Gwilym Croucher

Name (Individual/Organisation)

Gwilym Croucher

Responses

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.

Recent controversies for Australia’s system of competitive research funding have highlighted the challenge of the ‘fragile contract’ for science and research (Guston and Kenison 1994, 5). One of the elements that this tacit social agreement is usually taken to imply, is that for researchers to be effective, they must be trusted by community, government and nonexperts in how they use resources. This trust is fundamental to the operation of an effective research system as it helps resolve a friction between the legitimate desire for integrity, transparency and value for public money in granting processes, against ensuring that researchers can embrace their creativity, seek excellence and pursue discovery without unnecessary hindrance.

As the principal funding body for non-medical research, the ARC is central to how Australia has chosen to practically address the friction inherent in the fragile contract. Reflecting these challenges provides some pragmatic guidance to ARC programmatic and governance changes that can help maximise public resources for basic and applied research while ensuring that trust can be maintained.
This submission offers several considerations for governance reform that complement the discussion paper’s suggestion for a return to an ARC governing board, including around its remit and operation based on clear principles.

A RECONSTITUTED ARC BOARD WITH ADDITIONAL SPECIFICATIONS IN ITS FUNCTIONS TO THOSE OF THE PREVIOUS ARC BOARD:

The discussion paper sets out considerations for a renewed Board that suggests a further opportunity to clearly articulate some functions that go beyond those listed in the former version of the ARC Act which established the Board.

The Act is both specific on the purpose of the ARC (advice on financial assistance) while at the same time being broad and vague on its significant role (about matters related to research). In facilitating granting processes and providing expert advice on allocation and other matters, the ARC is a means rather than an ends, and its processes (chiefly providing funds) must be judged on how they enable research. It is widely accepted (and practiced in other jurisdictions) that the allocation of limited resources to enable research requires expert judgment and peer review (Auranen et al 2010; Geuna 2001; cf Fang 2011), and for example through policy that enacts the Haldane principle. This has direct implications for ARC governance and for research governance at a national level, where funding allocation is ideally based on expert judgment and peer review. ARC governance arrangements have a central role to play in this by ensuring that while discretion over resources must ultimately rest with the minister (and parliament), decisions over that investment that are crucial to enabling research and science need to be driven by those with the expertise to make informed recommendations.

• The functions of a reconstituted Board as set out in legislation should, in addition to “deciding the ARC’s goals, priorities, policies and strategies”, have explicit mention that it has a role in protecting and ensuring the role of peer and expert review, especially for the ARC’s role in providing funding advice to the minister.
• In fulling its functions and discharging it duty, the Board could be charged will the requirement that it should note the interests of researchers and the research community, as well as other stakeholders, much as corporate boards are responsible to stakeholders beyond shareholders.
• In reconstituting a Board and revising ARC governance, Section 52 of the ARC Act 2001 should be reviewed, to ensure that the Board has oversight of recommendations, e.g. 52 (2) and that 52 (4) be reconsidered to avoid a situation of funding veto, as has occurred recently.

STRENGTHEN THE STATUS OF THE ARC AND MAINTAIN IT AS A LISTED ENTITY:
The status of the ARC as a listed entity should maintained in change to the ARC and its governance. There is utility in the ARC as a statutory body, which by definition provides further independence from government, and suggests a specific relationship to parliament. Governance is a crucial issue here, one the one hand it helps define the separateness, noting that incorporation does not remove the body from the ‘shield of the crown’, or the implicit protection and responsibility of the Commonwealth. On the other hand, the ARCs status a statutory authority, especially where includes a renewed Board, itself is an important signal about the independence of advice provided by the ARC. A renewed governance relationship allows a clearer articulation of the balance between ministerial power and agency power, and could help ensure credibility in processes that promote transparency in funding pathways and responsibility over allocation.

GOVERNANCE CHANGES TO THE ARC TO PRE-EMPT DESIRABLE FUTURE CHANGES AT A NATIONAL LEVEL:

Changes to the ARC might ultimately align with desirable wider changes to national research governance where a transparent structure is implemented for priority setting for investment in science, research and innovation, that meets the needs of government but also meets the expectations community and industry. This should ideally be through an independent body, such as a national council for science and innovation led by a ‘Chief Scientist’ or similar, which supports existing and future capacity, and sits over and assists alignment of the ARC with other agencies.

At the national level priorities for investment in science, research and innovation that are set through the independent body, could drive allocation of all funding from a single, legislatively protected pool, in the form of an endowment, with the aim to ensure investment remains stable. The current governance arrangement for the ARC and for national research governance mean that priorities for the system will remain unclear. This requires a balance between government and authority, ensuring that those doing the research have ‘as much autonomy as possible at as low a level as possible’, while still meeting community expectations.

Auranen, O., & Nieminen, M. (2010). University research funding and publication performance—An international comparison. Research Policy, 39(6), 822-834.
Fang, H. (2011). Peer review and over-competitive research funding fostering mainstream opinion to monopoly. Scientometrics, 87(2), 293-301.
Geuna, A. (2001). The changing rationale for European university research funding: are there negative unintended consequences? Journal of economic issues, 35(3), 607-632.
Guston, D. H., & Keniston, K. (1994). The fragile contract : university science and the federal government. MIT Press.

