Response to Green Paper (Research elements) [DOCX 33.04KB]

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FINAL
University of Sussex
HE Green Paper Response: Research
January 2016
1.
This is the response of the University of Sussex to the research-related questions in the
Green Paper, ‘Fulfilling our Potential: Teaching Excellence, Social Mobility and Student
Choice’ (November 2015). It also takes into consideration the Nurse Review, ‘Ensuring
a successful UK research endeavour: A Review of the UK Research Councils by Paul
Nurse’ (November 2015), the Dowling Review, ‘The Dowling Review of BusinessUniversity Research Collaborations’ (July 2015), and the context of the Autumn
Statement and Comprehensive Spending Review (November 2015).
2.
In summary, the key elements are as follows:
a. The importance of retaining HEFCE’s organisational and sector knowledge, and
recognition of the relationship between research and teaching.
b. Integration and co-ordination of research and innovation policy and the bodies
responsible for it, coupled to the maintenance of the four strands of funding for
research and innovation.
c. The active management by institutions of research and knowledge exchange and
its quality should be expected in the context of the stewardship of public (and other)
funds; REF is one part of that active engagement.
d. The REF can be simplified, and should be based on the activities of a unit during
a census period, regardless of whether the individuals involved are present on an
arbitrary census date. This would remove staff selection, with all of the burden and
angst that goes with it.
e. Rationalisation of data collection, improvement of data quality, and maximisation
of data re-use are essential. Removing process steps and administrative
requirements (and variations) is crucial.
Question 24: In light of the proposed changes to the institutional framework for higher
education, and the forthcoming Nurse Review, what are your views on the future design
of the institutional research landscape?
3.
We welcome the recognition of the importance of the Dual Support system of funding
and the Haldane principle of decision-making, and wish to see both of these continued
and protected in any future framework.
4.
As noted, HEFCE undertakes important roles with respect to the support of research
and knowledge exchange, and contains substantive knowledge and understanding of
research at the organisational and sector level in subtly different ways from that of the
Research Councils, because of their particular focus. It is essential that the new
framework encompasses and does not dilute this system-level understanding.
5.
In the context of the Nurse recommendation to create Research UK, we believe that it
would be preferable to include the current research and knowledge exchange
responsibilities of HEFCE within that umbrella. The benefits of doing so would be to
encourage conceptual integration, enhance consideration of the whole environment,
and reduce alternative processes and reporting requirements. We also hope that the
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structure of Research UK will help to promote interdisciplinary research. There are,
naturally, some constraints and caveats, which are addressed in response to Question
25.
6.
We favour this integration over the creation of a new, separate body because the latter
would be relatively small and would potentially be isolated. Locating the function within
another existing body equally has the potential disbenefits of distance from the core of
research policy-making and funding that would be in Research UK. Locating the function
within BIS itself would also dislocate the function from other operational policy-making,
and possibly challenge the operation of the Haldane principle. We believe that operation
through an arm’s-length body is preferable for all concerned.
7.
We also support for similar reasons the Nurse recommendation that Innovate UK should
join the Research UK family. This should help to ensure a joined-up approach, and
harmonisation of processes, information flows etc. consistent with the recommendations
of the Dowling Review, which encourages better co-ordination of government strategy
on innovation. In this new location, there needs to be adequate attention given to skills
development and the movement of people, as well as to innovation through technology
development, translation and diffusion. Equally, ensuring engagement through large
and established firms is as important as through small and new ones in achieving
productivity improvement. As with our comments on HEFCE’s responsibilities, there are
similar caveats to this alignment, such as concerns about budget ‘leakage’ between the
strands of funding. We believe that there should be a presumption of harmonised and
common ways of working, with exceptions or variations where justified, rather than the
other way round. Echoing Dowling, we also believe that burden should be proportionate
to the size of funding.
8.
