ABSG Progress Report on the National Strategy to Reduce Gambling Harms – Year Two

Delivery and governance

1 Delivery and governance

This section focuses on the progress made to establish strong delivery mechanisms, including governance, leadership, evidence and funding. These aspects are essential to making effective progress and creating sustainable changes.

Summary of findings

Strengths

• increased involvement and co-production with people with lived experience of gambling harms
• Gambling Commission re-design of statistical outputs
• greater focus on evaluation – both of the impact of new regulatory policy and of pilot projects funded to support delivery of the National Strategy
• Strategy Implementation Groups for Scotland and Wales established
• increased activity at place-based level in England
• Gambling Commission commitment to identify metrics to measure its own performance and impact.

Weaknesses

• limited progress on national co-ordination in England
• limited progress on agreed metrics on the Strategy
• no progress on data repository
• delayed publication of PHE Evidence Review
• slow progress on timetable for NICE guideline development
• the roadmap for research funding remains unclear
• no progress on aligning with established research funders to improve transparency and robustness.

2 Progress involving people with lived experience of gambling harms.

Organisations led by people with lived experience have continued to gain profile and to influence public opinion about gambling harms²⁷²⁸²⁹. A collective submission by people with lived experience to the call for evidence Gambling Act Review (#WeAreTheEvidenceToo)³⁰ provides an example of the depth and breadth of expertise within the community, and its positive impact on progress to reduce gambling harms. The growing number of initiatives led by people with lived experience is a welcome and long overdue addition to the field³¹.

The Gambling Commission moved quickly on ABSG’s recommendation to involve people with lived experience in the delivery of the National Strategy. It appointed a Lived Experience Advisory Panel, which is made up of twelve individuals with personal experience of gambling harms – either resulting from their own gambling or someone close to them (See Case Study 1)³².

Partners in the National Strategy have been taking steps to include the voice of lived experience in their work. For example, the Health and Social Care Alliance Scotland was the first to recruit a group which is informing the work of the Strategy Implementation Group for Scotland. The Alliance has also created a PhD studentship with the University of Glasgow to explore the role of individuals with lived experience of gambling harms in the development of policy and research³³.

GambleAware have also increased their investment in working with people with lived experience. They have established a panel of people of have completed their treatment programme through GambleAware-funded services called ALERTS³⁴. In addition, they have awarded a contract to Expert Link to develop and support the creation of a network of people with experience of gambling harm.

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²⁷ Gambling with Lives (opens in new tab) aims to support families who have been bereaved by gambling related suicides (accessed 13 April 2021)

²⁸ GamLEARN (opens in new tab) supports those who have experienced gambling-related harm and provides opportunities for them to build a better future (accessed 13 April 2021)

²⁹ GamFam (opens in new tab) offers support for families of disordered gamblers (accessed 13 April 2021)

³⁰ We Are the Evidence Too: The views and experience of people with lived experience of gambling harms – a response to the DCMS Gambling Act review (PDF) (opens in new tab), GamFam and GamLEARN, accessed 13 April 2021.

³¹ Business Plan 2020-21, Gambling Commission

³² Gambling Commission appoints Lived Experience Advisory Panel to advance work in player safety, Gambling Commission, February 2021

³³ Alliance Scotland PhD Scholarship - Exploring the role of individuals with lived experience of gambling harms in policy and research (opens in new tab), University of Glasgow (accessed 14 April 2021)

³⁴ GambleAware promotes the voice of people who have lived experience of gambling harms (opens in new tab), GambleAware, February 2021

3 Mixed picture of national strategic co-ordination of implementation

ABSG’s first Progress Report proposed that efforts to establish structures and responsibilities for implementation of the National Strategy in the three nations would be critical to its success. Case Study 2 gives an outline of the work in Scotland, which is becoming increasingly integrated into the wider whole systems response to the Covid pandemic³⁵. A similar picture is emerging in Wales, where the Welsh Government Group on gambling related harms has taken a place-based approach, taking into account the different needs of urban and rural communities in its work on raising awareness and providing treatment and support, using Welsh language materials and bringing together key partners at a symposium. Incorporating gambling harms into the Adverse Childhood Experience (ACE) model³⁶ in Wales provides a framework for a coherent response and progress has been made through inter-agency work.

