander peoples, including the expansion of Indigenous systems of knowledge.

Recommendations
We therefore recommend the ARC act be amended to:
1. clarify that the purpose and function of the ARC is to fund pure basic, strategic basic and applied research in Australia’s universities and with their partners, and help shape the Australian research system for the benefit of the nation by enabling world-leading research, fostering research quality, translation and impact, and safeguarding research integrity;
2. empower the ARC to make regular operational decisions in designing and scheduling funding processes, guidelines and dates in line with priorities set by the minister and/or board without requiring specific ministerial approval for each scheme;
3. define the ARC’s role in supporting the research of Aboriginal and Torres Strait Islander peoples as individuals and teams.

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.

La Trobe University endorses the establishment of a skills-based board to support the Minister and CEO with appointees to this board to be drawn from prominent Australians with experience and understanding of research in the context of the Australian research system.

This board is an important step to rebuilding confidence and addressing perceptions of personalisation of the ARC’s function and capability. It will ensure confidence that the purpose of the organisation set out in new legislation will be implemented and embedded as effectively as possible. It will also represent one of several important steps that should be taken to ensure a greater depth of research and university experience and expertise is embedded within the organisation.

We note the distinct benefits of boards appointed by the Minister and the CEO respectively. Both models are in operation with examples of former including Industry Innovation and Science Australia, and the latter including the NHMRC.

The model selected should be able to provide advice on the development of strategy, ensure the ARC has access to appropriate academic expertise, and advise on any extraordinary situations.

We therefore recommend the ARC act be amended to:
4. establish a board to assist the minister and the CEO in governing the ARC and to provide advice on the development of strategy, ensure the ARC has access to appropriate academic expertise, advise on any extraordinary situations, and, if appropriately independent and informed, confirm funding decisions;

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 Act should be amended to provide for peer review as the mechanism for recommending specific grants for funding. Peer review ensures research is assessed by experts with the relevant expertise as part of a professional obligation not encumbered by financial interest. The process is multistage and deliberative, with procedures designed to avoid biases in decision making. This should be in line with the Haldane Principle, with the Minister responsible for the high-level allocation of resources but with the specific recommendations made via peer review. The Act should also provide for a transparent reporting process in the extraordinary event that the responsible minister, in consultation with the board, has access to information not available to peer reviewers (such as relating to national security) that affects their ability to accept a recommendation for funding.

Where there are concerns about the appropriateness of grants recommended for funding, the intervention should be in the principles, governance and process rather than the specific grant.

To ensure peer review is focused and efficient, the Act should also specify that the ARC maintain academic expertise selected based on excellence across the breadth of relevant disciplines.
In practice, this should take the form of additional academic expertise employed directly by the ARC in support of the Executive Director roles. The National Institutes of Health (USA) provide an example of this role. This will provide much needed support and succession for roles that have been vacant at various points in time. These roles would engage with the College of Experts to ensure their expertise is used appropriately, that the potential for drift in the focus of the College of Experts and assessors in the peer review process is avoided, workloads are more evenly distributed through more nuanced management of conflict of interest, and help to ensure the recruitment and retention of assessors.

These steps will strengthen the peer review process and address emerging issues deriving from resource constraints such as challenges in recruiting assessors, sustaining expertise across the disciplines and the peer review process diverging into the revision of proposals including via budgetary intervention. Further, where possible, assessors should be consistent between resubmissions of proposals to strengthen confidence.

We therefore recommend the ARC act be amended to:
5. provide for peer review as the mechanism for recommending specific grants for funding and provide for a transparent reporting process in the extraordinary event that the responsible minister, in consultation with the board, has access to information not available to peer reviewers (such as relating to national security) affecting their ability to accept a recommendation for funding;

To ensure maximum impact from these changes we recommend a statement of ARC’s required capacity and capability be developed, and encourage a consideration of the resources required to adequately achieve this. This should include:
A. expanding employed academic staff within the ARC to supplement the Executive Director roles, cultivate expert assessors and engage with the College of Experts to ensure their expertise is used appropriately.

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.

Our response to this question overlaps with the previous. Our specific recommendations are repeated here:

We recommend the ARC act be amended to:
5. provide for peer review as the mechanism for recommending specific grants for funding and provide for a transparent reporting process in the extraordinary event that the responsible minister, in consultation with the board, has access to information not available to peer reviewers (such as relating to national security) affecting their ability to accept a recommendation for funding;

To ensure maximum impact from these changes we recommend a statement of ARC’s required capacity and capability be developed, and encourage a consideration of the resources required to adequately achieve this. This should include:
A. expanding employed academic staff within the ARC to supplement the Executive Director roles, cultivate expert assessors and engage with the College of Experts to ensure their expertise is used appropriately.

