Ms. Karolina Zioło-Pużuk

Secretary of State

Ministry of Science and Higher Education

 

Dear Minister,

 

Subject: Position on the draft amendment to the Law on Higher Education and Science in the field of evaluation of scientific activity in the years 2026–2030.

In connection with the work on amendments to the Act of 20 July 2018 – Law on Higher Education and Science, we would like to express our support for the direction of the legislative actions proposed by the Ministry of Science and Higher Education, published on 2 June this year, the aim of which is to further strengthen the quality of the Polish science and higher education system, its competitiveness and its ability to generate socially, economically and culturally significant results.

In our opinion, it is of particular importance to shape the national system for the evaluation of scientific activity in such a way that it can reward the actual quality, originality and significance of scientific achievements to the highest possible extent, and not only their number or the bibliometric position of the journals in which they are published.

Therefore, we kindly ask that the following postulates be taken into account in the course of further legislative and implementation work:

1. Greater visibility of the assessment of the most important achievements of scientific units

We postulate that the importance of the most outstanding, representative achievements of scientific units – in particular those that make a significant contribution to the development of a given discipline, solve important research, economic or social problems, open new directions of research and thus have gained significant national or international recognition.

The evaluation system should make it possible to identify and properly evaluate the most important results of scientific activity, instead of leading to the aggregation of a large number of indicators describing publication activity.

In this context, it seems reasonable to strengthen the mechanisms that allow experts to qualitatively assess the presented achievements and determine their real significance for science and its environment.

2. Increasing the importance of the quality of scientific research, while maintaining the principle of balance between expert evaluation and statistics

We consider it particularly important to move away from a situation in which quantitative indicators may in practice determine the evaluation of scientific activity to a greater extent than the substantive value of research. Therefore, we recommend that bibliometric indicators, including the number of publications, citations or indicators related to journals, should have an equal and contextual function, and not replace expert judgment of the quality of research.

Expert judgement would require proposing objective criteria for the selection of experts (independent, without connections, without conflict of interest and, if necessary, perhaps foreign).

Such a solution would be in line with the international direction of the reform of science evaluation set by the Coalition for Advancing Research Assessment (CoARA), the basic principle of which is the primacy of qualitative assessment, based on expert judgment and peer evaluation, with the responsible use of quantitative indicators. (qualitative judgement first, metrics second).

3. Counteracting unethical publishing practices

We also draw attention to the need to design the evaluation system in such a way that it does not reward practices aimed at maximizing quantitative indicators at the expense of the quality and reliability of research.

In particular, the system should limit rewarding behaviours such as excessive fragmentation of research results, publishing papers of low cognitive value solely to increase achievements, unjustified increase in the number of authors, practices related to manipulation of citations, or the use of journals and publishers that do not meet appropriate standards of scientific integrity.

At the same time, it would be desirable to take into account the integrity, reliability and accountability of research more clearly in the evaluation system. The evaluation system should strengthen the scientific culture, in which the value of a single, solid and significant result may be greater than the value of many publications of marginal importance.

4. Increasing the importance of the popularization and social impact of science

We also call for more explicit consideration of their contribution to the dissemination of knowledge and building social trust in science in the evaluation of the activities of scientific units.

Popularization of science, accessible communication of research results in the public sphere, cooperation with schools, cultural institutions, social organizations and public administration, as well as the creation of high-quality educational materials should be seen as integral elements of responsible scientific activity and taken into account in the process of its evaluation.

In this respect, activities that lead to a lasting and documented impact of science outside the academic community are particularly valuable.

5. Stronger integration of commercialisation and knowledge transfer

We also consider it justified to increase the importance of achievements that translate into the practical use of research results, including their commercialization, technology transfer, implementation, patents, licenses, the creation of spin-off companies and cooperation with the economic sector. This would mean an increase in the percentage weight of the third evaluation criterion. 

At the same time, we believe that the principle that commercialization cannot be a universal measure of the quality of science should be maintained. Its meaning and method of evaluation should be adapted to the specificity of the discipline and the nature of the research conducted. In many fields, scientific achievements of the highest value may not have a direct commercial dimension, and their impact may manifest itself in the social, cultural, educational or methodological spheres.

6. Moving away from the mechanical use of a single set of indicators

In view of the above, we propose that in the further development of the evaluation system, the principle should be adopted according to which quantitative indicators mutually balance expert assessment, but do not replace it.

The evaluation should take into account the diversity of the missions of scientific units, disciplines and forms of research activity. It should also enable experts to assess achievements in their proper context, including their originality, relevance, reliability, durability and real impact on the development of science and society.

We support the comprehensive, multidimensional institutional assessment of the scientific potential of research units envisaged in the draft amendment.

This approach is in line with the direction of the international reform of research evaluation developed by CoARA, which aims to identify a variety of results and activities leading to maximizing the quality and impact of research, while reducing the misuse of publication indicators.

We are convinced that the reform of the science system should lead to the creation of such conditions in which not the most numerous, but the most valuable scientific achievements are valued the most.

Therefore, we kindly ask you to include the following principles in further work on the amendment to the Act and in the implementing acts and evaluation mechanisms:

• • Balancing qualitative expert assessment with quantitative indicators;
• • To expose the most important achievements of scientific units more clearly;
• • Increase the importance of quality, originality and relevance of research;
• • Limiting incentives conducive to unethical and unreliable publishing practices;
• • Taking into account the popularization of science and its social impact;
• • Increasing the importance of knowledge transfer, implementation and commercialization of research results, respecting the specificity of individual disciplines;
• • Use quantitative metrics responsibly, transparently, and contextually.

 

In our opinion, the adoption of such a direction will not only allow us to better reflect the real value of Polish science, but also to create a system of incentives conducive to reliability, ambitious research, long-term scientific cooperation and increasing the social and economic impact of research results on the economy and society. 

We express our support for the legislative actions taken by the Ministry of Science and Higher Education and hope that the above postulates will be taken into account in further work on the reform of the national science and higher education system.

Yours sincerely,

/Dr Mieczysław Błoński/

President of the Management Board

Polish Union of Education