In England, progress has been slower. There is no equivalent Strategy Implementation Group. DHSC convened a meeting of some key stakeholders in January 2021. These stakeholders are proposing to use this as a forum to increase momentum for wider engagement by public sector bodies and to improve co-ordination across services. Whilst leadership by DHSC is welcome, local authorities in England are addressing the gap too, for example, by learning from the public health approaches developed in Greater Manchester³⁷, the West Midlands³⁸, and the Yorkshire and Humber Region³⁹. These routes could lead to large-scale coverage in England, which would mean other regions in England could then follow. The Royal Society for Public Heath is also playing a convening role through its Gambling Heath Alliance⁴⁰.

There are examples of new approaches to building the required infrastructure in England. The Primary Care Gambling Service⁴¹ shows promise in creating intermediate care services, raising awareness amongst NHS health practitioners and embedding gambling into the NHS systems for signposting and onward referral via primary care networks.

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³⁵ Recover, Restore, Renew: Chief Medical Officer for Scotland Annual Report 2020-21 (opens in new tab), NHS Scotland (accessed 14 April 2021)

³⁶ Responding to Adverse Childhood Experiences, Public Health Wales (opens in new tab), Bangor University, 2019

³⁷ Gambling Commission welcomes new local public health approach to reduce gambling harm in North West, Gambling Commission, January 2021

³⁸ Destinations of regulatory settlements, Gambling Commission – Birmingham City Council/Aston University project

³⁹ Feature Article – Yorkshire and Humber’s Public Health Framework for gambling related harm reduction, Gambling Commission, 2019

⁴⁰ Gambling Heath Alliance (opens in new tab) – Royal Society for Public Health - website

⁴¹ Primary Care Gambling Service (opens in new tab)

4 Metrics for measuring harm

One of the key recommendations in ABSG’s first Progress Report was that the Commission should consider establishing a safer gambling league table and key baseline metrics from which to set targets and measure progress. During 2020, the Commission held a series of workshops to develop proposals on metrics. Three strands of work on data and metrics have emerged.

The outcome of this work is yet to be determined, but metrics to measure the performance of the Commission are due over the coming months as a response to the review of gambling regulation from the Public Accounts Committee.

The Commission is also working on creating greater transparency about the actions being taken by the operators to make gambling safe for consumers and to prevent harm. Some of this work has influenced the emergence of new consultations, for example on customer interaction and affordability checks⁴². ABSG look forward to reporting on outcomes in its third Report in 2022.

Progress on the metrics to measure the impact of the strategy itself has been slow and is unlikely to be finalised for the third year of the Strategy. Collecting data on gambling harms is challenging. Recent years have seen the publication of two scoping reports that have illustrated the type of data required⁴³ and how it could be obtained⁴⁴. Action and resources are now required to put the recommendations of these reports into action. The first ABSG Progress Report identified key areas where collection of data should be prioritised (See Annex 1)⁴⁵. As baselines are established, it will be important for this to be done in a way that allows identification of differences by age, ethnicity, geography and other social-economic factors.

One promising area of development in relation to metrics to measure the impact of the National Strategy, has taken place in Scotland. The Scottish Public Health Network convened a round table for members of the Strategic Implementation Group and its wider partners (see Case Study 2). They looked at measurement and metrics with input from experts in the field of gambling harms in the UK.

GambleAware is in the process of establishing a data sharing agreement with Public Health Scotland to facilitate transfer of Data Reporting Framework data to support on this work.