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

We acknowledge recent changes to the operation of the National Interest Test, welcoming the replacement of responsibility for approval by the CEO to a university certification, and note that both peer reviewers and the Minister will have access to the statement.

The value of the current NIT lies in the need for a clear, accessible statement of the benefit for audiences without specialist knowledge, and is not fit for purpose to be the basis of decision making. The national benefit statement is written to be read by expert peer reviewers and has a distinct purpose. The NIT therefore has value but should not be about communicating the research, and the language of “Test” dropped in favour of an alternative, such as “Statement.”

More importantly, additional effort needs to be made to communicate the benefits of ARC-funded research to the public, including through dedicated media and outreach, program benefits evaluations, and project outcomes reporting. These are likely to have greater effects in preserving and strengthening the social licence for public funding than statements available on the website.

We therefore recommend changes to ARC resources and capability to include:
B. promoting the outcomes and benefits of research across the disciplines and drive public understanding and confidence in the value of the work they have funded.

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

La Trobe University would like to acknowledge the work of staff across the ARC under frequently challenging circumstances with lean resourcing. We would also like to acknowledge the work of many assessors and College of Expert members in sustaining the critical peer review processes on which a research council with the ARC’s remit depends. We also commend the ARC for initiating work on reducing the administrative burden on applying for, managing and reporting on funding provided under its programs, and on other processes such as ERA. We would advise the panel to recommend that these efforts be accelerated and the simplification, streamlining and reduction of administrative process be made a primary objective of the ARC’s activities.

Current administrative process pain points that are numerous. Examples include:
1. Conflicting advice from different staff members concerning the justification for minor project variations without financial implications;
2. Frequently changing scheme dates that produce volatile and unmanageable workloads and often conflict with other agencies;
3. Complex project budget requirements with numerous exclusions of real costs of conducting research;
4. Extremely lengthy grant applications compared to international comparators that places burden on grant applicants, reviewers, assessors, and staff responsible for ensuring grant compliance
5. Feedback has suggested that the ROPE requirements are unnecessarily complex and may act against rather than in favour of more equitable outcomes;
6. Grant compliance requirements are excessively prescriptive – considerable expense and time from talented people is devoted to measuring font sizes, margins, etc.;
7. The medical research exclusion is not predictable and appears to be being extended well beyond medical research to basic biological sciences beyond the NHMRC remit;
8. Proliferation of hundreds of adversarial business rules in ERA that presume ‘gaming’ on behalf of universities that result in extremely complex submission development;
9. ERA processes that require submission of all outputs produced by all staff members at all universities twice every six years is not proportional to the value of the exercise.
10. The rejoinder process involves challenging timelines and may not add value commensurate to the academic and administrative effort involved.

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.

The improvement of ARC processes should begin with changes to the Act that empowers the ARC to manage schemes in line with practice at the NHMRC. This will enable clear timelines and contribute to a culture of active, responsible management. A re-examination of ARC capability, capacity and resourcing can build upon this and enable a new operating model that extends the ambition in the current ARC strategy’s priority three. This will ensure front-line employees are equipped to make responsible decisions, provide accurate advice, and anticipate and remove administrative roadblocks in order to better facilitate research.

An active, managed program of process improvement should be initiated. Given that previous process improvement consultations have not always produced significant outcomes whether due to a lack of alignment between stakeholders, or conservatism on behalf of stakeholders with limited information, clear objectives and principles should be articulated. Principles could include:
• transparent consultation with the sector, ensuring multiple stakeholders including researchers, assessors, research offices, and senior university leadership are engaged alongside each other, and;
• allocation of decision rights and responsibility to the appropriate party (avoid multiple reviews of decisions at the university and ARC levels).

Objectives could include:
• a reduction in administrative burden on the ARC, researchers and research offices;
• halve the time from grant submission to outcomes, potentially enabling multiple rounds per year, and;
• reduction in the length of application forms by half

Specific initiatives may include:
• increasing Universities’ ability to manage agreements and their variation within parameters without lengthy but redundant approval processes;
• reducing proposal documentation, including reduction of the project proposal length, reducing the complexity of ROPE statement requirements;
• removing burdensome and counterproductive formatting requirements for grants and replace with appropriate guidance;
• introduce single line budgets, simplifying the application and assessment processes and avoiding the rework of complex projects;
• full use of ORCID for publication track record with no further entry required;
• trialling a two-stage process with an EOI followed by a full proposal as used in the New Zealand Marsden schemes, and;
• developing clear scoring guidance with improved descriptors, modelled on the seven-point scale used by the. NHMRC.