Nurse’s recommendation of the creation of a Ministerial Committee has the potential to
provide a joined up approach across Government R&D that is currently lacking. Whilst
there are a number of active and effective bilateral agreements between Research
Councils and Government Departments, it makes sense to have a co-ordinated
superstructure within which these are located.
9.
One important consideration of the proposed new framework that is not addressed in
the Green Paper is that of the relationship between research and teaching. The current
policy confluence within HEFCE helps to ensure balance. The proposed splitting of
HEFCE’s responsibilities hold the prospect of that understanding, and the benefits that
derive from the relationship, to be diminished, if not lost. Aside from the mixedmessages that could ensue, the sector and hence the UK could miss opportunities
where there needs to be combined action across the portfolio. Postgraduate research
sits squarely in this nexus, but the topic is not mentioned in the Green Paper at all, which
is surprising given the importance of higher-level skills provision. A number of
knowledge exchange activities are also good examples of the interface between
research and teaching, but it also applies to wider business, community and employer
engagement, which will typically be comprised of a combination of activities, outputs and
outcomes. These are areas where there is some differentiation across the sector, and
which responds to the Government’s interests in smart specialisation.
Question 25:
a) What safeguards would you want to see in place in the event that dual funding was
operated within a single organisation?
b) Would you favour a degree of hypothecation to ensure that dual funding streams,
along with their distinctive characteristics, could not be changed by that organisation?
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10.
As already noted, whilst we support the operation via a single organisation, as proposed
by Nurse, there are a number of provisions that need to be in place.
11.
The functions of RCUK and HEFCE have different geographical remits: UK and England
respectively. A body that is responsible for policy, activities and funding that are thus
differentiated will need to have appropriate and separate funding streams. This is not
only because of the span of responsibility, but also because of the related effects on or
of the budgetary arrangements for the devolved administrations.
12.
We believe that the same principles need to apply to the funding for innovation, as
allocated through Innovate UK. This is to ensure relevant protection of each strand of
funding, whilst encouraging integrated working under the umbrella of Research UK.
13.
We thus believe that the UK Government should allocate budget, via BIS, specifically to
each of the four strands of: institutional research and knowledge exchange block grants
(i.e. QR and HEIF); research projects and initiatives; innovation; and research and
innovation capital. They would need to be managed in concert by Research UK, but
each within their distinct envelopes.
14.
We also note the importance of the individual elements of QR as currently constituted:
mainstream, charity support, business support, and research degrees. The evolution of
these needs to be adequately considered, in particular how they make possible projects
and activities funded through a range of mechanisms from a range of funders, be they
governmental, business, or third sector, from the UK and overseas, as well as
institutionally-initiated activities. A naive view of the role of QR, e.g. purely to match
Research Council grants, would be highly damaging.
15.
The Dowling Review also notes the value of mechanisms such as KTP, CASE, HEIF
and IAA, which provide flexible and responsive means of supporting collaborative
arrangements. Our only note of concern in this respect relates to the restricted access
to some of these funds.
16.
Research UK’s potential for better co-ordination may be offset by the possibility of a
single dominant model of ‘excellence’ or ‘innovation’, which would thus reduce the
potential effect. Diversity in research (topics and approaches), structures, and
timescales all contribute to creating flexible capacity and responsive capability, which
are needed to address new and complex challenges. Structural diversity is associated
with innovative and impactful research outcomes, and hence needs to be actively
fostered.
Question 26: What are the benefits of the REF to a) your institution and b) to the wider
sector? How can we ensure they are preserved?
17.
The REF, and its predecessor RAEs, have provided substantial incentives to individual
institutions and to the sector more generally to understand and manage actively its
research. Through successive exercises, institutions have been able to identify
strengths and weaknesses as a consequence of the reviews that they undertake and
the benchmarking that the exercise provides. Many institutions have taken positive and
constructive action as a consequence of their improved understanding of their own
capabilities, addressing planning, staffing and infrastructure. To a significant extent,
these approaches and processes have become a regular part of the natural, active
management of research and knowledge exchange and its quality, which is what one
would expect in the context of the stewardship of public (and other) funds.