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⁴² Have your say on tougher rules for identifying and tackling gambling harm – including customer affordability, Gambling Commission, November 2020

⁴³ Measuring gambling-related harms – a framework for action (opens in new tab), Wardle et al, Gambling Commission, RGSB, GambleAware, July 2017

⁴⁴ Measuring gambling-related harms – methodologies and data scoping report (opens in new tab), McDaid et al, London School of Economics, October 2019

⁴⁵ Annex 1 provides a summary of the ways that data could be collected and key partners who could support this work.

⁴⁶ Evaluation of the Credit Card Ban for Gambling in Great Britain (opens in new tab), GREO (accessed 13 April 2021)

5 Evaluation of policy

The need to evaluate in order to understand what works is a long-standing priority. Whilst there has been ad hoc activity previously, a more systematic approach is starting to emerge.

The Commission is embedding evaluation into its implementation plans for policy changes. At the time of writing, a procurement process is being carried out to appoint an independent evaluator for the new LCCP requirement on use of credit cards⁴⁶. The evaluation should tell us more than just how people’s behaviour has changed in response to this measure – but also explore the impact on reducing harms. This is a positive step, but, ideally, an evaluation would have been established from the start of the new requirement in April 2020.

There are other encouraging signs of progress. Plans to evaluate the changes to safer game design are being developed before this LCCP change is implemented in October 2021. The case study below provides more detail. A specific team within the Gambling Commission now has responsibility for establishing evaluation plans accompanying new policies. This means that all new policies will have a clearly expressed understanding of the intended changes, and a plan in place to collect the relevant data to measure this. Understanding what works is critical to longer-term success in reducing harms, and we remain concerned about the Commission’s capacity and resources to regulate a large and fast changing industry. The Gambling Act Review is an important opportunity for the Government to ensure the regulator is sufficiently resourced to expand the quantity and quality of this work.

As shown in Case Study 4, it is also encouraging that evaluation plans are being embedded into Regulatory Settlement projects from their outset⁴⁸. GREO are also assisting many aspects of this through the creation of an Evaluation Hub to build the infrastructure needed to support evaluation activity in relation to the National Strategy. This is helping smaller projects deliver their evaluations and report on impact.

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⁴⁶ Evaluation of the Credit Card Ban for Gambling in Great Britain (opens in new tab), GREO (accessed 13 April 2021)

⁴⁷ Online games design and reverse withdrawals, evaluation of changes to slots games, Gambling Commission, February 2021

⁴⁸ Destinations of regulatory settlements to be applied for socially responsible purposes, Gambling Commission (accessed 13 April 2021)

⁴⁹ Destinations of regulatory settlements, Gambling Commission

⁵⁰ TalkBanStop (opens in new tab) - GamCare

6 Funding

This year has seen continuing uncertainty over the distribution of voluntary contributions. In June 2020, the BGC announced that £100 million of industry funding would be invested in GambleAware over the coming four years⁵¹. GambleAware’s latest accounts shows that funding for 2020/21 was £19 million⁵². Although this is an increase of £9 million on previous years, the timing and volume of future donations remains uncertain, creating limitations for those dependent upon voluntary contributions to deliver prevention and treatment services.

These funds were originally pledged to Lord Chadlington’s charity in June 2019⁵³. There was no public rationale for this change, but it did prompt a response from many British-based academics who drew further attention to the weakness of a system funded by voluntary contributions⁵⁴.

The uncertainty arising from such changes make long-term planning difficult and impedes involvement of well-established research funding and quality assurance infrastructure to improve our understanding of gambling harms. Early engagement with RCUK and NIHR funders was positive but seems to have not progressed beyond initial exploratory conversations.

In July 2020 the House of Lords Committee published its report, advocating an immediate change to funding arrangements⁵⁵. Section 123 of the Gambling Act 2005 (opens in a new tab) allows the Secretary of State to make these changes which are permitted but have never been enacted.

In December 2020, ABSG published its advice to the Commission summarising the evidence and outlining the reasons for supporting a statutory system of funding for treatment, education and research⁵⁶. We continue to have concerns that the Strategy will not achieve its aims without sustained, independent funding for all these.

