9 August 2021
Ms Margaret Leggett
Research Policy and Programs Branch
Higher Education Division
Department of Education, Skills and Employment
Dear Ms Leggett,
The Group of Eight (Go8) welcomes the opportunity to provide input to the consultation on the 2021-22 Budget measure, ‘Growing industry internships for research PhD Students through the Research Training Program.’
The Go8, comprising Australia’s leading research-intensive universities, graduates a significant number of PhD candidates. In 2019, Go8 universities awarded 52 per cent of all domestic doctorates by research and 4,800 in total across international and domestic students. These graduates are trained in an environment which is both research-intensive and industry engaged. In 2019 the Go8 collectively earned over $1 billion in research income directly from industry – excluding government, 70% of the sector total.
This highlights the Go8 commitment to industry engagement in research and research training to underpin Australia’s future economy and why it considered it was vital to provide input to this consultation.
The Go8 is firmly supportive of the measure. However, the Go8 warns that it requires significant further detailed development to realise the ambition of both Government and the Go8 for enhanced engagement of industry in research training.
Consequently, the Go8 recommends that in initial implementation in 2022 that indicators are as inclusive and flexible as possible to allow for further development and avoid unintended consequences.
In the recommendations immediately below and in the discussion that follows, the Go8 sets out the issues it believes need to be addressed in designing an effective measure and to avoid unintended consequences that would work against delivering the intended outcomes of the policy.
In doing so, the Go8 seeks to engage with the Department to ensure that this policy delivers the best results in the national interest.
The Go8 recommends:
- The primary policy intent behind the measure must be to enhance the research training experience of PhD student through industry engagement. This must be alongside benefits to the research-end user/industry partner and desired employment outcomes. The policy’s success for both students and the nation does depend on such a priority.
- That the definitions of ‘research internship’ and ‘research end-user’ be refined to provide greater consideration of a PhD candidate’s circumstances. As it stands the proposed definitions for ‘Research internship’ and ‘Research end-user’ rule out PhD students undertaking an internship with an industry partner which does not ‘directly use or directly benefit from the output, outcome or results of the research’. As set out in our first recommendation, the primary purpose of HDR industry engagement is educational – to increase the research student’s career employability through the development of research and transferable skills. This must be a policy for the long term that prepares PhD graduates for a career of combining research and innovation in industry.
The Go8 therefore endorses the Australian Council of Graduate Research (ACGR) position which encourages DESE to accommodate as much flexibility as possible when deciding the types of HDR/Industry arrangements that will be eligible for the RTP funding uplift. Specifically, the ACGR recommends that ‘non-cognate’ internships (those on topics not directly related to the student’s research discipline) should be accommodated. It also argues that ‘cognate’ internships (those directly related to the student’s research discipline), whether undertaken with the core or a different industry partner, should be eligible because of the significant benefits that can still flow to both the student and the industry partners. As this goes to the heart of how the policy can be successful to the nation it is a view held strongly by the Go8.
- In shaping the policy, Government, together with universities, must consider the industry ‘pull’ factor. This ranges from filling immediate skills/research capacity gaps to establishing early pathways for longer term careers seeking to build a workforce with high-level research skills. This will impact on the design and required characteristics of the internships.
- Flexibility is essential in the timing and length of the internships so that industry needs align with greater benefits of mature entry into an internship. The rigidity of the proposed requirement that students must commence their internship within 18 months of enrolment is concerning. It risks unintended consequences. These could include, for example
- discouraging other forms of valuable HDR industry engagement including in settings not directly related to the student’s research; and
- providing an incentive for universities to bring forward the start date for internships to meet the eligibility requirements, even when this may not be the best timing for some students – both in terms of educational benefit and their personal circumstances – or the industry partners needs.
Maximum flexibility as to timing is therefore critical.
- That the change be refined to take into consideration existing research training internship programs whose internships may be excluded otherwise as non-eligible. For example, Research Masters student internships may not have been included in the Government’s RTP funding change proposal. The exclusion of Research Master student internships should be reconsidered as a short HDR award with an internship will be attractive to some industry partners, students, and universities – especially those seeking to shift to a condensed Research Masters as a preparatory pathway to a PhD.
- The explicit exclusion of MRIs from the definition of ‘Research end-user’ should be reversed as it will likely have significant negative impact on industry engagement. While we note that this definition has been in place for HDR engagement data reporting since 2018, the Go8 recommends strongly that it is revisited, at least for PhD students based in MRIs (many from the Go8) whose research is being funded or otherwise undertaken in collaboration with an industry partner that meets the Department’s definitions.
