Advice to the Gambling Commission on a statutory levy
Section 4: What could a statutory levy achieve?
In this section we outline the key benefits a levy could help achieve. This is not intended to be a full needs assessment. We outline key activities, processes and services which could be introduced with sustainable funding to illustrate the range of benefits which could be delivered.
A sustainable independent infrastructure for research
The current perception that gambling research is influenced by relationships with the gambling industry may be inhibiting both the acceptability of research findings and the attention of health researchers and health policymakers67,68,69. In both substance abuse and alcohol research, any direct funding for research from industry is seen as a clear conflict of interest70. There is strong evidence from other sectors showing that studies sponsored by industry are more likely to produce favourable results than non-industry funded studies71. However, this has not yet been examined for gambling research.
A statutory levy would help enable the creation of joint funding relationships with large health and social care funders such as NIHR, ESRC, Wellcome Trust and the Health Foundation. Mainstream health and social care funding partners have established processes for ethical approval, peer review, independent research oversight, and the involvement of those with lived experience in the design and delivery of research and frameworks for supporting early career researchers as standard. These governance and ethical frameworks provide quality assurance, ensure the involvement of experts by experience, and would offer new frameworks for gambling funded research programmes. These would, under a statutory levy, apply to all gambling related research, raising standards and attracting a wider pool of academic expertise into the sector.
Requirements of mainstream health and social care funding councils
- Ethical standards - Research undertaken within the NHS requires Health Research Authority (HRA) approval and compliance with ethical standards. The HRA is an executive non-departmental public body (NDPB) sponsored by the Department of Health, which provides robust ethical and legal governance, and supports transparency of NHS research - including a public register of all research.
- User involvement - Involvement of the public and other stakeholders in the co-production and delivery of research is fundamental to all NIHR activity, and UK Research and Innovation (which incorporates the seven Research Councils) requires researchers to broaden their focus on user involvement in research and engage more with under-represented groups72.
- Developing future research leaders - The NIHR and UKRI funders offer established pathways for the development of Early Career Researchers, for example the MRC supports the development of independent researchers through both fellowship schemes and MRC New Investigator Research Grants73, and the NIHR supports ECRs across fellowship schemes (NIHR Academy), project funding streams, research infrastructure (Applied Research Collaborations (ARCs) and research delivery (Clinical research Network (CRN))74.
A statutory levy would also drive innovation in research and development. The future of safer gambling will be increasingly tied to advances in technology, as developments in game design and communication infrastructure change the shape and nature of products and how they are marketed. These will potentially increase risks of harm for some but also provide opportunities for understanding consumer behaviour. Understanding these processes and how best to harness them for the protection of consumers will require significant, and independent, investment in data science combined with the skills of public health prevention experts.
A statutory levy would help generate these partnerships by enhancing the volume of resource in research and by creating a an independent research and development environment (see Appendix 2 for details of areas of research required and Appendix 3 for examples of research council funded studies in comparable areas).
A key objective in the National Strategy to Reduce Gambling Harms is the creation of an independent data repository, into which all operators will be mandated to submit their data for research purposes. Both the House of Lords75 and APPG76 Reports emphasise the importance of this work to understanding harms. There are precedents elsewhere for this approach. In France, the online gambling regulator, the Autorité de Regulation des Jeux en Ligne (ARJEL) mandates disclosure of transaction data and customer behaviour as part of the licence. This allows cross operator research to be conducted without direct funding77. In the UK, an initial scoping study by the University of Leeds provides details of how a data repository might be established and what this might cost. A statutory levy would allow the long-term investment necessary to create and maintain this world leading independent repository, which will be essential to building a credible and extensive evidence base on gambling harms78.
A sustainable funding stream for prevention
We know from other areas that preventative and public health interventions can reduce future costs associated with poor health. Predicted cost benefits suggest that £14.30 could be saved for every £1 invested79. The government’s across Great Britain recognise the importance of prevention to future population health and sustainability of the NHS80,81,82.
A statutory levy could make a significant contribution to a public health prevention approach. It would bring gambling research investment in line with other public health priorities that are important to preventing non-communicable disease (NCD) and reducing the health impacts of smoking, obesity and poor air quality. Unlike gambling, these areas have been key priorities within current prevention research funding streams including the UK Prevention Research Partnership funding initiative. This is a collaboration of funders (including the UKRI Research Councils, NIHR and charities) investing £50 million in 5-year primary NCD prevention research consortia and networks83, and the NIHR Public Health Research programme which invests £12 million each year in non-NHS prevention and population health research84.
A sustainable funding stream for treatment provision
A statutory levy would enable the funding of a wider range of effective and regulated treatment options, integrated within established NHS organisations working in partnership with the third sector.
Despite recent initiatives to expand helplines and treatment services, such as the helpline opening 24-hours a day85, there are large gaps in geographic availability and inequalities in access between different groups and communities. This can mean that those with the greatest need are least likely to get access to services.
The NHS England Long Term Plan proposes there is a need to create up to 14 centres that can offer a blend of treatment provision across England86. In addition to these specialist centres, adequate provision will require a system wide, intermediate integrated service (IIS) modelled on those existing in many areas of mental health. Based on successful initiatives for other addiction services87, these IIS would ideally be primary care led, multidisciplinary services able to identify, assess, case manage, prescribe and treat some gamblers, and refer on to other specialist treatment providers in the NHS and third sector.
