The UK Gambling Commission has initiated a consultation on a new national strategy to reduce gambling harms, with the current strategy officially ending in March 2019. What’s particularly interesting is that the Gambling Commission has sought this input in its own right.
Currently, there are three bodies that are involved in the development and implementation of the national strategy:
- The Responsible Gambling Strategy Board (RGSB), which develops strategy and advises the Gambling Commission
- The UK Gambling Commission, which adopts and implements the RGSB’s strategy
- GambleAware, formerly The Responsible Gambling Fund (RGF), which raises funds, and commissions research, treatment and education services, in line with the RGSB’s strategy, independently from the industry.
The UKGC’s announcement states that the reason it, rather than the RGSB, is seeking input is that the current process between the UKGC and the RGSB is informal and has not been effective in producing the outcomes that they both wanted. “Despite concerted efforts to position it as a ‘national strategy’, it has often been called ‘the RGSB strategy’ and there have been challenges to ensure commitment towards the strategy and progress towards delivery.” In other words, it ain’t working. The RGSB believes progress against the official strategy has been slow because of the disjointed nature of the relationship with the UKGC, and the UKGC’s lack of some needed statutory powers to implement the strategy.
Previously, before the fundraising arm (The GREaT Foundation) and the commissioning body (The RGF) merged into what is now GambleAware, there were four bodies. At that time there was much criticism of The GREaT Foundation because its trustees came from the gambling industry; it was seen to be “manipulated” by the industry and to unduly emphasise treatment over research. Considering the foundation was purely a fundraising body that handed the money over to the RGF to commission services or research, I am not sure that was a fair criticism. But as the founding Chairman of the foundation, I would say that, wouldn’t I?
The initial structure was unwieldy and expensive, with many administrative functions being duplicated. It made very much sense to merge the two bodies and for the industry’s “control”, whatever the extent actually was, to be removed over time. I suspect the current structure will be streamlined yet further, with the RGSB becoming purely an ad hoc advisory body to the UKGC, and with all strategy development and implementation becoming purely a function of the Commission.
What is really positive to see is that the outline for the new proposed strategy emphasises a more logical approach to understanding harm and how to minimise it: define the problem; identify the risk; develop and test; and if successful, ensure widespread adoption. To me, there are two key points here: defining the problem you want to solve, and – somewhat unsaid – setting the criteria for what will be defined as success. Without the latter being done prior to starting the evaluation, as I have seen in other areas, it is all too easy to move the goal posts after the event to ensure whatever was done is deemed to be a “success”.
The proposed strategy has five priority areas: Research, Prevention, Treatment, Evaluation, and Gambling Businesses. The first suggests the creation of a central data depository and the creation of an independent research hub to ensure joined-up thinking between research and policy.
The second priority area, prevention, is looking to build on current work for measuring and preventing gambling-related harms. Gambling addiction in the UK is now seen, rightly, as a public health issue. That means that addressing addiction should link with many other areas of government involvement, especially the delivery of health services through the cash-strapped National health Service (NHS). In addition, the NHS commissions millions of pounds of research annually; clearly, where gambling is concerned, such research needs to be coordinated with external bodies such as the UKGC and GambleAware.
As for the third pillar, treatment, there are existing treatment services, but the availability and quality does vary geographically; some would say the supply needs to be increased dramatically. To date, treatment and related services has been given the lion’s share of the available money, primarily because of need. If there is to be an increased emphasis on the other “priority areas,” much more money will need to be found. The Commission proposes some joined-up thinking with the National Health Service Long Term Plan, which includes funding for more mental health services and a focus on preventing ill health rather than the expensive challenge of making ill people better. Given that those with a gambling addiction are likely to have other mental health problems and suffer illness disproportionately, this all makes good sense. If GPs are trained to look for gambling problems and start pointing their patients to problem gambling treatment services, mental health services had better be available. More therapists will need to be trained; only with a truly national, integrated strategy is this likely to happen.
The Commission would like to ensure consistent evaluation is at the core of any new and continuing initiative and that this be coordinated through a central evaluation body. Again, this sounds to be expensive.
Finally, UKGC wants the industry to collaborate and put its efforts behind a targeted approach. Hah! Coordination between the different sectors is like herding cats. At the moment each sector of industry, usually through the auspices of the sector’s trade association, trials different technologies to see if they can be effective in whatever it is proposed they do. For example, we now have different exclusion schemes for each sector. If you are a customer and want to stop yourself gambling, you have to sign up with each sector’s exclusion scheme. But based on some recent mystery shopping by the UKGC, this is still not very effective. And what is economic for a casino may not be economically justifiable for a bookmaker or an arcade. For example, facial recognition systems are expensive, though it’s true that the price is coming down; it’s difficult to argue that they should be installed for all arcades and retail bookmakers.
The Commission proposes biting off small, manageable chunks in each year, but it all looks to be very expensive and will probably need a levy to be imposed on the industry to ensure consistent funding. As more and more of the functions are stripped away from GambleAware and the RGSB, I predict there will not be three bodies but ultimately one. The UKGC will develop strategy, determine what the priorities are, how much money will be needed, and raise that in the form of a levy directly from the industry.
