Category: Submissions

Research Australia’s Pre Budget Submission September 2022

Research Australia’s submission ahead of the Alabnese Government’s first Budget, to be handed down in October, acknowledges the large debt the Government is faced with. In keeping with the Government’s objective to fund activities that will boost productivity, we have outlined how investing in health and medical research can help grow Australia’s economy and provide well paid jobs, now and for future generations.

We have reiterated the need for a National Health and Medical Research Strategy and for a research workforce plan to support this objective.

Research Australia’s submission is available here.

Draft Data Code must provide more guidance

Following passage of the Data Availability and Transparency Act earlier this year, the National Data Commissioner has now released a draft Code of Conduct to provide further guidance on how to apply the data sharing principles, privacy protections, the public interest test and ethics requirements, as well as data sharing agreements.

The definition of ‘data project output’ continues to be problematic, with the terms ‘output’, ‘final output’ and ‘use of a data output’ all used ambiguously. It appears there are some circumstances in which the use of a data output is itself a data output and others where it is not, but the distinction is not clear. This is important because data outputs are regulated by the Act and the Code.

Research Australia’s submission addresses this issue and a number of others, including the public interest test and the circumstances in which designated persons need to be identified in a Data Sharing Agreement.

The final Data Code was published on 16 December 2022 and is available here.

Enabling the ARC Industry Fellowships Scheme to work for HMR

Announced in February this year, the ARC Industry Fellowships Scheme is intended to support all of the Government’s strategic target industries, including medical products.

Research Australia believes that the Scheme is at risk of failing to meet its objective of supporting the strategic area of Medical Products unless some form of exemption from, or relaxation of, the ARC’s Medical Research Policy is applied to the Industry Fellowships.

This issue has been raised by Research Australia in ARC consultations on the guidelines for the new Scheme and in a formal submission to the ARC. The submission is available here. 

Changes to RBG formula opposed by Research Australia

Research Australia has opposed the Government’s proposal to alter the formulae for calculating Research Block grants to universities as a means of incentivising greater engagement with business. Research Block grants consist of two programs provided by the Department of Education. The Research Support Program provides funding to universities relative to the research revenue they receive from different sources: government, business, not for profits etc. The Research Training Program funds the stipends and research costs of students undertaking Masters Degrees by research and PhDs.

The Government has proposed increasing the proportion of funding tied to business research revenue and reducing the proportion of funding tied to other research revenue.

Research Australia has opposed this measure because the most recent data shows that business funded research increased by 15.5% between 2018 and 2020, and basic research (usually funded by governments and universities themselves declined by 11.3% over the same period. Research Australia is concerned that simply changing the formulae rather than providing more block grant funding will further reduce basic research at a time when business research funding is already increasing.

Read Research Australia’s submission here.

Regulating AI and ADM in healthcare and HMR

The scope for the use of Artificial Intelligence and Automated Decision Making is only limited by our imagination. In responding to the Government’s Issues Paper on the regulation of AI and ADM, Research Australia has expressed the view that AI and ADM in healthcare and health and medical research need to be subject to regulation which can cover potential future applications and adapt and develop as AI and ADM change without requiring constant revisitation of the framework.

Research Australia believes the existing regulators and responsible agencies are best placed to regulate the use of AI and ADM in healthcare and in health and medical research and innovation. While a robust national safety framework with common principles is required to guide regulators and promote consistency, existing regulatory bodies should be appropriately resourced to ensure they have the capacity to effectively regulate and support the implementation of AI and ADM now and into the future within their own areas of responsibility.

Read Research Australia’s submission

Draft National Medicines Policy acknowledges research is key

Following on from our submission last year to the Discussion Paper, Research Australia has welcomed the acknowledgment of the importance of research in the new draft National Medicines Policy (NMP). Research Australia has used our submission to highlight further areas under the policy’s pillars where research can play a critical role, and has called for a dedicated stream of funding for research to support the Policy’s implementation and objectives.

Research Australia believes the Governance and Implementation sections of the draft policy need more work and has joined with the medicines sector and consumer groups to call for further consultation before the NMP is finalised. The Government has now heeded this call, with the Minister for Health announcing on 23 March that there would be further consultation before the Policy is finalised.