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⁵¹ Largest BGC members pledge £100million for treatment services (opens in new tab), Betting and Gaming Council, June 2020

⁵² GambleAware publishes donations for 2020-21 (opens in new tab), GambleAware, April 2021. £15.4 million of this comes from the largest four donors – Entain, William Hill, Flutter and Bet365. This suggests a high reliance on a small number of organisations and that voluntary donations from the remainder of the industry significantly lag behind these larger donors.

⁵³ UK gambling firms offer to boost levy branded a bribe (opens in new tab), The Guardian, June 2019

⁵⁴ Open letter from UK based academic scientists to the secretaries of state for digital, culture, media and sport and for health and social care regarding the need for independent funding for the prevention and treatment of gambling harms (opens in new tab), Wardle et al, British Medical Journal 2020:370, July 2020

⁵⁵ Social and economic impact of the gambling industry (opens in new tab), House of Lords, July 2020

⁵⁶ Advice to the Gambling Commission on a statutory levy, ABSG, December 2020

7 Research

ABSG’s advice on the statutory levy recommended that research into gambling should be funded independently of industry. In October 2019, GambleAware gave evidence to the Lords Committee, signalling their intention to withdraw from commissioning research which lay beyond independent evaluations of its work in the delivery of education treatment services.

GambleAware’s Strategy for 2021-26 clarifies this, and signals the intentions to move away from directly collecting and managing datasets, including the Annual Treatment Statistics and the Annual Treatment and Support Survey⁵⁷. In the absence of specific recommendations from PHE and NICE, this has left a vacuum, as yet unfilled by the Research Councils. The Gambling Act Review may well create an opportunity to ensure that there are also funds available to assist with regulatory changes.

Proposals for a data repository have not progressed. This is a missed opportunity, particularly with the rise in online gambling activity which lends itself to greater scrutiny using predictive analytics where access to large anonymised datasets is possible. Recent research using big data from banking as well as large data sets from operators⁵⁸ has provided a window into research that could be generated from an anonymised data repository.

ABSG welcomes the Commission’s recent work to re-design its statistical outputs and industry data for maximum effect. There is some way to progress before data warehousing for research purposes becomes viable, but there is a broad consensus that such a repository is essential to progress in identifying interventions to address harm. Agreeing specific areas of responsibility, timelines and outcomes is essential to achieving the results that are needed.

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⁵⁷ GambleAware Organisational Strategy (opens in new tab), 2021-26

⁵⁸ Exploring online patterns of play: Interim Report (opens in new tab), D.Forrest and I.McHale, NatCen/University of Liverpool/GambleAware, March 2021

Prevention and education

1 Prevention and education

This section reviews progress in relation to the strategic objective of Prevention and Education.

Summary of findings – Prevention and Education

Strengths

• regulatory changes on safer game design and testing more stringent monitoring of ‘high value customers’
• new age restrictions for under-18s on scratchcards and other National Lottery products
• improved use of ad-tech to control marketing online
• customer interaction and affordability consultation
• increased focus and activity on this issue by the financial sector
• new targeted education campaigns and digital innovations
• multi-agency city-wide collaborations
• increased number of support services delivered by and with involvement of people with lived experience of gambling harms.

Weaknesses

• very little progress on addressing gambling related suicide
• limited progress on establishing a single customer view
• slow progress on integration of gambling harm prevention work into existing public health activities and infrastructure
• limited progress on establishing local area data collection to inform prevention and identify harms
• limited evaluation of impact of education campaigns
• limited information to assess the effectiveness of player messaging and other actions taken by industry to reduce harm in its customers.

2 Improved regulatory protections

Industry challenges

The ‘industry challenges’ announced last year have progressed and led to tangible changes which may improve consumer protection. These changes are welcome but need to be monitored for impact and followed up with more emphasis and action to deliver safe products and better support for customers.

