Association of Australian Medical Research Institutes (AAMRI)

Name (Individual/Organisation)

Association of Australian Medical Research Institutes (AAMRI)

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.

AAMRI does not believe it would be of any benefit to specify the scope or balance of research funding within the ARC Act, except to reference its role in providing national leadership in upholding integrity in research.

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.

AAMRI is supportive of the establishment of a Board that can advise the ARC CEO on:
• priority areas for future investment;
• funding allocations across ARC funding schemes; and
• committees that are needed to support the effective function of the ARC.

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?

AAMRI does not recommend that ensuring academic and research expertise is obtained and maintained to support the ARC is reflected within the Act. If a Board was to be established, this could be reflected in its terms of reference.

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.

AAMRI has condemned previous Ministerial decisions not to fund projects recommended by the ARC, and we consider this to be a significant risk to Australia’s international reputation.

However, AAMRI is supportive of the principle that when a Minister makes decision not to accept the recommendation of the ARC to fund a specific research project, the Minister should be obliged to provide reasons in detail to the Parliament about how they reached that decision and why the decision was taken. AAMRI recommends that these reasons should also be provided publicly.

Proper accountability and transparency should be ensured for any Ministerial decisions taken not to fund a recommended research project.

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

Benefit to the community should be defined broadly and include knowledge generation and fundamental discoveries as an explicit benefit of research. Fundamental, curiosity-driven research and knowledge generation is the engine that drives knowledge translation and applied research.

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

The ARC should seek to align its processes and practices with other major research funding organisations in Australia, so that researchers are not burdened by adapting their applications, track record information, biographical statements, and other information for different funding organisations.

This may include further utilising data-driven approaches, such as has been done with ORCID integration.

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.

Illogical ARC funding program rules are weakening our research effort by excluding some of Australia’s top talent

Issue:
Australia’s research effort is being undermined by ARC funding rules which are excluding some of Australia’s top research talent. This is occurring as eligibility for ARC grants is being determined not on the basis of the type of research being funded, but on the type of research organisation employing the Chief Investigator and administering the grant. Government research funding should be invested on the basis of quality, and not on the basis of arbitrary rules that prioritise one sector over another.

Background:
The funding rules for ARC programs only permit Higher Education institutions to apply for ARC funded projects (as per the Linkage Program Grant Guidelines (2022 edition) and the Discovery Program Grant Guidelines (2021 edition)). This restriction is excluding some of Australia’s best researchers, such as those employed by medical research institutes, from undertaking world class science that is in the national interest.

Australia’s research council funding system serves the nation well, with the NHMRC responsible for health and medical research, and the ARC responsible for all other areas of research. However, there are increasingly many areas of research that intersect with both ARC and NHMRC responsibilities.

There is also an increased need to undertake multi-disciplinary research to respond to grand research challenges. The ARC recognises this issue with its Medical Research Policy statement and provides clear advice on the areas of research the ARC will support, such as bioengineering, the natural sciences, and observational research.

This policy allows university based medical research institutes, departments or schools to apply for ARC funded research, and there are many examples where this is the case. The exclusion of medical research institutes within the ARC funding rules arbitrarily prevents many of Australia’s most exceptional researchers from pursuing research opportunities that fall within the ARC’s area of funding responsibility.

There are medical researchers at universities who hold both ARC and NHMRC grants concurrently in the following areas: immunology, reproductive biology, neuroscience, vascular biology, genomics, stem cell research, and public health research. Researchers at medical research institutes are excluded from this opportunity simply because they are not employed by a university.

This has led to researchers either abandoning or not participating in ARC funded projects or has forced some institutes and researchers to enter into convoluted employment arrangements whereby researchers are seconded to universities to allow them to work on ARC funded projects.

Impact:
Our national research effort is undermined when we exclude some of the world’s best researchers from Australian Research Council programs. Progress in fields such as immunology, reproductive biology, neuroscience, vascular biology, genomics and stem cell research will inevitably be slower and multi-disciplinary collaborations will be harder to pursue.

Recommendation:
AAMRI is not seeking any change in policy to the types of research funded by the ARC. We are seeking to widen the current restriction that only permits Higher Education institutions from hosting ARC grants.

Researchers at medical research institutes, and other organisations beyond universities, should be allowed to compete for ARC funding on the basis of excellence, rather than be held back by arbitrary rules.

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 provides an incomplete view of research excellence in Australia, as it is limited to research undertaken at universities. This excludes a significant portion of Australia’s research effort which is undertaken by researchers employed at non-university organisations, including medical research institutes, publicly funded research organisations like the CSIRO, and others.

Alongside the issue of limiting ARC grant funding eligibility to universities, consideration should be given to expanding the scope of the ERA to include research undertaken outside of universities. This would provide a broader understanding and more accurate representation of the true state of research excellence in Australia.

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?

Research Impact Framework:
In 2021 an expert working group funded by the Ian Potter Foundation and coordinated by AAMRI completed development of the AAMRI Research Impact Framework. This project delivered a standardised framework designed to enable Australian medical research institutes to measure the impact of their research and its contribution towards knowledge, society, health and the economy.

We believe this framework has broad applicability to many disciplines beyond health and medical research, and have made it publicly available.

The AAMRI Research Impact Framework report will be provided as an attachment to this submission for your information. It includes a range of impact indicators that may be used to assess research impact across outcomes including: advancing knowledge; research capacity building; informing decision making; health impacts; economic impacts; and social impacts.

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?

Unequal gender representation in the research workforce

Issue:
Gender representation in Australia’s research workforce is highly variable across disciplines, but on average men are significantly over-represented in STEMM disciplines.

This inequity undermines the excellence of Australian research, and feeds continued imbalances in power structures within the workforce.

Background:
The ARC’s own statistics show that, since 2011, the proportion of ARC-funded investigators in STEM disciplines that are women has been between 19 and 24%. While it is positive to see roughly equal success rates for applications submitted by both men and women, there clearly remains a major discrepancy in the number of applications received from women across STEM disciplines.

We believe the ARC has a critical role to play in advancing the cause of equity, diversity and inclusion across Australia’s research workforce. We note that the ARC has published the ARC Gender Equality Statement, outlining the issue and describing actions being taken in this space. We also note that the new Australian Research Council Strategy 2022-2025 does not explicitly mention the words gender, equality, or inclusion.

Recommendation:
AAMRI is calling for the ARC to make gender equity, diversity and inclusion across Australia’s research workforce a major strategic priority. This should specifically include consideration for non-binary and transgender researchers.

The ARC should seek to learn from the approaches of other organisations in Australia and internationally about how best to achieve a more equal, diverse and inclusive research workforce.

This should include approaches that acknowledge the need for greater flexibility in career paths, allowance for caring responsibilities, part time work, and career disruptions, as well as direct methods to improve equity of funding outcomes.

The ARC should also consider how the current paradigm of assessing research excellence contributes to the inequality observed in the research workforce.

These reforms would not only result in more equal gender representation in the research workforce, but will also benefit all researchers through greater access to provisions for caring responsibilities, more diverse career paths and outcomes, and a broader definition of ‘success’ for researchers.

Submission received

14 December 2022

Publishing statement

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