Read Research Australia’s submission here.

The 2022 National Medicines Policy was subsequently published on 20 December 2022, and the role of research is recognised in several areas, including as an enabler of the Policy. The Policy is available from the Department of Health’s website here. 

Research Australia supports ARC’s independence

The Senate Employment and Education Legislation Committee is undertaking an Inquiry into the Australian Research Council Amendment (Ensuring Research Independence) Bill 2018, which lapsed when the 2019 election was called and has recently been revived. The renewed interest has been prompted by the decision of the acting Minister for Education to reject some proposed ARC grants in December 2021.

As stated in the Bill’s explanatory memorandum, ‘The intent of the Bill is to remove Ministerial discretion from research grants administered by the Australian Research Council (ARC).’   While Research Australia accepts the right of the Government to set the criteria for research funding programs, including the eligible applicants and research areas, and the amounts of funding available, Research Australia does not believe the Minister should have the power to refuse to fund individual research proposals that are recommended by the CEO of the ARC under an approved funding program.

Research Australia’s submission is available here.

The Senate Committee’s report was released on 21 March. The majority report, by ALP and Coalition Committee members recommended against passage of the Bill. The report is available here. A dissenting report from the Australian Greens senators is available here.

2022-23 Pre Budget Submission- a way forward

Research Australia’s 2022-23 Pre Budget Submission acknowledges the COVID-19 pandemic has had an enormous toll on the Australian community and globally, but also recognises that as a consequence of the way Australian governments and the community have responded, the impact in Australia has been comparatively mild.

Australia’s response to COVID-19 has been so broad and deep because of previous investments in the nation’s research and innovation capacity. This capacity, and the funding that underpins it, cannot be taken for granted. There is no guarantee that Australia’s health and medical research and innovation community will be equally well placed to respond to a future pandemic.

Research Australia’s submission makes the case for why maintaining and expanding this existing capacity for health and medical research and innovation is in the national interest.

In addition to raising national prosperity and diversifying our economy, smarter investment in health and medical research and innovation can improve the effectiveness of our health system; constraining the rise in health costs that accompany an ageing population. It can also provide a sustainable pathway to addressing modern lifestyle factors such as obesity. Smarter investment also drives skilled employment in vibrant new pharmaceutical, medical device and biotechnology industries.

Research Australia is advocating for an overarching national health and medical research strategy which ensures smarter, coordinated, strategic public investment in all stages of research; maximises impact on national priorities such as burden of disease, and the stronger translation of evidence-based research into healthcare delivery; and exploits areas of international competitive advantage. Imagining and preparing for the Australia we want in 50 years’ time has to start today.

Research Australia’ s submission is available here.

Privacy Act Review- implications for research

The Attorney General’s Department is currently undertaking a review of the Privacy Act 1988. Several of the proposals for change to the Act, including introducing the concept of anonymisation, have implications for research, but the Discussion Paper  does not directly include the way the Privacy Act affects the use of information for research purposes.

Research Australia’s submission highlights these areas and proposes that an expert group  be formed specifically to work on the redevelopment of the NHMRC guidelines in parallel with drafting of proposed amendments to the Act.

Research Australia’s submission is available here.

The Review has been completed and the findings are expected to be released in the first half of 2023.

 

Research must support Primary Health Care 10 Year Plan 2022-2032

Research Australia’s response to the Department of Health’s consultation endorses the direction of the draft Primary Health Care 10 year Plan and welcomes its recognition of the key role research can and must play if reforms are to be achieved. Research Australia has  recommended a sustained investment in translational primary care research that is commensurate with the reform task outlined by the 10 Year Plan.

Research Australia has recommended the creation of an Institute for Primary Health Care Translational Research and Innovation and we have outlined in our response to specific questions the critical role this Institute could play in the implementation of the 10 Year Plan. We propose the development of a primary health care research agenda, supporting each action area of the 10 Year Plan. The Institute would be responsible for delivery of this research agenda.

Read Research Australia’s submission here.