Safer game design

The consultation has led to new rules for safer game design, including the removal of ‘auto-play’, increased prominence of players’ balances and prevention of reverse withdrawals⁵⁹. These changes were supported by available evidence, but also represent precautionary action on game design features which are likely to be associated with the risk of harm. ABSG welcome the move to make these requirements mandatory through the LCCP, rather than relying on a voluntary industry code.

Requirements for how operators interact with customers who lose the most money

Schemes for so-called ‘high-value customers’ have been recognised as a key area of risk in enforcement action for some time⁶⁰. ABSG are pleased to see new requirements emerging and welcome the Gambling Commission’s commitment to becoming more proactive in monitoring the impact of these new requirements and to take further action if continued failings are observed.

Ad-tech

An industry code has been implemented to ensure better use of ‘ad-tech’ to avoid young or vulnerable people being targeted by marketing for gambling⁶¹. We note this is a voluntary code and look forward to seeing the evidence of effectiveness which will be carried out by the BGC.

ABSG commends the Commission for promoting a more a rigorous approach, consulting quickly on key issues and mandating requirements where evidence has identified a need to take further precautionary action. However, as with all projects, this needs careful evaluation and greater levels of transparency. ABSG look forward to reporting on evidence of effectiveness in 2022.

National Lottery Age Limits

The Government announced in December 2020 that the minimum age for purchasing National Lottery products would increase from 16 to 18. This change has been made with the aim of protecting young people from gambling-related harm – particularly given the evolution of National Lottery products from weekly draw-based games to a growing trend towards scratchcards and online instant wins. The change will be fully implemented in October 2021⁶².

Single customer view

Progress on developing a single customer view has been less tangible. Highly engaged gamblers have multiple accounts⁶³. There is a clear rationale for taking a holistic approach to a consumers’ data to allow better detection of harmful gambling and more targeted interventions. We are pleased that co-operation will continue between the Commission, the Office of the Information Commissioner (ICO) and the Betting and Gaming Council (BGC) to achieve an effective solution⁶⁴. Input from the financial sector, which also holds data relevant to building a single view of a consumer’s risk of experiencing gambling harms, is also needed. We welcome steps being taken by the Commission to explore the feasibility of access to this data. Key reports published this year concur with ABSG’s position. Data from operators, the financial sector and the Commission, if combined, could form a powerful tool to reduce harms⁶⁵. The creation of a single customer view is essential to progress.

Customer interaction and affordability

In last year’s progress Report, ABSG discussed four categories of metrics which required further regulatory action⁶⁶. Affordability was one of these. Since then, the Commission has consulted on bold plans to enhance and strengthen the requirements on operators to interact with their customers and check their levels of gambling are affordable. Focus on this issue is welcome as published enforcement cases shows failings by operators in this area have been responsible for harm over many years⁶⁷. A review of the Commission’s most recent compliance work shows there is no sign of improvement on the part of the industry⁶⁸. The Commission is currently considering its response to the consultation. It received a large number of responses expressing concerns about proportionality, but equally strong views making the case that regulatory action on affordability would be effective at protecting those at risk of harm.

As with the proposals for a single customer view, we welcome ongoing work between the Commission, UK Finance and the ICO, to explore how operators can have access to information that could inform their customer interactions, whilst acknowledging that operators do have sufficient information on their own customers to be more proactive than they currently appear to be. Recent analysis of 140,000 active accounts across seven operators found that that, during a one-year period, 0.13% of customers are contacted by phone and 3.9% by email⁶⁹.

The Commission will publish its proposals on this in the coming months. ABSG’s position is that there is sufficient evidence to take action now and to introduce mandatory action in this area⁷⁰,⁷¹. Voluntary compliance has not been effective. The evidence of high harms associated with high spend is strong⁷², together with factors such as length of gambling sessions, number and type of gambling activities undertaken⁷³. Recent research using machine learning has shown that a combination of variables are better predictors than single variables to identify those at risk⁷⁴. Further, the evidence of links between harm, spend and deprivation indices supports immediate action to protect those with the least resources⁷⁵,⁷⁶. This needs to take account of research which suggests a rise in use of payday loans and PayPal accounts to fund gambling⁷⁷.

