(Edited by Cosmos for length and format, please read the full submission, details below)
The Australian Academy of Health and Medical Sciences welcomes the opportunity to
respond to Department of Education’s review of the Australian Research Council. We are
Australia’s Learned Academy for health and medical sciences – the impartial, authoritative,
cross-sector voice for the sector. We advance research and innovation in Australia to
improve everyone’s health.
We are an independent, interdisciplinary body of Fellows – elected by their peers for their
outstanding achievements and exceptional contributions to health and medical science in
Australia. Collectively, they are a representative and independent voice, through which we
engage with the community, industry and governments.
This response has been informed by contributions from Fellows and Associate Members of
the Academy as well as other experts. We are grateful for their valuable contributions.
Q1. How could the purpose in the ARC Act be revised to reflect the current and future
role of the ARC?
To ensure we keep pace in an increasingly competitive global landscape we must now re-evaluate our goals and enhance the system so that the success can continue. By doing so we can grow and
nurture Australia’s research and innovation landscape for the benefit of the whole
At present, the functions of the ARC, as specified in the ARC Act, do not state its role in
influencing and being responsive to the broader ecosystem. The Act could better
acknowledge this as an important role.
An important first step would be to better align our major federal research
funders – particularly the ARC, the National Health and Medical Research Council (NHMRC)
and the Medical Research Future Fund (MRFF).
This would also benefit Australia’s standing as an influential research nation on the global stage – allowing us to attract the best talent and collaborate internationally for global good. However, the ARC Act does not currently specify the ARC’s role in this regard.
In addition to the high-level suggestions above, we suggest that as the Panel works to define
and clarify the functions of the ARC, the Panel should consider the following issues:
• Interdisciplinary research: At present, the ARC is the major funder of interdisciplinary research in Australia however, there are significant structural barriers that prevent this type of research and innovation from flourishing. For instance, some programs lack a mechanism to assess grant applications between grant panels. Some researchers we heard from in developing this response described feeling disheartened with the process for submitting interdisciplinary applications.
As the global research community moves towards greater interdisciplinarity, Australia
must actively facilitate this type of research, or we risk falling behind.
• Balance between discovery and applied research: There is no individual or
organisation that can predict where the biggest impact from research and innovation
will come from. Curiosity-driven research that is borne out of genuine intellectual
freedom, and critical appraisal by colleagues, has led to some of the world’s most
important discoveries that have in turn shaped the world in which we live. The ARC plays a vital role in supporting discovery research. As the Panel reviews the ARC’s funding distributions as part of
the Act, it should be made clear that funding should better support basic research, for
which the potential applications may not yet be known.
Q2. Do you consider the current ARC governance model is adequate for the ARC to
perform its functions?
The ARC should be led and underpinned by the best, most appropriate academic expertise.
Robust governance that harnesses diverse and high-quality research expertise would improve
the ARC’s strategic direction and better enable effective decision-making. As highlighted in
our response to question one, the ARC also exists within a broader ecosystem; expertise
from outside research could be incorporated into the governance structures to promote a
wider range of perspectives.
Q3. How could the Act be improved to ensure academic and research expertise is
obtained and maintained to support the ARC?
The ARC has a strong reputation for utilising high quality and transparent academic and
research expertise. However, there are still several barriers to attracting and retaining this
expertise to support the ARC as it works to advance a thriving research and innovation
system in Australia. Although the ARC has a strong peer review process, in preparing this
submission, we heard about particular issues that could be addressed to make the system
more robust and consistent. For instance, within the current mechanisms, lead peer reviewers
are sometimes asked to comment on, or decide the outcomes of, applications for which they
do not have relevant expertise. The ARC should continue its efforts to ensure it has a pool of
reviewers with the necessary expertise to review the wide range of applications it receives.
There may also be an opportunity to develop more effective matching of reviewers and
Q4. Should the ARC Act be amended to consolidate the pre-eminence or importance of
The ARC has an important role to play in upholding the pre-eminence of the peer review
process in the determination of research funding. The Academy released a joint statement
with the other Learned Academies and the Australian Council of Learned Academies in
February 2022 cautioning against compromising the integrity of Australia’s research system
through perceived, or actual, political interference.