These services would provide the bridge between third and specialist sectors. Only with such primary care involvement will services be able to deliver at scale and be able to provide routine screening and assessment and appropriate levels of support for those affected by gambling and their families88. There is a need to build on the learning from other services in areas of mental health to develop a tiered approach to service delivery, with different providers creating a more sustained, systematic delivery model. The forthcoming evidence review by Public Health England will be critical to the development of much anticipated NICE guidelines in 202189.
A sustainable funding stream for increasing workforce capacity
Increased treatment provision and prevention also means better awareness of gambling harms and likely increased demand for services as more individuals and their families seek help. The treatment system needs to be able to respond to this and build capacity, including through the primary care workforce, where currently one million individuals present for care each day.
All GPs need to be equipped with the skills, knowledge and support to identify, provide early intervention and appropriately signpost gamblers (through digital solutions as well as training programmes and support systems). In addition,there is a need to develop the skills of medical, nursing and mental health work force practitioners to identify gamblers who might present to accident and emergency, antenatal services, or mental health services. Some of this capacity building could be linked to existing training programmes such as the NHS Improving Access to Psychological Therapies (IAPT) programme, and other regional counselling service providers. Peer led training programmes at Recovery Colleges90 would also form an important part of this training, as would training delivered by third sector organisations with expertise in this area. All would require additional funding.
A sustainable approach that addresses the social and health costs to society
A recent UK review of the evidence on the social and health costs of gambling harm concluded that this was a new area for research with no published studies prior to the 1990s91. However, the report does provide a review of those countries that have carried out extensive analysis on the costs of gambling harms to society. The Australian Productivity Commission estimated that the social costs of gambling were between £2.5 and £4.4 billion per year, excluding costs in relation to health care services92. In Germany a study found that additional annual healthcare costs for their population of problem gamblers was £185 million93. Fully comparable costs calculations have yet to be made for Great Britain, but estimates of a range of social costs suggests these would be between £120 million to £1.1 billion.
67 Clear principles are needed for integrity in gambling research (opens in new tab), Livingstone and Adams, Addiction, June 2015
68 Gambling Research and Industry Funding (opens in new tab), Collins et al, Journal of Gambling Studies, 2019
69 Funding of gambling studies and its impact on research (opens in new tab), Nikkenden et al, Nordic Studies on Drugs and Alcohol, 2019
70 Funders must be wary of industry alliances (opens in new tab), Bauld, 2018
71 Industry sponsorship and research outcome (opens in new tab), Lundh, 2017
72 UKRI Vision for Public Engagement (opens in new tab), UKRI, 2019
73 Supporting early career researchers: (opens in new tab) The transition to independence, Medical Research Council
75 Gambling Harm - Time for Action (opens in new tab), House of Lords Select Committee on the Social and Economic Impact of the Gambling Industry July 2020
77 Activity report 2017-2018 (opens in new tab)ARJEL. . Paris: Autorité de régulation des jeux en ligne; 2018.
78 Independent Repository of gambling industry data – a scoping study (opens in new tab), Lomax, University of Leeds, August 2019
79 Return on investment of public health interventions: a systematic review (opens in new tab), Masters, Anwar, Collins et al, Journal of Epidemiology and Community Health, 2017
80 Toward a public health approach for gambling-related harm: a scoping document (opens in new tab), Gillies, et al, Scottish Public Health Network, August 2016
81 (Para 2.36, page 43) The NHS Long Term Plan (opens in new tab), NHS, January 2019
82 Gambling as a public health issue in Wales (opens in new tab), Rogers et al, Bangor University, 2019
85 National Gambling Helpline to Pilot 24-hour Service (opens in new tab), GamCare, August 2019
86 NHS to launch young people’s gambling addiction service (opens in new tab), NHS, June 2019
87 Gerada C, Tighe J, Betterton J, Barrett C. The Consultancy Liaison Addiction Service- the first five years of an integrated, primary care–based community drug and alcohol team. Drugs: Education, Prevention and Policy, 2000. The costs of a service based on this service are estimated at £15 million per year, although a full needs assessment for an IIS service for those affected by gambling would be required
88 Problem gambling and family violence in a population study (opens in new tab), Dowling et al, Journal of Behavioural Addictions, 2018
89 Gambling-related harms evidence review: scope (opens in new tab), Public Health England, October 2019
90 Recovery Colleges provide low cost support and training to people with a wide range of needs. Support and training courses are co-designed and led by people with lived experience and professionals. Services are online and face to face, individual and group. There are currently 81 Recovery Colleges in Great Britain, funded jointly by NHS and third sector organisations. The majority of them offer suicide prevention support and all have a strong focus on mental health and wellbeing. This is an example of an existing infrastructure that could be used to support individuals with gambling problems and their families.
91 Measuring Gambling-Related Harms: Methodologies & Data Scoping Study (opens in new tab). McDaid, Patel, London School of Economics and Political Science. 2019
92 (Page 48) A Productivity Commission Inquiry Report (opens in new tab), Australian Productivity Commission, 2010
93 The Effect of Online Gambling on Gambling Problems and Resulting Economic Health Costs in Germany (opens in new tab), Effertz et al, European Journal of Health Economics, 20182
Advice to the Gambling Commission on a statutory levy: The case for change Next section
Advice to the Gambling Commission on a statutory levy: Challenges to implementation
Last updated: 1 December 2023
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