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18.
The reputational effects of the REF (at institutional and UK levels) has direct effects on
the attraction of people and funds. High quality researchers wish to work in the UK,
overseas institutions wish to work with UK institutions, and companies use the
information to identify collaborators and support investment decisions. The inclusion of
impact in 2014 has demonstrated the breadth and depth of socio-economic benefits and
value across all subject areas, in terms of public good as well as specific private good
(be that commercial or governmental). The inclusion of impact has also spurred
engagement, by individuals and institutions, and hence is helping to accelerate the
achievement of beneficial socio-economic outcomes. Impact is now becoming
embedded in research practice and institutionalised in policies and processes, such as
recognition and promotion criteria.
19.
Whilst the estimated costs of the 2014 exercise were considerably higher than the
estimate for 2008, partly because of the introduction of impact and measures to promote
equality and diversity, we also believe that the 2008 estimate was not calculated as
robustly as that for 2014. The increase is therefore more a consequence of policy
changes than institutional changes in behaviours. The relative size is also less than that
estimated for the Research Councils’ project-based processes.
20.
We believe that the objectives in the first paragraph of Chapter 2 of Part D remain valid,
and are required for future purposes.
21.
The Green Paper suggests the possibility of ‘refreshing’ the assessment results inbetween full reviews. This has some attractions, but would need to be compatible in two
key respects. First, the refreshed information needs to be compatible and consistent
with the results from the full review, otherwise there is a danger of unnecessary volatility.
This would include the effects of not covering all areas of the assessment, because they
were not amenable to a light-touch approach (e.g. impact, due to the lack of appropriate
metrics). Second, the refreshed information needs to be compatible with the funding
formula, so that updates can meaningfully be fed into the formula. The effect of these
may be to require changes to the full review process as well as to the funding formula
(noting also that the latter varies between the parts of the UK, and hence any changes
need to be compatible with each of the devolved administrations’ uses of the results).
22.
A further danger of having an intermediate review is that if the form of assessment is
sufficiently different from that of the full review, it would thus require institutions to
prepare for and manage two different processes. This is likely to create additional rather
than less burden.
Question 27: How would you suggest the burden of REF exercises is reduced?
23.
The burden of the REF might be reduced through a number of changes to its structure
and operation.
24.
REF operates through the assessment of a unit, not each individual nor the whole
institution as a single entity. It is an assessment of a unit’s performance in terms of its
outputs, impact and environment across the full census period, with an element of a
forward look in the environment statement.
25.
The 2014 REF introduced a decoupling between the impact cases and the staff
‘submitted’. This approach should be extended to outputs, which would address a
number of issues and mitigate concerns about the (perceived) transfer market effects.
The future REF should therefore include all activities in that period, from that unit,
regardless of whether the individuals involved are still in the unit on a particular, arbitrary,
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census date. There would thus be a consistent approach to all of the elements of the
assessment.
26.
With particular reference to the burden and other effects of staff selection:
a. Use the average FTE of staff on Research & Teaching contracts over a period to
determine the required number of outputs and the number of impact case studies.
HESA data could be used for this purpose. Senior independent researchers in
substantive posts might also be included in this figure, if their identification was
automatically possible from HESA data.
b. Select outputs to be reviewed on the basis of the unit where they were produced,
not on the basis of the current location of an author.
c. Allow the selection of the best outputs for the unit, rather than requiring selection
against an existing member of staff. For some types of outputs, this may allow for
a level of automation.
d. Use bibliometrics (where valid and appropriate) at the aggregated level of the unit’s
submission, not at the article level. This is consistent with expert advice that field
weighted and time normalised citation counts are more reliable at higher levels of
aggregation.
27.