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⁵⁹ Gambling Commission announces package of changes which make online games safer by design, Gambling Commission, February 2021

⁶⁰ Changes to the licence conditions and codes of practice on High Value Customers: Consultation Response, Gambling Commission, September 2020

⁶¹ Gambling Industry Code for Socially Responsible Advertising (PDF) (opens in new tab), Industry Group for Responsible Gambling, January 2021

⁶² https://www.gov.uk/government/news/government-launches-review-to-ensure-gambling-laws-are-fit-for-digital-age (opens in new tab), DCMS, December 2020

⁶³ Gambling participation in 2019: behaviour, awareness and attitudes, Gambling Commission, February 2020

⁶⁴ ICO supports innovative data sharing projects to protect vulnerable people (opens in new tab), Information Commissioner’s Office, January 2021

⁶⁵ Gambling regulation: problem gambling and protection of vulnerable people (opens in new tab), Public Accounts Committee, June 2020

⁶⁶ Progress report on the National Strategy to reduce Gambling Harms, ABSG, June 2021

⁶⁷ National Strategic Assessment 2020, Gambling Commission, November 2020

⁶⁸ Raising Standards for consumers - Compliance and Enforcement report 2019 to 2020, Gambling Commission, December 2020

⁶⁹ Exploring online patterns of play: Interim Report (PDF) (opens in new tab), D.Forrest and I.McHale, NatCen/University of Liverpool/GambleAware, March 2021

⁷⁰ Deriving low‐risk gambling limits from longitudinal data collected in two independent Canadian studies (opens in new tab), Currie et al, Addiction, November 2017

⁷¹ Similar results found in: The development of empirically derived Australian low-risk gambling limits (opens in new tab), Downing et al, 2021.

⁷² The association between gambling and financial, social and health outcomes in big financial data (opens in new tab), Muggleton et al, Nature Human Behaviour 5, February 2021

⁷³ The conceptual framework of harmful gambling: a revised framework for understanding gambling harm (opens in new tab), Hibrecht et al, June 2020

⁷⁴ Gambling spending and its concentration on problem gamblers (opens in new tab), Fiedler et al Journal of Business Research, 2019

⁷⁵ Using machine learning to predict self-exclusion status in online gamblers on PlayNow.com platform in British Columbia (opens in new tab), Finkenworth et al, Sept 2020.

⁷⁶ Our Year One Progress Report recommended operators should be required to publish figures on the number of customers losing more than £500 per month as part of a drive to increase transparency. In the Nordic countries, operators are required to submit losses for the highest 5% of spenders.

⁷⁷ Six-month progress report, LAB Group and City, University of London, February 2021 (forthcoming)

3 Suicide and gambling

Progress by government agencies on prioritising data collection and actions to address gambling-related suicide has been disappointing. There has been no progress on commissioning the psychological autopsy study, and no steps to include gambling disorder in the coronial codes or to mandate training on gambling-related suicides amongst coroners⁷⁸. It has become clear that some of these will only be realised through changes in legislation and concerted action by health professionals and coroners⁷⁹. However, the forthcoming PHE Evidence review (expected in the summer of 2021) will provide new evidence⁸⁰, drawing on a wider range of data sources. We hope that this will provide the impetus for further action by government agencies and third sector organisations. The National Confidential Inquiry into Suicide and Safety in Mental Health (NCIH) is an established centre for the collection of information on all suicides in the UK⁸¹. Although the NCIH has reduced suicide rates, there is currently no link between the NCISH and organisations involved in delivering services to those harmed by gambling and their families.

NHS Digital have begun work on the Adult Psychiatric Morbidity Survey (APMS) for 2022 and there are indications that gambling might be re-introduced into the survey⁸². The House of Lords Committee Report highlighted the importance of action on this issue and its notable absence from the 2014 APMS survey⁸³. The APMS 2022 is an important opportunity to understand this issue in more detail and to look at the impact of online gambling since 2007. We note however, sufficient evidence already exists to demonstrate the need for action on this specific area of gambling harms as an urgent priority.

