Go8 Submission: DET consultation on R&D income – Category 1 data – self-assessment to replace the ACGR

March 29, 2018

Thank you for your invitation, by email on 2 March 2018, to provide feedback on the Department’s draft guidance on Category 1 R&D income data collection with the move to self-assessment to replace the Australian Competitive Grants Register.

Please note this submission represents the views of the Group of Eight (Go8) network; member universities may also make their own, more detailed, submissions.

Decision to move to the ACGR

Go8 recommends that further detail be published by the Department on the rationale including level of support expressed by the sector to move from the existing ACGR to a self-assessment model. This significant change warrants appropriate transparency around the decision taken, especially as it impacts on resourcing in universities who must initiate processes to determine Category 1 income.

Go8 recommendations on draft DET guidance

Go8 recommends that DET undertake a review of the implementation of the new process, following the 2018 Higher Education Research Data Collection (HERDC) and the application of the first year of self-assessment by universities of Category 1 income. The review would help confirm whether there are appropriate levels of consistency in the way Higher Education Providers (HEPs) self-assess.

• The review would also provide an opportunity for DET to assess whether further guidance or finetuning of the process is needed.
• At a minimum, this review should occur once the current and final Australian Competitive Grants Register (ACGR) has lapsed – that is, five years from application of 2018 ACGR.

The Go8 further recommends that:

1. the schemes against which Category 1 income is reported by universities be published, preferably at the same time as the HERDC 2019 specifications are published.
2. the definition for ‘nationally advertised’ be refined to include awareness through the ‘use of any combination of direct ‘and indirect’ contact’, as researchers may become aware of national opportunities purposely or subsequently highlighted in specialised, local or university publications or other media.
3. DET guidance include a recognised subset of major Australian Government categories of grants that would qualify as Category 1, including specified NHMRC and ARC grants.
4. the Decision Tree include another checkpoint, at the top of the tree, seeking to know if the funds result from an ‘Australian’ grant.
   1. In determining the eligibility of new funding schemes for Category 1, it will be important for HEPs to understand what the meaning of ‘Australian’ grants for this purpose. This is not so far provided in the HERDC specifications, which currently refer to grants listed on the ACGR.
   2. ‘Australian’ should be defined in explanatory notes to specify if Australian (competitive) grants need to be from an Australian provider, solely for researchers in Australian universities, or other qualification.
5. ‘shared income’ be further defined, supplementing the definition in the HERDC specifications, for the purposes of this guidance – to clarify if it is only income shared between Higher Education Providers (HEPs) or if it can be passed from a primary business recipient to the HEP.
6. further guidance be provided on the level of responsibility of a HEP to ascertain if a ‘qualified panel’ was used in assessing applications.
   1. It is unclear that HEPs can indeed affirm that a qualified panel was used, given the details of the panels may remain confidential or only released after a significant period.
   2. The Decision Tree question could go instead to asking whether there is evidence that there is a well-defined mechanism for independent peer review or competition and selection by an independent panel.
   3. Guidance could be further added by a Frequently Asked Question on the degree to which the HEP is expected to affirm or determine the rigour of the competition or selection process.

Thank you again for the opportunity to comment on these proposed changes. Should you have any questions regarding this feedback, please contact Cheryl Kut, Go8 Research Policy Director, on 02 6175 0709 or at cheryl.kut@go8.edu.au.

Yours sincerely