Flinders University

Name (Individual/Organisation)

Flinders 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.

a. We are strongly supportive of the ARC continuing to be recognised in the ARC Act as the key funder of basic and applied research in universities across all non-medical disciplines.

We recommend that peer review is recognised in the Act as the best method for determining how funding is distributed across disciplines.

b. We recommend that commitment to support for basic research (currently through the Discovery schemes) and for industry engagement (currently through the Linkage schemes) should be incorporated into the Act.

c. The ARC could play some role in shaping research directions, but primarily through participation in the establishment of priority research areas, normally led by the Chief Scientist, and through incentivising funding of research in these priority areas, as per current practice.

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

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

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

The ARC Act should legislate a similar board structure to the NHMRC to provide consistency in the governance processes for the two major research funding bodies and to support the work of the ARC CEO.

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?

We agree with the statement in the consultation document that the ARC Act, strategies and operations should be informed by the structures, governance and practices of other successful international funding bodies.

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 integrity of the peer-review system, which we argue above should be enshrined in the form of a commitment to the Haldane principal, has been undermined in recent years by the rejection of grants by the Minister.

The Act should make it clear that the Minister can only intervene in extraordinary cases where there is a genuine national security issue that would warrant withholding of funding, as it is possible that researchers may be unaware of potential national security issues. Appropriate involvement of other arms of the Commonwealth Government responsible for national security should be utilised to advise on such a decision. The Minister responsible for the ARC (currently the Minister for Education) should not be able to reject grants based on his/her perception of benefit to the Australian community. The peer-review process has already thoroughly assessed this through the Benefit statement in the application.

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

National interest is already assessed in most grants schemes using the benefit statement in the body of the application. The National Interest Test is therefore unnecessary and inappropriate as a mechanism to inform the assessment process. To better convey the research to the public, successful applications could be required to submit a short description of the goals and expected impact, to be approved by the DVCR, for use in ARC and Ministerial media releases.

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

Having to complete multiple iterations of the NIT is a waste of time for researchers, universities, and the ARC. The use of existing online databases of publications/outputs from trusted sources could be used instead of requiring researchers to provide them.

Q7. What improvements could be made:

(a) to ARC processes to promote excellence, improve agility, and better facilitate globally collaborative research and partnerships while maintaining rigour, excellence and peer review at an international standard?

(b) to the ARC Act to give effect to these process improvements, or do you suggest other means?

Please include examples of success or best practice from other countries or communities if you have direct experience of these.

Some other Nationally Competitive grant schemes use Expressions of Interest prior to submission of a full application (e.g., the Marsden Grants in NZ). As it stands, the application process for DPs and most other schemes administered by the ARC is overly burdensome. Given the relatively low rate of success, it would make sense to make a call for EOIs. These EOIs could be relatively short, and a number of applications be selected to go onto a full application.

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?

a. We strongly support discontinuing the Excellence for Research in Australia and Engagement and Impact assessment processes as they currently stand, as we believe they have served their purpose and no longer justify the extraordinary workload required to prepare submissions. Nonetheless, we also support the ARC should have a role in advising the Minister for Education on the quality and impact of the research that it supports, although in a future vision manner rather than the current retrospective manner. How the ARC might support the Minister in this respect should not be prescribed in detail in the ARC Act. At a bigger picture level, a forward looking, broader and system wide approach to assessment of research quality and impact could be considered perhaps focusing on particular disciplines on a rotating basis.

b. The advantage of data-driven approaches is that they could be relatively easy to administer and draw from a pre-existing data base. The major obstacle, however, is that data-driven approaches do not capture the Humanities well – and do not capture the creative arts at all.

c. Research that engages with end users, can be translated, and as an impact is already encouraged through the benefit statement in most ARC schemes. This is especially the case for Linkage grants that partner with industry/government. There is no need to have a further assessment process because this impact is already assessed in the grant application and final report process.

Submission received

14 December 2022

Publishing statement

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