Despite the lack of progress on new data collection and awareness raising with coroners, the critical importance of the work required to address gambling- related suicide and suicide ideation remains.

Recently published analysis of the existing APMS 2007 dataset provided new insights into the links between gambling and suicide, highlighting high levels of suicide ideation among problem gamblers⁸⁴.

In Scotland, the Strategy Implementation Group is working with Scottish Government, local authorities and health boards to raise awareness and ensure that gambling is recognised in the Scotland-wide Suicide Prevention Strategy, putting people at the centre, and looking to reduce stigma and develop metrics⁸⁵.

A programme of work to learn from Gambling with Lives to utilise lived experience of gambling related suicide to raise public and professional awareness and inform the development of gambling and suicide prevention work across Great Britain⁸⁶.

These initiatives are welcome, but insufficient to achieve the priority focus that this issue requires. Campaigns to reduce gambling-related suicides led by those with lived experience in collaboration with others have emphasised the need for: clear resourcing for population level awareness raising; clear messages about gambling harms; more research on specific gambling products and their association with harm, strategies to address the stigma associated with gambling and adequate resources for peer support networks; and adequate access to help for individuals and their families. We continue to recommend the inclusion of gambling harms in the National Suicide Prevention Strategies for England⁸⁷ and Wales⁸⁸.

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⁷⁸ Report 3, Scoping current evidence and evidence gaps in research on gambling-related suicide (PDF) (opens in new tab), John et al, July 2019

⁷⁹ To place a requirement on coroners to record gambling disorder.

⁸⁰ Gambling-related harms evidence review: scope (opens in new tab), Public Health England, April 2020

⁸¹ National Confidential Inquiry into Suicide and Safety in Mental Health (opens in new tab), University of Manchester

⁸² Problem gambling and suicidal thoughts, suicide attempts and non-suicidal self-harm in England: evidence from the Adult Psychiatric Morbidity Survey 2007 (PDF) (opens in new tab), Wardle et al, GambleAware, May 2019

⁸³ Government response to the House of Lords Gambling Industry Committee Report: Social and Economic Impact of the gambling Industry (page 11) (PDF) (opens in new tab), December 2020

⁸⁴ Problem gambling and suicidality in England: secondary analysis of a representative cross-sectional survey (opens in new tab), Wardle et al, Public health 184, July 2020

⁸⁵ Mental health, Suicide (opens in new tab), Scottish Government

⁸⁶ Gambling with Lives (opens in new tab) - website

⁸⁷ Suicide prevention strategy for England (opens in new tab), Department for Health and Social Care, 2012

⁸⁸ Suicide and self-harm prevention strategy 2015 to 2022 (opens in new tab), Welsh Government

4 Improved profile of gambling harms as a public health issue

There has been progress on improving the profile of gambling harms as a public health issue.

Notable milestones this year include the announcement of the Lancet Public Health Commission on Gambling⁸⁹ and a Public Health Special Issue on Gambling⁹⁰.

The Lancet Commission has an ambitious agenda to guide action to reduce population level gambling harms, to protect people from harms and to provide evidence-based care where needed⁹¹. The need for population level interventions and integrated services is well documented for other forms of addiction and is no less relevant in this context⁹². To have any prospect of preventing harm, particularly in children and other vulnerable groups, it is essential to take a population-wide, public health approach.

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⁸⁹ The Lancet Public Health Commission on gambling (opens in new tab) – this is made up of international academics and is supported by a lived experience advisory group.

