The University of Queensland

Name (Individual/Organisation)

The University of Queensland

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.

The University of Queensland (UQ) welcomes the opportunity to respond to the Review of the Australian Research Council (ARC) Consultation Paper. The Consultation Paper raises a range of important questions that warrant dialogue between Universities, the ARC, and the Department of Education, particularly in light of parallel exercises such as the Universities Accord process.

In considering the current and future role of the ARC, whether expressed in legislation or strategy, two principles must be upheld:
--The ARC must continue balanced investment in basic, strategic and applied research.
--The ARC must support excellence and integrity in Australian research through its investments and its service delivery.

There is scope to amend the Act to better define the position and role of the ARC by including objects that reference the agency’s proactive role in shaping the research landscape. This would reframe the mission of the ARC from a granting agency that funds research to an agency that invests in research and creates public value.

To update the purpose of the ARC, it is suggested that Section 3(b) of the Act be expanded beyond the current ‘the funding of research programs’ to include:
--the funding of research programs
--supporting the development of Australia’s researchers;
--helping to shape the Australian research system for the benefit of the nation;
--investing in basic, strategic and applied research;
--the creation of public value through grant outcomes, translation of research, service quality delivery, and service efficiency.

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.

UQ considers the introduction of a Board may provide a useful way of providing transparency of decision making and the assurance of process that would restore confidence in the outcomes from the ARC.

A model worth exploring is that used by the NZ Ministry of Business, Industry and Employment in the allocation of a number of its research programs (Research, Science, and Technology Act 2010 No 131 (as at 07 August 2020), Public Act – New Zealand Legislation - https://www.legislation.govt.nz/act/public/2010/0131/latest/whole.html).

This model extends the proposal outlined in the consultation paper by making clear the responsibilities of the Minister in the setting of the parameters of funding, but removes the reference to the Minister for the allocation to specific funding proposals. The Board should be appointed by the Minister (with a composition outlined in the Consultation paper) and has an obligation to deliver the broad outcomes articulated by the Minister. The Board should also have a responsibility for ensuring the robustness of the processes used by the ARC in the ranking of proposals, with recommendations for funding being delivered through the CEO to the Board for final decision making.

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?

In order to consolidate the pre-eminence of peer review and support trust in assessment processes, several minor amendments could be considered:

--A definition of peer review could be inserted into Section 4 of the Act.
--Section 33B of the Act could be modified to state that one role of the CEO is ‘to ensure that recommendations and advice to the Minister are informed by a process of peer review’.
--In Section 3(a)(i), the term ‘high quality’ ought to be replaced by ‘informed and impartial’ recommendations. This would remove a subjective term and replace it with one aligned with the principles of peer review.
--In section 3(a)(iii) the term ‘high quality’ should be replaced by ‘authoritative’ since this reflects the need for the Minister to receive advice that they can trust.

Although beyond the scope of the Act itself, UQ would support a greater operational emphasis on the expertise and pre-eminence of academic excellence of the Executive Directors and members of the College of Experts.

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.

UQ refers to our February 2022 submission to the Senate Education and Employment Legislation Committee Inquiry on the Australian Research Council Amendment (Ensuring Research Independence) Bill 2018.

UQ’s submission to that Inquiry reasserted our strong support for the role of independent peer review as the mechanism for the allocation of funding administered by the ARC.

If Ministerial discretion is retained, its use should be subject to a limited set of conditions, which should be set out in Section 51 of the Act. This should specify the limited circumstances in which a Minister can exercise the authority to determine against funding a project that has been recommended for approval. These limited circumstances would include where the integrity of due process is in question and/or where national security may be compromised.

The practice of funding announcements being made by Members of Parliament other than the relevant Minister has had negative consequences and should be avoided in future by ensuring that the Act specifies that only the Minister or a delegate, as listed in section 66 of the Act, will announce the outcome of funding applications.

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 National Interest Test should be discontinued in its current form. The current NIT model lacks transparency and creates administrative burden.

An assessment of national interest should be part of the ARC’s assessment process, preferably through expansion of the current layman summary to describe benefit and, where relevant, pathway to the translation of research outcomes.

Statements highlighting the importance of knowledge generation and discovery, without a reference to immediate translational potential, should be acceptable. Academic impact could be considered as an alternative to ‘adding to global knowledge’ here since this would require applicants to describe the expected contribution of the research to changing conceptual understanding in a research field, advancing methodologies, and reframing discussion in and beyond academia. Incorporating academic impact into the layman summary would enable researchers to better articulate the purpose of fundamental research.

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

A review of ARC administrative practices in light of government requirements and risk tolerance would be welcome, but this should be the focus of specific and well-structured consultation, and goes well beyond a review of the Act itself.