The effects of a, b and c would be to remove staff selection. This would substantially
reduce both equality and diversity issues, and the burden of adequately addressing
those issues: reporting of individual circumstances would not be required because the
selection is of outputs, not of individuals. This would also remove the language of staff
being ‘submitted’ to the REF, which causes many of the negative side-effects of the
process. A further benefit would be not to disadvantage staff moving between HE and
non-academic organisations, or those ‘discipline hopping’ (as promoted by Dowling).
28.
Using the author’s location at time of publication would also make use of published
records easier, as the review would be based on the author’s attribution on the
publication itself. It would thus remove the need to match staff lists to authors, but would
require the publication’s author attribution to be accurate and complete. It might
alternatively be worth considering using location at time of submission or acceptance
(which is also relevant to the open access requirement), in order to reflect where the
work was actually undertaken, subject to that information being routinely and
systematically available.
29.
Selecting the best outputs for the unit correlates with the purpose being to assess the
unit, not the individual. In this context, one could choose to select an output that was
authored by someone who would have been ineligible in 2014, such as a postdoctoral
researcher or a postgraduate student, thus widening inclusion but preventing debates
about eligibility. The ‘eligibility’ of the author is less of an issue, because they are not
necessarily part of the FTE that drives the profile or the funding formula, but the output
is part of the research output of the unit.
30.
To promote connection to current academic staff (as used in the funding formula), it may
be appropriate to require at least one output from each member of staff in post on the
census date. However, this would entail an element of process burden, which may be
better omitted.
31.
With reference to the environment section of the REF submission, we believe that there
could be greater use of standard data to provide context. For example, using the profile
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of academic staff FTE (drawn from HESA) across the census period, to match the
profiles of research income and PGR degrees. We also believe that the impact template
should be incorporated into the environment template, as impact should now be part of
the institutional and unit environment.
32.
As a note of caution, we observe that the changes in income reporting required by
FRS102 could make research income figures incomparable both longitudinally and
between institutions. Other approaches to the use of research income data may
therefore be required.
33.
There may also be merit in considering an institutional level environment statement, to
cover generic issues, policies and approaches, which would otherwise need to be
covered in each unit submission. This may also be a way of being able to recognise
institutional responses to substantive policy requirements, such as research integrity,
equalities and diversity, staff development, open access, and infrastructure provision.
34.
Not all valuable impact can be encapsulated in the form required by the REF.
Constraining the form or type of representation of impact would narrow further the range
that could be assessed and hence valued. If we wish to encourage longer-term, larger
impacts, the complexity inherent in such outcomes will need to be represented. It may
be possible to standardise some elements of data collection associated with each case
study, noting that not all elements will apply to all cases. That could help comparison
and subsequent analysis, but will not affect the burden of production.
35.
We do not believe that there are a suitable set of indicators that would adequately
characterise the range of possible impacts and outcomes. The use of simple metrics
would be inappropriate as well as damaging. For example, world-wide, only about 3%
of patents generate any income.
36.
We suggest reconsidering whether the case studies should be tied to units of
assessment, or whether they should be related to broader categorisations, such as
economic, public policy, health, and so on. Whilst this undermines the argument about
assessment of the unit, it would better reflect the cross-disciplinary nature of the
outcomes of research, as evidenced in the 2014 case studies. Ensuring a reasonable
balance of contribution across all of the institution’s units would need to be addressed.
A first level approach might be to use the main panels, rather than the sub-panels as the
unit of assessment.
Question 28: How could the data infrastructure underpinning research information
management be improved?
37.
We support the recommendations of The Metric Tide report in respect of data
infrastructure for research. We also caution against the inappropriate use of some
metrics, and the reliance on other simplistic metrics just because they exist. A nuanced
approach to a set of indicators is required. A diverse research environment can be
inappropriately assessed by what are often discipline-based metrics, which thus
undermines the strength and flexibility of response that diversity represents.
38.
We wish to encourage the Government and its agencies along with other funders, the
publishers and research stakeholders to adopt unique identifiers (e.g. for people and for
organisations), and enable transferability of data and interoperability of systems.
39.