Although the Federal Government is responsible and accountable for the expenditure of
taxpayer funds, decisions to veto grants that have been approved through the ARC’s peerreviewed process – without expert consultation, detailed feedback, or option to appeal –
should not occur.
The Academy supports a change to the ARC Act in line with international best practice to
protect the pre-eminence of peer review in the determination of research funding. This
should be explicitly stated within the Act and in circumstances where the Minister does not
solely rely on recommendations made by the CEO following peer review, the Act could
ensure greater transparency and accountability around this decision-making.
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 Academy welcomes the recent announcement regarding the changes to the National
Interest Test (NIT) process. We hope these changes will be an important first step to
addressing the significant issues around the NIT as they stand. In developing our response to
this consultation, we heard that the NIT does not adequately fulfill its stated purpose to
entrench and enhance the social licence to provide public funding for research through the
ARC. In addition, as noted in the review consultation paper, the grant application selection
criteria already assess the value and potential benefit of research to the community – and this
is reviewed at multiple points throughout the process. This duplication of effort for the same,
or similar, purpose is placing an unnecessary burden on researchers.
The NIT process is subjective and does not appear to be applied consistently, creating
It is important to strengthen the social licence for publicly funded research. We also strongly encourage the utmost transparency and accountability in the assessment of national interest.
Q6. What elements of ARC processes or practices create administrative burdens and/or
duplication of effort for researchers, research offices and research partners?
In developing our response to this consultation, the researchers we heard from reinforced the
feedback received by the Panel, noted in the consultation paper, including:
• Onerous requests for information, including duplication:
• Unexpected changes to grant rules and deadlines:
• Prescriptive financial requirements:
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?
As highlighted in our response to question one, in a globally competitive environment, the
ARC must see itself as an international collaborator to ensure it continues to advance
Australia as a truly global player in research and innovation. It is crucial that the ARC engages
with its counterparts overseas and with international funding networks.
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
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 Academy supports the use of data-driven methodology to assist with evaluating research
excellence and impact. However, we urge the Panel to consider that data-driven methods
alone will not be sufficient for this purpose – such as using citations to assess research
impact. These methodologies have some limitations, including the inability to discern a
citation in support of a publication from a citation that is more critical of a publication. There
are also known biases in citation, such as gender and other biases that could influence
evaluation outcomes. Journal quality rankings also have limitations, such as how the data
provider defines a research grouping. This has the potential to make things more challenging
for interdisciplinary research.
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?
• Diversity and inclusion: The Academy suggests that the ARC could play a bigger role
in promoting and advancing diversity and inclusion in the research and innovation
workforce in Australia – for instance in gender equity and Aboriginal and Torres Strait
Islander led research.
• Early- and mid-career researchers: While the Discovery Early Career Research Award Scheme (DECRA) aims to support early- and mid-career researchers, The Academy understand that the majority of applicants, successful or not, are more towards the middle stage of their career.
This has affected the opportunities for early career researchers, limiting their ability to receive the
necessary funding to produce high quality research and advance their careers. In
addition, there are several similar gaps in the ARC’s suite of fellowship support, which
has the potential to affect the pipeline to future research excellence in Australia.
• Transparency and feedback for grant applications: One of the key benefits of the
peer review process is that feedback can be used to improve future applications. We
heard from researchers that they would benefit from greater transparency in how
their applications are assessed and more opportunities to receive feedback.
• Medical research institutes: At present, medical research institutes (MRIs) are not
eligible for ARC funding. MRIs contribute to important basic and interdisciplinary
research. While it is not the ARCs role to fund medical research, it could work more
closely with health and medical research funders to ensure better mechanisms for
involving MRIs in ARC projects where appropriate.
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Originally published by Cosmos as Australian science review – Australian Academy of Health and Medical Sciences
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