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.

RECOMMENDATION: Seek a better balance between investment of researcher time and the allocation of public resource by introducing an expression of interest (eoi) process for major granting schemes that follows a clear set of principles and timelines.

WHY AN EOI PROCESS?
Fuller consideration should be given to how the granting process impacts researchers in unintended ways. That is, enabling research is a more expansive task than simply providing funds, even if this is in an efficient and fair manner. There is a trade-off between what is administratively possible and reasonably affordable, and cost when granting processes take away from research time and distract from others effort (especially where success rates are very low, as they are now). The challenge is to develop an ‘investigator first’ approach that seeks to prioritise researcher time and effort as much as allows the system to remain administratively feasible. Such an approach acknowledges the impact of research granting systems themselves on the research effort (Blcoh 2014; Hicks 20012; Horta et al 2008; Hottenrott & Lawson 2013; Hren et al 2022).

A two-step EOI approach seeks to judge the core idea first as part of the winnowing process, which frees resources for a detailed application assessment, including capacity and chance of successful delivery. It could focus on reducing the burden on applicants where demand for grants outstrips available resource, and explicitly trades off the added complexity that a two-step process implies.
Splitting out assessment of the project proposal can reduce opportunity for some bias and ensure good ideas have a better chance of a fair hearing, where unconscious discrimination against junior or inexperienced research teams may be at play. In this, it seeks to re-situate track record in assessment. It sends an important message that project quality is valued. It offers a deeper competitive and vetting process for the Australia public to be comfortable of successful completion. This is aimed at ensuring a more level ‘playing field’ across Australian research institutions.
The increased administrative burden of a two-step process can be in part offset due to a lower number of applications invited for full assessment. While not fully offset from the perspective of ARC resourcing and process, the benefits for researchers almost certainly would out way the additional resources required.

AN EOI PROCESS IN PRACTICE
While a two-step process with EOIs have been previously proposed to reduce the onerous task of writing applications, some principles and specifications are needed if they are able to achieve their stated goals of reducing the burden on researchers.

Several principles can guide the development of such a process. First, is the need to acknowledge the unavoidable resource trade-off that comes with a granting approach that is have the effect of further minimising burden on researcher time (eg Vaesen & Katzav 2017; Wang et al 2018). Second, that to ensure transparency, efficacy and fairness there are limits to how minimalistic and rapid any major granting process can feasibly be, and total process time will always be a ‘hard limit’. Third, it is crucial to recognise that in practice the granting process is jointly undertaken by both universities and the ARC, and so this must be made explicit in the design (such as where ‘culling’ processes should rightly be situated). Fourth, that the granting system must be able to reward the best projects and researchers, so must have some level of discretion.

From these considerations, a major granting process might have the following features:
• Take no longer than the current 9-12 months to complete.
• Enable some separation in the assessment of the core project idea, and assessment of its feasibility and likelihood of success.
• Ensure that for the majority that will not receive a grant, the process is not as onerous as a full application is at present.
• Ensure that assessment and administration is feasible.

A model that would contain these features might look something like the following:

1. Universities invite EOIs of 3 to 4 pages, which they will minimally assess (December)

2. EOI submission to ARC, due the end of February with university sign-off. It is focused on the core project proposal with only limited information on proposed time, budget and research environment. Potentially no ROPE or track record of team included at this stage to ensure a semi ‘blinded’ review.

3. First Assessment – project quality. Assessed by one external, and carriage through the current system internally (March-mid April).

4. Invite full application for high quality proposals (likely need to be a top proportion, eg top 20 per cent) by the end of June. Written feedback not provided but some indication of rank provided to applicant, potentially in a more detailed way than at present which provides little information.

5. Second Assessment – full evaluation through current process with detailed assessments due end (August). This would use the current assessment criteria.


6. Short rejoinder process as per current system

7. Award after panels meet and then announcements made (December)


Bloch, C., Graversen, E. K., & Pedersen, H. S. (2014). Competitive research grants and their impact on career performance. Minerva, 52(1), 77-96.
Hicks, D. (2012). Performance-based university research funding systems. Research Policy, 41(2), 251-261.
Horta, H., Huisman, J., & Heitor, M. (2008). Does competitive research funding encourage diversity in higher education? Science and public policy, 35(3), 146-158.
Hottenrott, H., & Lawson, C. (2013). Fishing for complementarities: Competitive research funding and research productivity. ZEW-Centre for European Economic Research Discussion Paper(13-113).
Hren, D., Pina, D. G., Norman, C. R., & Marušić, A. (2022). What makes or breaks competitive research proposals? A mixed-methods analysis of research grant evaluation reports. Journal of Informetrics, 16(2), 101289.
Vaesen, K., & Katzav, J. (2017). How much would each researcher receive if competitive government research funding were distributed equally among researchers? PLoS One, 12(9), e0183967.
Wang, J., Lee, Y.-N., & Walsh, J. P. (2018). Funding model and creativity in science: Competitive versus block funding and status contingency effects. Research Policy, 47(6), 1070-1083.

Submission received

14 December 2022

Publishing statement

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