In particular, we support the report’s recommendation that ORCID iDs should be
mandatory, but we would reframe it to be for all staff with a research component in their
contract, and for all PGR students, rather than tying it to the REF. The need for and
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effects of such identifiers are wider than just the REF assessment process, and include
the project funding and output publication processes.
40.
There needs to be rationalisation of data collection, with promotion of re-use. The
relationship between HESA records, Research Council records, and the information
used for REF and other similar purposes should be improved. As examples, subject
classifications should be aligned, and the Research Council provision of information
about the use of shared facilities for RAEs and the REF, which has always been
problematic, needs to be systematised and made regular. Nurse makes an observation
about recognition for peer review service; at a practical level, the Councils could make
this information more transparent, and it could be a feed into the REF environment.
41.
The differences in definitions should be removed, and the data quality should be
improved. One might also ask about the relationship of these various records with the
ONS, and we would wish to ensure that the information captured as part of the science
and innovation audits are appropriately integrated into a single record.
42.
Nurse recommends the creation of a system encompassing all Government-funded
research, plus philanthropic and commercial research activities. We believe that this
would be a very substantive task, with associated risks, and that effort should first be
placed on existing records, as noted above.
43.
Nurse also makes an observation about usability and effectiveness of Researchfish, the
required reporting tool for the Research Councils and a number of other funders. We
support this concern, and further note that it is iniquitous for the Councils to require the
use of system for which institutions have to subscribe to a commercial company in order
to be able to use a half-decent interface because the standard one is inadequate.
44.
Part C, Chapter 1 makes reference to HESA collecting data and that the Office for
Students will in future be responsible for data. We hope that any changes driven by
student data requirements will not adversely affect research data collection and
provision, and that the relationship between the two areas will be borne in mind.
45.
We support the Nurse recommendation that the functionality of the Shared Business
Service should be more closely integrated under the auspices of Research UK, and
should continue to seek to harmonise and simplify the processes and systems involved.
46.
In supporting moves to enable compatibility and greater use of data, we are mindful that
institutional capacity in this respect varies across the sector, whether for financial or
technical reasons, or as a result of institutional balance of priorities. The Government
should therefore seek to ensure that infrastructure requirements are likely to be met by
the full range of institutions, so as not to exclude some for purely technical reasons.
47.
An additional area of concern is that in seeking to increase the use of data, the sector
could become overly reliant on a small number of commercial suppliers of information
and tools. This could become as costly as the internal processes that the Government
seems to wish to reduce, and have the potential to be constraining if those suppliers do
not evolve their products adequately to meet the Government’s and the sector’s
requirements.
48.
Aside from improvements in data infrastructure, we also believe that there could be
savings in operational costs and academic time through a range of relatively low-level
policy and process changes that, cumulatively, would have a substantial effect. The
Wakeham savings have been introduced as a mechanism to reduce the cash cost of
project funding to the Research Councils, but neither the Councils nor the sector more
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widely have addressed the efficiency of the underlying process and what they require.
The overhead costs of research are thus not necessarily decreasing, just because the
Wakeham formula has been applied. Some costs have shifted from one party to
another, but not actually been reduced. Indeed, overhead costs are increasing because
of some of the necessary and justifiable policies introduced by Government, the
Research Councils and other research funders, as well as the increased competition for
funding or to be published. Examples of such policies and processes are demand
management, research integrity, equality and diversity, research staff, public
engagement, open access, and doctoral training funding mechanisms. As Dowling
noted, the burden should be proportionate to the size of the funding.
49.
We are in danger of slipping back into the habit of ‘over-trading’, for which the sector
was strongly criticised by the then Government in the late 1990s and early 2000s. Aside
from the financial implications of over-trading, there are also cultural and behavioural
effects, because of the additional pressures placed on individual researchers, which may
lead to inappropriate practices or misconduct, which we are all seeking to reduce. There
are also negative effects on the quality of research and the resulting impact, and on the
quality of life and skills development of researchers.
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