July 25, 2022
25 July 2022
DESE Industry PhD Team
The Group of Eight (Go8), representing Australia’s leading research-intensive universities, welcomes the opportunity to provide feedback on the National Industry PhD Program Guidelines.
The Go8 is strongly committed to both research and research training, conducting $6.5 billion in research annually and in 2020 completed more than 4,300 PhDs comprising 50 per cent of the national total. The Go8 is also directly engaged with industry and in commercialisation activities, earning $1.2 billion in research funding from industry (Category 3) in 2020 – 71% of the national total – and nearly $100 million in research commercialisation income.
Consequently, the Go8 is closely aligned with the objectives of the Program, including supporting high calibre industry professionals to develop expert research skills and support the next generation of industry researchers and leaders. Only by increasing the absorptive capacity of industry for research and engagement with universities can Australia hope to create a step-change in the national capacity for innovation and commercialisation.
However, the Go8 has concerns about the technical and practical difficulties and complexities of running such industry engaged PhD models at scale.
The Go8 has four areas of overarching comment on the guidelines.
1 – Maintaining a student-centred focus as a research-training Program
While the objectives of the program are broadly to support the next generation of industry researchers and leaders and strengthen industry-focused innovation through greater university-industry collaboration, and more specifically support PhD candidates working with industry in their research, it is by definition a PhD program. The educational research training outcome for the student should be the primary objective.
The Go8 has concerns regarding the Termination provisions in Section 8 of the guidelines. In either the case of scholarship for the Industry Linked PhD Stream or Industry Researcher PhD Stream, if the industry partner ceases its business operation – beyond the control of the PhD candidate – the scholarship is to be terminated if the research project is not completed. Given the bespoke nature of the industry negotiated project and IP conditions, completing the specific research project may prove difficult under such circumstances and there should be greater flexibility afforded to supporting the student to the completion of a PhD.
2 – Preventing over-reach into university operations by the Service Provider
As noted above, the Go8 members complete over 4,300 PhDs a year – many involving industry engagement – and have well established and rigorous processes for managing all elements of a PhD. These include determining the suitability of research for a PhD, the alignment of the research with the university’s research interests, and the composition of the supervisory team. In Section 7.1 the guidelines explicitly provide for the administering organisation of the Program to make judgements on these issues in selecting projects for the Program and these provisions should be removed.
3 – Access to the Program by International students
The guidelines do not address the issue of whether international students will be permitted to access the program. In 2020 the Go8 completed nearly 2,000 highly quality international students in a postgraduate research degree and so there is capacity for international students to contribute to this program. This would serve to integrate high-achieving international students into the Australian economy and increase the chances of retaining talent in Australia – an ambition that has been articulated by the Minister for Education, the Hon Jason Clare MP.[1]
The Go8 recommends that the guidelines make explicit that international students are eligible to participate in the Program.
4 – IP arrangements
Determining Intellectual Property (IP) arrangements can be one of the more difficult and time-consuming elements of negotiating PhD projects with industry partners. As noted above, IP can also potentially complicate the possibility of PhD completion in the case where the industry partner ceases operation or withdraws from the Program. The guidelines do not reference IP arrangements and the program would benefit from the setting of parameters/expectations as to what is expected of university and industry partners (subject to further consultation).
In addition to these overarching points, more detailed questions and comments from Go8 members have been collated in an appendix to this submission.
The Go8 is prepared to facilitate discussions with relevant Go8 experts on the points raised below and provide further feedback to the Department.
Finally, the Go8 welcomes the opportunity for ongoing discussions with the Department on both the range of research training measures that Go8 members are implementing, as well as possible new models that deepen the engagement of PhD students and graduates with Australian industry.
Yours sincerely
DR MATTHEW BROWN
DEPUTY CHIEF EXECUTIVE
Appendix: Detailed comments and questions on the guidelines from Go8 members
- Eligibility
- Will International HDR candidates be eligible for the program?
- Will the RTP scholarship for the Program be awarded from a university’s existing RTP allocation?
- Guidelines note that candidates cannot have previously completed a PhD program at the time of application. It remains unclear if a PhD candidate is eligible if they have commenced a PhD program and, if this is the case, whether there are any limitations as to the remaining candidature time.
- Funding and Support
- Will universities be able to apply their own policies on indirect costs for industry contributions?
- Can a university provide training from existing suite of programs for industry collaboration to count towards the 12 weeks of training required?
- Is the mandatory 12-week training program required to be delivered in a block or can it be spread out across the duration of the PhD program?
- It may also be worthwhile to develop a course for the Industry Researcher PhD stream that focusses on the university side of the research ecosystem.
- Has any costing been undertaken to inform the appropriateness of the $10,000 annual payment to universities to fund the cost of engagement with industry?
- For the Industry Researcher PhD scheme, paying the Industry Partner subsidy to the university and requiring the university to pass on the subsidy to the Industry Partner is inefficient and puts an unnecessary burden on the university.
- Program Conditions and Rules
- Can the guidelines be adjusted to permit flexibility in time spent in industry and university to be decided by agreement between the parties without Government approval?
- Does embedment in the Industry Partner’s “setting” explicitly mean onsite? If the Industry Partner conducts all or most of their business remotely, will remote work fulfill the embedment requirement? What if the industry partner wants to utilise a lab or setting at the university? Do offshore settings fulfill the requirement?
- It will be important that the leave and other conditions of these scholarships are the same as those of other PhD candidates enrolled at the administering institution.
- Application Process
- More details on the EoI process would be appreciated, whether it will be time-limited or open, and the application data requirements.
- Selection Process
- As noted above, universities should have well-established processes to ensure that Section 7.1 of the selection process is satisfied.
- What assessment process and weighting will be applied to the selection criteria in Section 7.2?
- Termination
- There does not seem to be adequate consideration for the candidate in this process and termination of a scholarship due to issues beyond the candidate’s control. There needs to be protection of the candidate’s rights and their ability to complete their degree. An RTP scholarship has existing conditions, including different termination clauses.
- If the project has been co-designed with a particular industry partner, how can a different industry partner pick up the remainder of the project in a termination situation? This is a significant IP issue and there would be serious risk of legal consequences if this was required.
- Performance Reporting and Monitoring
- Will this data be collected centrally through the Tertiary Collection of Student Information (TCSI)? If so, how long will universities have to change their systems for a further amendment to HDR industry data collection?
- Will students in the Program be considered to have undertaken an industry internship for the purposes of weightings in the RTP allocation formula?
- The evaluation of Programs will be monitored according to the Program Guidelines. What will the criteria be? As universities are primarily responsible for ensuring quality of the award of PhD, will universities have a say to ensure they are satisfied with the monitoring?
- Attachment A – Program Roles and Responsibilities
- What type of collaborative agreement is intended by the guidelines, noting that it will have to sit alongside university policies that govern PhD admission, progress and examination? Will there be any direction on how IP and confidentiality (e.g., restrictions on materials that can published or included in the thesis) should be handled in the guidelines?
- Can a university use existing agreements for similar existing programs or will be there be a standard agreement for each stream of the program?
- Further consideration should be made regarding the activities undertaken by the service provider. It is critical that duplication of effort is avoided. For example, given that universities are best placed to monitor academic progress of their PhD students, it should be clarified what the third-party provider will monitor on an annual basis.
[1] For instance, see the Minister’s speech at the Universities Australia Gala Dinner: https://ministers.education.gov.au/clare/universities-australia-2022-gala-dinner