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Public Consultation on the NHMRC Draft Principles of Peer Review submission

This submission reflects the views of
Individual Background: 
Researcher – biomedical
Personal Details
First Name: 
Last Name: 
General Comments




Firstly, I would like thank the NHMRC for the opportunity to comment on their peer review process in an open consultative manner.  I provide my response relative to each of the Section headings of the Open Consultation document. 


 (1)   Principles of Peer Review

Whilst it is recognised, but not stated, that the Principles of Peer Review applied to all facets of the Peer Review process, this is not fully articulated in the current guidelines which focus primarily on the Assessments and Peer Review Panels, but is relatively silent on Peer Review and Conflict of Interest issues of the Research Committee as well as Council which are dealt with quite appropriately within the processes of NHMRC at current stages.  It would be more appropriate to have an explicit comment that the Peer Review guidelines are operative over the full remit of people involved in the Peer Review from applicants’ Assessment reports, GRP members, Chairs, Observers, Members of Research Committee, Council as well as the Minister of Health who has declared any conflicts of interest or notification of grants being awarded within her electorate.  This would signify the extent and breadth of the Peer Review guidelines and how it can impact upon not only Research Community, the Office, but also ministerial appointments.


(3)  Independence
  The 3rd dot point - Peer Review Panel Chairs.............:  This should be reworded to clarify the role of the Chair.  Suggested text would be “Peer review panel Chairs are independent of the review process - they are not involved in the Peer review of any application before that panel, Subscript 6”.  The rewording of this sentence implies that they are independent of the Review process as opposed to them being “independent”, something which currently lacks clarity in the research community.
b.  Dot point 2 currently reads: “Assessment reports provided by reviewers are not amended by NHMRC staff or members of Peer Review Panels”.  This comment may need to be refined to include any comments which may be considered inappropriate for the Grant Review process or inflammatory in nature.   The current wording would mean that any Grant Review report would be provided to the applicant unaltered.   There may be at times where some panel reports or assessment reports are not provided to the applicants since they are inflammatory and NHMRC would then have a decision to alter the report or withdraw the report from provision to the application. 
c.  Late Assessment Reports – These are not dealt with within the current Peer Review guidelines and there also needs to be a comment on the timelines for review.  NHMRC has a clear remit to advise the timelines for the schemes and that is provided within the current guidelines, however there is no provision for the acceptance of reviews and panel members to respond to certain timelines which may result in administrative withdrawal or non-supply of assessment reports. 



(4)  Appropriateness and Balance

       a.  An additional dot point that may be required in this section to indicate the requirements of the NHMRC for appropriate review of applications for Indigenous health.  Currently dot point 1 stating “Peer review panels are established to meet objectives and breadth of disciplines covered by applications received” could be extended to cover those of strategic importance or Peer review surround defined strategic programs.  This would then cover off two major areas which do have different a panel establishment for Grant Review Panels such as Indigenous Health and Large Scale Clinical Trials. 


       b.  An additional dot point should be about the “principles for selection of Peer Reviewers and a Peer review process”.  Such a document was being worked upon by NHMRC and should be open to the public to determine what are the key selection criteria for Grant Review Panel members, Reviewers, Assessors and Chairs such that it is transparent to people in the community.  There is concern in the community of how memberships of panels are drawn. 


(6)  Confidentiality

       The 2nd dot point, last sentence could be reworked. 

       Currently, this sentence is: “When this occurs, it will be done so following discussion with the assessors”.  A more appropriate sentence would be “When this occurs, it will be done so following discussion with affected assessors and Review Grant panel members”.  Presently, the wording is such that any Grant Panel members who may be affected by an investigation under relevant legislation would not be advised as it is limited only to external assessors.


(7)  Impartiality

       The 2nd dot point, 4th sub-dot point - Needs a line adjustment to read as: “Any other relationship that may, or be seen to, impair fair and impartial judgement”.   Currently there has been a line return introduced between ‘impartial’ and ‘judgement’


(8)  Continuous Improvement

       a.  Dot point 4 – The wording from this dot point could be reworked and my suggested wording is: “NHMRC will undertake post-Program assessment of all its schemes, based on feedback from applicants, assessors, Panel members, Chairs, Research Committee and the NHMRC Commission of Complaint”.  This sentence allows for assessors to provide commentary about the process whereas the current wording does not allow assessors to provide any input for a continuous improvement of the Review process. 

       b.  Dot point 5 – Currently this dot point limits NHMRC to provide feedback and advice on training need for Peer reviewers coming into the system.  This currently has limited scope since it would be accepted that any Peer reviewers within the system are appropriate, and I believe that NHMRC should provide feedback advice and training for all Peer reviewers within the NHMRC system. 

       c.  Dot point 6 – Again I suggest wording alterations for this dot point such that it should read: “Where the Peer Review Panels find peer reviews to be substandard, feedback may be provided directly to the reviewer or their institution”.  This suggested change allows greater flexibility for the Peer Review Panel whether that is the Chair of the Panel or other members, to provide feedback to Panel members and not only limit any feedback to external Peer reviewers.  This seems a major limitation in this report here that there is feedback required for external Peer reviewers as well as the Peer Review Panel in itself. 

Page reviewed: 19 February, 2013