Discussion and additional detail
As noted above, the Go8 has a strong track record in industry engaged research training. The Go8 has trained many highly successful industry leaders and future-thinking entrepreneurs including Magellan CEO Brett Cairns (University of Sydney), WearOptimo CEO and former Vaxxas CEO Mark Kendall (PhD in Mechanical Engineering from the University of Queensland), Rob Newman MD and CEO, Nearmap (PhD in Computer Networking, University of Western Australia), Anastasia Volkova, CEO Regrow, CEO FluroSat (PhD in Aerospace, Aeronautical and Astronautical Engineering, University of Sydney).
As the Department is aware, the Go8 deeply values what PhD students gain from joint activity, including joint projects and supervision but makes the point that is it critical when formulating policy on industry internships that significant consideration must be given to the fact that the average age of students starting a PhD in Australia is 32, with 56 per cent starting in 2019 being 30 years or older. They are not school-leavers and in policy framework terms, decisions should be avoided which fall into the trap of treating this component of their study as if they are.
Many are already well-embedded in industry, with existing career pathways – as one example Andrew Forrest, Chairman and former CEO Fortescue and now with the Minderoo Foundation. Maturity, position on a career pathway, and in fact positions already in industry-sponsored PhDs require consideration. The Go8 therefore does not consider a one-size fits all approach can work and in fact may be detrimental rather than positive.
Just as Australian industry needs to flexible and fit-for-purpose to compete in the modern global economy so does the engagement of research training with industry. In this context, the Go8 offers the following further detail on specific elements of the RTP measure.
Timing of internship
Insufficient evidence is provided to support the premise that internships beginning early in a research PhD student’s degreehelp students build strong industry-relevant capabilities and enable their research to be shaped by current and future industry needs.
Conversely the first 12-18 months of study can bring significant pressure to the student from research intensity and expectations, just when they are establishing key relationships with supervisors and mentors and seeking to initiate key research activity such as data collection. Within 9-15 months PhD candidates must be reviewed to see if their project is viable and that they are on track and/or pass their confirmation (i.e. demonstrate that they can complete their candidature) depending on university and faculty.
Nor is it demonstrated that industry would be prepared to accept PhD students at such an early stage of their training and development, nor that this approach would persuade industry stakeholders to readily seek and employ PhD candidates upon their completion. Vitally, if a company’s expectations of a PhD candidate are higher than could be reasonably expected at such an early stage, this could very well be a set-back to the company’s willingness to engage with researchers or universities.
The Go8 would urge that this requirement not be absolutely exercised, and that the Department provide for certain internships starting outside this period to be counted as eligible. These would include but are not limited to
- completion within a certain timeframe linked to the final date of candidature.
- availability of an attractive internship later in the candidature.
- consideration of internships affected by seasonal factors, such as agricultural placements.
- when formalities or milestones of the internship agreement were unable to be concluded in the first 18 months.
- ensuring the industry partner’s desired benefits from the collaboration, including specific skills, are available at the appropriate point of the company’s project.
Further clarity is needed in the eligibility condition that the internship must be completed within 18 months:
- whether the stipulation refers to 18 months of elapsed time from commencement of candidature or 18 months of FTE candidature from commencement.
- whether any periods of enrolment suspension such as sick leave or other leave of absence are accommodated in calculating which internships are eligible.
The COVID pandemic has highlighted the significant unforeseen interruptions to university student schedules, and a range of factors that influence the availability of a PhD student for an internship within a prescribed period. These can include critical fieldwork or observations and an industry partner’s timing requirements
Length of internship
The required length of an eligible PhD internship of three months or 60 FTE days is yet to be tested but does seem workable. However, it must be taken into consideration that different circumstances affecting students in different disciplines do mean a three-month continuous period could cause difficulties. Flexibility is needed so that a shorter continuous period with the 60 days broken up sensibly can be implemented.
As it relates to the calculation of 60 FTE days, the Go8 agrees with the ACGR that the proposal to count and report “days of engagement with research end-user” is unrealistic for graduate research candidature. It appears to assume attendance on-site and individual full days of engagement. The Go8 agrees these definitions be refined to acknowledge the likelihood of virtual and/or part-time internships that are not necessarily undertaken in discrete blocks of time. Therefore:
- flexibility should be provided for the internship to be over separate periods (the number of periods to be pre-defined) as needed by the industry partner rather than in a single block. The gamut of possible options including block intensive or flexible, part-time, over time, should be accommodated when the Department identifies eligible internships.