As proposed above, a renewed ARC should also embed additional academic employees to supplement the Executive Directors and play an active role in recruiting, retaining and supporting assessors and engaging and focussing and balancing the activities of the College of Experts. More equal allocation of workloads within the College should be pursed, and larger panels such as the Discovery Projects panel split. A more proportionate conflict of interest process aligned to the NHMRC would assist with addressing high workloads as the current declaration of a conflict by institution greatly reduces the capacity of College members from the largest, most research intensive universities from assessing a large proportion of applications, and this placing additional burden on others.

We therefore recommend a statement of ARC’s required capacity and capability include, in addition to recommendations A. and B. previously:
C. operating a managed program of process improvement in consultation with stakeholders with clear principles, objectives and timelines;
D. enabling staff administering schemes to provide oversight and proportionate advice and adopt principle-based governance of responsibilities delegated to universities;

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?

ERA and EI should not continue in any form that involves the compulsory collection of data from institutions or comparative rating of research by institution.

Australian universities have an existing imperative to grow their reputations for research excellence and impact, and mechanisms to measure this via bibliometrics, university rankings, reputation surveys and market recognition. Justification for a highly rigorous, retrospective excellence and impact exercise that seeks to rate institutions discipline by discipline is therefore lacking.

This is especially the case given the costs and burden of a comprehensive collection of six years of outputs from all staff members of all Australian universities, including the peer review of a full 30% of outputs in relevant disciplines, and complex business rules predicated on the assumption of adversarial behaviour be submitting institutions.

Recent proposals to simplify this process while retaining a requirement for institutions to regularly provide a comprehensive submission of coded research outputs are also not justified.

Similarly, the process of evaluating and rating case studies does not add particular value to that created by the assembly of the case studies in the first instance and does not need to occur in its current form.
What is required is a future-focused capability to evaluate research outcomes and impact. More detail on this is provided in relation to question 9, below.

An evaluation function need not form part of the ARC legislative foundation beyond a high-level statement that the ARC help shape the Australian research system for the benefit of the nation by enabling world-leading research, fostering research quality, translation and impact, and safeguarding research integrity, in line with its existing strategy.

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?

In place of compulsory data collections and evaluations that drive competitive rather than collaborative behaviour in an underfunded sector, the ARC's scarce and valuable resources should be devoted to a function with the mission to identify strengths and weaknesses in the national research capability against global trends and national priorities and make appropriate recommendations regarding these. This function should also be equipped to provide compelling evidence to the public, Government and industry of the impact and outcomes of research funded by the ARC and as a product of the national research system.

It is critical that this parts ways with the existing practice of compulsory data collection from universities. Due to the part-funding of research, the shortfall in costs provided for by in research block grants, and the end of the capacity to maintain cross subsidies from teaching with changes to the Job Ready Graduates Package and disruption to international markets, Australian universities are unable to bear the unfunded costs these requirements impose.

In place of compulsory data collections, these functions should utilise existing data sources without the need for a university submissions or data collections by leveraging third party bibliometric databases including ORCID metadata records.

This capability should be endorsed by the minister and other stakeholders, including appropriate co-ordination with the Chief Scientist and Industry.

Moreover, the outputs of these processes should not be ratings or evaluations of individual institutions, but evidence that is compelling to the public and industry stakeholders.

This function would require an extension of the current capabilities of the ARC, particularly in terms of use of third party data and the translation of data and analysis into effective outreach and communications.

We therefore recommend ARC capacity, capability and resourcing be reviewed to include:
E. developing a capability for the development of forward-looking advice and recommendations relating to the strengths and weaknesses of the collaborative Australian research system and development of initiatives to address them in place of existing programs of retrospective competitive evaluation and assessment, and;
F. ensuring a capability to design initiatives and influence schemes to improve equity of outcomes and the development of a more diverse research workforce.

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?

These recommendations and initiatives should be combined with a review of the funding required for the ARC’s grants programs. Current success rates and funding per grant are below those of international comparators that maintain success rates at approximately 25% and have higher average levels per grant by discipline. These are now below levels for sustainability of an internationally competitive research system. Without addressing this, the ARC risks becoming a marginal part of the Australian research system despite its critical position within it. Given the end of cross subsidy from other sources of funding, this funding also needs to cover the full costs of the research to be conducted. This is a challenging prospect in the current national and international economic environment but needs to be a priority to ensure the proper functioning of the Australian research and innovation system that is needed for the development of an advanced economy and skilled workforce.

Submission received

14 December 2022

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