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GamCare Response to Gambling Commission's Review of Research, Education and Treatment
7 August 2008
Research (Consultation Questions 1-4)
We believe that the paper contains a thorough review of RIGT’s research and correctly identifies the shortcomings of the existing programme (particularly at paras 2.16, 2.18 and 7.2). We agree with the research priorities identified, and support the need for a longitudinal survey as an integral part of an effective research strategy. We would emphasise the need to take forward work co-operatively, both in this country and internationally; to ensure the UK research effort takes full and proper account of work done elsewhere, and in particular does not seek to duplicate facilities available elsewhere (eg the Responsible Gambling Council of Canada’s online library, the Harvard Brief Addiction Science Information Source (BASIS); and to provide regular and accessible updates on latest research findings from around the world.
We suggest that the estimate of the amount of funding needed (£1.5 million per annum plus £600k one-off) should be validated by the Strategy Board, and it is they who should determine the research strategy and the place of a longitudinal survey within it. It seems possible some of this funding might be found from matching or partnership opportunities, though the non-availability of such additional funds should not be an excuse for constraining the strategy.
Education (Consultation Questions 5-7)
We fully support the need for an effective education and awareness strategy, and are keen to play our part in it. Whilst we understand the doubts expressed about the value and effectiveness of national prevention campaigns, we also note that the Government’s approach in other areas – smoking, responsible drinking, obesity - is not necessarily consistent with the Commission’s or the ASA’s conclusions (para 3.6).
We agree that young people are a particular target group, but we also believe that the existing schools programmes funded by RIGT need to be rigorously evaluated before it can be decided that they should continue (as implied by para 3.15). Similarly, we would like to see a full evaluation of gambleaware.co.uk; a web resource would clearly be an important part of an awareness programme, but it needs to be placed within the context an overall strategy. These are important matters for early determination by the Strategy Board.
Much of your paper is devoted to a discussion of the national telephone helpline. GamCare’s helpline already operates across the country as both an information and support line; our experience suggests that the two services should not be separated. We are pleased that we have reached agreement with the Commission and RIGT on the Pathfinder exercise we are conducting to raise awareness of the helpline for front line professionals (GPs, CABx, Debt Advice Centres etc). It is also vital that quick decisions are reached on the nature and scope of the national helpline. We stand ready to have the discussions with you and RIGT promised in para 3.12. We have already made it clear that we would be happy to operate a helpline number owned by the Commission and if necessary to compete to run it in the future. For us, the important things are to ensure simplicity and ease of access for the user (ie a single telephone number, nationally promoted), and that the helpline is answered promptly and in person by suitably trained and experienced operators.
The quantum of funding needed should again be a matter for the Strategy Board. It is clear though that the national helpline must be a central pillar of the strategy, and that the costs of our existing helpline (over £400k per annum) at present score against RIGT’s treatment programme rather than education.
Treatment (Consultation Questions 8-10)
We endorse the main conclusions, which we understand to be:
- The need for a range of treatments and methodologies
- Clear routes into treatment
- Greater understanding of co-morbidity and a more joined-up response
- The need for properly qualified counsellors
- Greater emphasis on evaluation.
We welcome the recent launch of the Soho Clinic under Dr Henrietta Bowden-Jones and will work closely with her on its development. Our partnership with Dr Bowden-Jones, working also with Salford University, has also recently produced the new Certificate Course in Problem Gambling Counselling.
In our view, the proposed doubling of those accessing treatment to 1% (representing some 3000 people – para 4.23) is timid and unambitious. If the comparison with alcohol is pursued, then the target should be nearer 6%. Whilst there would clearly be efficiencies and economies of scale, funding levels should be considered to deliver at this level over a prolonged period.
Future funding requirements (Consultation Questions 11-12)
The determination of funding requirements based on need should be the first priority for the Strategy Board. The analyses in the consultation paper represent a firm starting point for this work, which we believe needs to be completed before the end of this calendar year. Whilst we believe that the total research bill might be reduced by attracting partnership funding, the expansion of education and treatment services will undoubtedly require increased investment.
Structures (Consultation Questions 13-16)
We strongly support the creation of a small Strategy Board. We believe that this should be seen to be an independent and authoritative body whose role should be:
- To establish a national strategy for gambling research, education and treatment
- To establish the minimum levels of funding needed to deliver the strategy
- To establish appropriate mechanisms for distributing funding
- To secure objective evaluation of the effectiveness of programmes funded to deliver the strategy.