- Serious consideration should be given to whether a shorter internship may in some circumstances yield greater opportunity or greater potential of meeting the Government’s stated policy and the candidate’s development needs – whether quality may outweigh quantity
Definition of research internship
The Go8 emphasises the diversity of the PhD candidate cohort, including the later average age at which these students begin their PhD (32 years in Australia). In many cases, this means that a candidate is already employed while studying. A variety of other circumstances may apply. For example, the student may be fully engaged in an industry sponsored PhD, be funded under an industry scholarship, be a participant in an industry PhD program, be employed in a Government organisation, or be engaged in a university spin-out, all of which may be aimed at achieving similar outcomes to the Government’s aspirations for the ‘research internship’.
The Go8 would also caution against the measure placing undue emphasis on building immediate employment pathways as the chief benefit/outcome for the research PhD student. While employability is of course an important aspiration, the learning and experience for the student should be valued. The aim should be to explicitly enhance their skills to boost their career employability overall, whether through practical application of their research knowhow or through additional workplace ready attributes.
‘Research internship’ should be more carefully described to accommodate the variety of such circumstances and others in which the university may be supporting the student to acquire or remain connected to other sources of experience in industry settings.
Definition of research end user
The requirement that the researcher end user ‘directly use or directly benefit from the output, outcome or results of the research’ is inherently problematic, given the challenges in ascertaining or measuring whether the end-user does indeed benefit from the research.
The specific exclusion of all affiliates (including affiliated Medical Research Institutes) would severely hinder logical and expected career pathways for PhD students, noting that many such affiliates are large hospitals, companies or other such entities.
Further clarification of the definition of research end-user to specify what is precisely meant and intended by ‘directly benefit’ is essential. Importantly, as the Go8 recommendations set out, further discussion needs to occur before MRIs are excluded from the definition of research end-user, given the huge potential for these organisations to provide the necessary practical and industry-focused settings for biomedical students.
Impacts on certain student cohorts
The Go8 cautions against unintended consequences for certain cohorts of PhD candidates, such as mature HDR candidates with children, or other caring responsibilities, who may require flexibility in relation to the timing of their candidature. Also, there would need to be sufficient flexibility in the measure to support and consider part-time students.
The Go8 has identified some potentially unforeseen consequences:
- The measure may lead to universities investing more resources into the establishment of scalable internship programs, adding significant operational costs to the sector, without increasing the overall number of national PhD completions.
- Universities may seek to remunerate industry to provide more internships for students.
- Internships may potentially be more accessible for high-cost STEM students rather than low-cost HASS students, creating additional disincentives or barriers to HASS PhD candidates.
- Students may be offered employment and seek to discontinue the PhD, creating perverse outcomes given both the possible wastage of RTP stipends to that point and undesirable impact on the RTP allocation to the university.
You will note that the Go8 has not responded according to the prescribed survey format, which was set out only for use at individual university level. Given our role in graduating more than half of the nation’s domestic doctorates by research we considered it was vital to provide input and hope it is of use in assessing answers to the questions provided. Please feel free to contact me or our Director, Research Policy, Cheryl Kut, should you wish to discuss further.
 In total, in 2019, the Go8 provided 28 per cent of all domestic graduates from Australian higher education institutions across all levels of course from undergraduate to higher doctorate.
 Department of Education, Skills and Employment (DESE) 2020, Higher Education Statistics Commencing Domestic Students by Age Group and Broad Level of Course, Full Year 2019
 For instance, the study referred to in the paper by F Valencia-Forrester was based on seven interviews with PhD students at a single university.
 See, for instance, the Nature study on graduates (https://www.nature.com/articles/d41586-019-03459-7) that discusses the impact on mental health
 A student working in a university spin out may be outside scope unless spin-out is seen for the purposes of the definition of research end user as outside academia
 Indeed, AMSI’s submission to this consultation (accessed at https://amsi.org.au/wp-content/uploads/2021/08/rtp_submission_amsi_final.pdf) notes that ‘APR.Intern program has also been able to create a pathway to employment with 22.5% of internships’ suggesting that employment cannot be the sole or even chief indicator of success, given the 633 internships under the program to date (2017-2021), of 3 to 6 months duration.