On 26 June 2020 the Advisory Board for Safer Gambling – an independent advisory body funded by the Gambling Commission – published its “Progress Report on the National Strategy to Reduce Gambling Harms” (that you can download below).
You can find out more about the National Strategy here.
The Progress Report’s Executive Summary states as follows:
- The Gambling Commission published the National Strategy during a year of rapidly growing interest in gambling related harms. The range of organisations now taking an active role represents a significant step forward, and there has been some progress in both priority areas of prevention and treatment.
- Much more, however, still needs to happen to achieve the objectives of the National Strategy. Failure to make progress on the issue of gambling related suicide must be urgently addressed.
- Our priority recommendations for year two include establishing a safer gambling league table and key baseline metrics from which to set targets and measure progress. Government, regulators, industry, the NHS and third sector organisations should agree areas of responsibility for ensuring these metrics are in place.
- There needs to be an acceleration of efforts to involve people with lived experience in the delivery of the National Strategy.
- To make faster progress on treatment, the NHS should lead the creation of a national treatment strategy working in partnership with the third sector. Agreed care pathways between the NHS and other providers are essential to the development of equitable services and there needs to be rapid implementation of quality assurance processes to monitor existing provision.
- Greater progress is also required to secure more effective arrangements for commissioning research – particularly on the measurement of gambling harms. We recommend that initial engagement with research councils is built upon to increase their involvement on this area.
- We continue to urge progress on a statutory levy to underpin all of this work with sustainable, independent funding. Without the levy, progress will be limited.
- The COVID-19 pandemic has created unprecedented challenges to almost every aspect of life in Britain. Gambling activity is no exception and the exhortation to “Build Back Better” is as relevant to the goal of safer gambling as it is elsewhere in society.
Based on recent experience, we can expect to see the Gambling Commission advance progress on each of the above-mentioned items that fall within its power although, in relation to item 4 above, it has already announced creation of an interim Experts by Experience Group.
Prompt action in relation to:
- item 3 above, “establishing a safer gambling league table and key baseline metrics from which to set targets and measure progress” and
- item 6 above, “more effective arrangements for commissioning research – particularly on the measurement of gambling harms”
would serve to address certain of the hard-hitting criticisms contained in the House of Commons Public Accounts Committee’s “Gambling regulation: problem gambling and protecting vulnerable people” report published on 28 June 2020.
In the case of its recommendation that the the Gambling Commission should introduce a ‘safer gambling league table’ (item 3 above), the ABSG proposes that the table should be populated by new mandated metrics from the industry. It does not yet have any firm ideas on specific metrics that should be included in the league table but has suggested the following as a starting point:
- affordability checks,
- gross gambling yield metrics,
- time spent gambling online and
- warning labels.
Insofar as a statutory levy (item 7 above) is concerned, it is of interest that in its 29 April 2020 supplementary written evidence to the House of Lords Select Committee on the Social and Economic Impact of the Gambling Industry, the government answered the Committee’s question on this subject as follows:
Question: The Government has the power to introduce a mandatory levy on the gambling industry, but has so far declined to do so. Can you explain the reasons for this?
Answer: The Gambling Act 2005 includes a provision for the creation of a mandatory levy payable to the Gambling Commission. The Act states that funds collected through such a levy are to be used by the Commission to fund projects related to addiction to gambling, other forms of harm or exploitation associated with gambling, or any of the Commission’s licensing objectives. It is unusual for a regulator to be the commissioner of support services and we are concerned that placing such a responsibility on the Gambling Commission risks broadening its remit too far. Funding for the Commission’s licensing objectives are provided by licence fees without the need for a separate levy on operators (see q5 for more detail about licence fees).
Our focus to date with regard to gambling addiction treatment has been on ensuring that we have the right level and forms of support available for those who need it, rather than the mechanism by which this provision is funded.
The Gambling Commission requires operators to support research, prevention, and treatment of problem gambling and in January 2020 it amended this rule to specify the organisations that it considers suitable recipients for these donations. The Commission plans to begin publishing the value of these donations on its website. During the 2018/19 financial year the gambling industry gave £9.6m to the charity GambleAware, which commissions research, education, the National Gambling helpline, and a network of treatment services. Industry group the Betting and Gaming Council estimates that a further £9.7m was given to other charities.
In July 2019 five major operators also committed to increase their donations tenfold, from 0.1% to 1% of gross gambling yield over the next four years. This included a commitment to spend a cumulative £100m on treatment over those four years. We welcome this commitment and will monitor progress against it closely.
A mandatory levy on operators would also be a hypothecated tax. Public services are not usually funded by such taxes as they risk raising too much or too little for the purposes for which they are intended. As Lord Smith of Hindhead observed in his question to Sir Alan Budd on 3rd September 2019, ‘the drinks industry does not specifically have to pay for liver disease treatment; the smoking industry does not specifically have to pay for lung disease treatment; the motor vehicle industry does not specifically have to pay for car accident treatment.’ Alcohol and tobacco products are taxed in recognition of their social costs and support services are funded from general taxation, according to need. The upscaling of NHS treatment for problem gambling under the NHS long-term plan is primarily funded through this route.
We are working on building the evidence base to inform our understanding of the treatment need, which will in turn inform decisions on funding need. In the Government Response to Proposals for Changes to Gaming Machines and Social Responsibility published in May 2018, it was announced that Public Health England would undertake an evidence review of the prevalence of gambling, its associated health harms and their economic and social burden. This study by Public Health England is complemented by an evidence review conducted by the National Institute of Health Research that aims to establish which interventions are effective and cost-effective in preventing or reducing gambling-related harm. The National Institute of Health Research will publish its report in the coming months, while pressures resulting from Covid 19 have delayed the likely publication date of Public Health England’s review until later in 2020 or early 2021. Work is also underway to scope a cross-government addiction strategy that will include gambling.
It is presently anticipated that the Select Committee’s report may be published on Thursday 2 July 2020.