All interested parties (the Commission, industry, the distributor and service providers) should explicitly recognise and accept the Board’s authority to fulfil this remit. To make its role and authority clear, we believe it is important that the body is described as a Strategy, not an Advisory, Board.
We believe there is a strong case that DCMS should take the lead in establishing this new body, working with the advice of the Commission, the industry, the academic community and treatment and other service providers. An alternative is for it to be created by the Gambling Commission; if this route is chosen, there must be transparent assurances that the Commission will heed and implement the Strategy Board’s advice and recommendations.
We understand that the Commission is considering a Board with nine members: an independent Chair; two industry members; five members who between them have expertise in research, preventive education, public health, addiction services and counselling, all drawn from non-industry backgrounds; and one member involved in services to help problem gamblers and support responsible gambling. We also believe that, collectively, the Board needs to have strength in strategic analysis and planning in the public sector. We understand that the Department is considering chairing a Panel to make appointments to the Board, and would support this.
We also strongly support the absolute separation of fundraising from the development of strategy and the distribution of funds (para 7.26, second sentence). We are concerned that some parts of the industry have suggested that the industry fundraising body might also take responsibility for all, or elements of, the education and awareness programme. This would be completely at odds with the conclusion of the paper, and would not have our support.
We therefore envisage a simple structure, with the Strategy Board at the top; a single-purpose industry fundraiser to provide the funding determined by the Board; and a Distributor to fund programmes, through grant-making or commissioning, to deliver the strategy determined by the Board. The consultation paper floated the idea that funds might be distributed by a third party, effectively under contract to the Board (paras 6.15-16), and we would be interested to hear what further thinking has been done on this option. However, we understand that the Commission may now favour the creation of a new Distributor, suggesting that appointments to it might be made by the Panel which also appoints the Strategy Board. Clearly, the Distributing Body should not have members drawn from the industry or from potential recipients of funds. We agree, though, that there may be advantage in some (or indeed all) of its members being drawn from the Strategy Board. We understand that the Commission believes that the distributor should be a charity but do not understand the need or rationale for this, particularly if it were to produce a lack of clarity about the future control of the distributor.
The consultation paper also floated the possibility of a separate National Research Institute for Responsible Gambling (para 6.32). We certainly believe that the Board and the distributor need to capture the expertise and knowledge of the academic community. This might be achieved through such an Institute, which could also help provide the strategic focus currently lacking; if not then there will certainly need to be a research advisory panel, just as we envisage panels on treatment and education/awareness. These panels could draw on some of the existing expertise represented on the existing RIGT board and panels.
It is clear that there is now a real opportunity to introduce a system which will deliver a coherent and defensible strategy for dealing with problem gambling. Whilst the existing system has had its successes, and we recognise the need to minimise disruption and ensure continuity from the existing arrangements, we would also encourage you not to compromise the clarity of what can be quite a simple system in order to deal with short term or transitional considerations.
Transition (Consultation Questions 16-18)
We know that the Commission has received many representations on the suggested target implementation date of April 2010 and has already signalled its desire to get the new arrangements in place from April 2009. We welcome this, and will do all we can to help the Commission and DCMS to achieve this timescale. As the paper recognises (para 6.23) we and other service providers would need assurances of future finance which may need to be underwritten by the Commission and/or DCMS.
Future fundraising (Consultation Questions 19-20)
We have consistently made clear our preference for a voluntary system rather than a levy, not least because that would facilitate fundraising from the much broader range of businesses that benefit from gambling. So far, though, we all have to accept that the voluntary system has delivered neither enough money nor in a timely way (paras 7.36-38). Ultimately, these are not matters for us. However, we hope that the industry will be able to provide bankable guarantees to deliver adequate funds, and set up and properly resource a dedicated and professional fundraising capacity; if it does so, we believe that such strengthened voluntary arrangements could deliver the assurances of funding that would otherwise have to be guaranteed by a statutory levy.GamCare July 2008
Further reading can be found at: http://www.gamblingcommission.gov.uk/Client/mediadetail.asp?mediaid=361
Notes to Editors
GamCare is the UK’s leading authority on problem gambling and the largest provider of help, advice and support services for problem gamblers and their families and friends. Working with other agencies across the United Kingdom, GamCare’s Helpline ensures that anyone with a gambling problem or a relative or friend of that individual is able to access all the services available across the UK. Contact: Eileen Kinghan- Marketing Director 020 7801 7003 eileen@gamcare.org.uk
GamCare’s national helpline telephone number is 0845 6000 133. GamCare’s Netline is available at www.gamcare.org.uk/netline