The most intractable administrative burdens in relation to ARC processes and practices lie in the differences between the national funding bodies, with little commonality in things like researcher identification, CV requirements, and application systems. Uncertainty has also existed in scheme opening, closing and announcement dates. Regularising across funders, and in relation to timeframes, would make significant gains in reducing administrative burden.

A uniform Head Agreement across the ARC, NHMRC and MRFF (including AusIndustry-administered grants) would simplify many of the activities universities are required to undertake in order to execute agreements with the agencies. Risk tolerance would be an important aspect of a potential Head Agreement in order to regularise practices around when expenditure can start on grants, funding expenditure variations and the reporting requirements associated with each funding body. A common understanding across agencies of foreign influence and its assurance processes would also enable the ARC and administrating organisations to deploy resources appropriately and in appropriate timeframes.

We acknowledge that the ARC has attempted to align its research integrity reporting requirements with the NHMRC, which has been beneficial from an administrative perspective. The ARC are co-authors of the National Statement on Ethical Conduct in Human Research and the Australian Code for the Care and Use of Animals for Scientific Purposes. There is scope for strengthening research ethics and reducing administrative burden through more timely revision of these documents and associated processes. This includes necessary revision to the Guide to Managing and Investigating Potential Breaches of the Australian Code for the Responsible Conduct of Research, which many institutions are finding impractical in application.

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.

While UQ welcomes meaningful and proactive progress toward efficiencies in ARC processes, similar to Question 6 these actions may lie beyond the scope of the review of the Act, and deserve a dedicated and well-structured consultation process.

Attempting to improve process efficiency through legislative reform risks restriction in ongoing agility and innovation.

UQ recommends that opportunities for process improvement should be considered via a dedicated process that engages with key stakeholders. International examples may be considered as part of this further consultation such as:
1) The National Institutes of Health (USA), where program administration staff work with applicants to improve their grant submissions, and peer review of grants has a memory/carryover across years, as opposed to applications needing to be submitted every year.
2) The Endeavour Fund (NZ), uses a two-stage process, where consistent assessor comments can be generated without placing undue burden on assessors. This ability to provide rapid feedback to researchers allows for quicker applications, and better success rates when re-submitting initially failed grants.
3) Various funding schemes within the Swiss National Science Foundation prioritise the rapid funding of new ideas and projects, and could be considered.

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 response to Question 1, above, we provided some suggested additions to the Act to reference the ARC’s more strategic functions. We suggested that a purpose-oriented addition to the Act of this kind would be sufficient to encompass current and potential future activities in relation to research quality and impact assessment.

More generally, UQ is concerned that placing the current ERA process on hold without a clear vision of the way forward, and having multiple processes running concurrently on eliciting commentary on the ERA process, may generate a suboptimal outcome.
UQ supports the continuation of a national excellence/impact assessment exercise that: focuses on academic excellence and end-user and societal impact; supports the case for public investment in research; provides the ARC with an appropriate quality assurance mechanism for its expenditure; and, avoids unnecessary administrative burden.

Any processes adopted for a new assessment exercise must be informed by research evaluation best-practice, and underpinned by principles such as those outlined in the Leiden Manifesto and the Declaration on Research Assessment. The Leiden principles, published in response to the proliferation of metrics, are designed to minimise the risk of ‘damaging the system with the very tools designed to improve it’. New assessment processes must also ensure that data collection and analytical processes are open, transparent, and simple, while avoiding any false precision or misplaced perception of validity that an automated, data-driven approach might introduce. Assessment should also avoid any additional burden being placed on individual researchers

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 development and/or redeployment of the ARC’s evaluation capability seems outside the remit of the current consultation with respect to a review of the Act.

In addition, the commentary accompanying Question 9 appeared to assume that the outcome to Question 8 would be the abandonment of an assessment exercise, thus enabling redeployment of this assessment capability. UQ does not agree with the proposition that an assessment exercise should not be conducted.

Nevertheless, UQ does see value in the wealth of expertise within the ARC being applied to greater effect for generating a wider appreciation of the benefits and impacts of publicly funded research in the community. Achieving this would seem reliant on a deep understanding of the long-term impact of ARC funded research which comes from an assessment exercise such as E&I that encompasses;
1) Commercialisation of research outcomes, including both licencing and company formation
2) Translation of research outcomes that does not included commercialisation that involve changes in policy, practice and other impact on end-users and the community
3) Impacts from consultancy activity with industry and government

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?

Conflict of Interest Disclosure: The Vice-Chancellor and President of the University of Queensland, Professor Deborah Terry AO, is a member of the ARC Advisory Council.

Submission received

14 December 2022

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