⁹⁰ Gambling: An emerging public health challenge (opens in new tab), Public Health Research Network, July 2020

⁹¹ Interventions to reduce the public health burden of gambling-related harms: a mapping review (opens in new tab), Blank et al, The Lancet Public Health, Volume 6:1, January 2021

⁹² New dimensions for hospital services and early detection of disease: A Review from the Lancet Commission into liver disease in the UK (opens in new tab), Williams et al, The Lancet, March 2021

5 Increased engagement from the financial services sector

The increased activity within the financial services sector is a key area of progress. It has the potential to contribute to align with the ‘whole systems approach’ to reducing gambling harms.

This activity is vital given the unique role this sector can play in reducing gambling harms and over the past twelve months progress has continued to accelerate.

Key areas of progress

Major banks, including Lloyds and HSBC, have established specialist support teams to identify and support customers with gambling addictions⁹³. In addition, there has been an increase in the number of major banks introducing gambling blocks, as well as improvements to make these tools more effective. It is estimated that blocking software is now available to around 60% of personal current accounts and 40% of credit cards⁹⁴.

The Money and Mental Health Policy Institute, funded by a regulatory settlement, delivered a conference for financial services firms to discuss and identify best practice in terms of protecting customers from gambling harms. Best practice guidance will be published later in 2021⁹⁵. This work helps join up activity from across the sector to help contribute to improved outcomes for consumers.

One major bank has collaborated in a major research project examining the associations between gambling and social, financial and health outcomes⁹⁶.

The Financial Conduct Authority have published guidance for financial services on identifying vulnerability and have identified gambling as an additional factor in vulnerability⁹⁷. This puts more responsibility on banks and lenders to be aware of customers spend on gambling.

GamBan have proposed the introduction of minimum standards for gambling blocking software, designed to ensure that all products are accessible, effective, responsive accountable and safe. The work to develop these standards was co-produced with people with lived experience and reflects best practise in standards development in health and social care⁹⁸.

GamCare set up an Advisory group on Financial Harm which includes banks and advice and support agencies and launched a Gambling related Financial harm Toolkit in September 2020⁹⁹.

This activity across the financial services sector is positive and we look forward to seeing the industry build on this promising start in future years. It provides new opportunities for consumer protection and enhances the reputation of the financial services sector. There are valuable lessons here on the potential benefits of data sharing for the gambling industry.

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⁹³ Worth the gamble? HSBC UK increases gambling block feature to 72-hours (opens in new tab), HSBC, January 2021

⁹⁴ Bank card blockers: a story of progress (opens in new tab), MMHPI, October 2021

⁹⁵ 3 takeaways from our conference for financial services firms on tackling gambling harms (opens in new tab), MMHPI, October 2020

⁹⁶ The association between gambling and financial, social and health outcomes in big financial data (opens in new tab), Muggleton et al, Nature Human Behaviour 5, February 2021

⁹⁷ Finalised guidance, FG21/1 Guidance for firms on the fair treatment of vulnerable consumers (opens in new tab), FCA, February 2021

⁹⁸ Fundamental standards for blocking software: ensuring quality support for people impacted by difficulties with gambling, Vita CA, GamBan (opens in new tab), March 2021

⁹⁹ Gambling Related Financial Harm (opens in new tab), GamCare (accessed 14 April 2021)

6 Gambling is not yet fully integrated with local public health activity

There have been a number of positive pilots to demonstrate how harm prevention and support for at risk groups can be integrated with wider services and public health activities. Many of these are referred to elsewhere in this report, and include:

• Primary Care Gambling Service, which provides professional development learning and resources for GPs
• Citizens Advice work, funded by GambleAware, to develop systems and training on gambling harms for frontline staff in advice settings
• Surrey Prisons Gambling Service project, funded by GambleAware, to provide screening and support in custodial settings¹⁰⁰
• Pilot project in Hertfordshire by GamCare to provide specialist support to people in the criminal justice system from arrest through to probation¹⁰¹
• Personal Finance Research Centre’s development of resources for the financial services sector.

There has also been good progress in the Greater Manchester collaborative¹⁰², Leeds City Council collaborative¹⁰³ and the Glasgow whole systems approach pilot¹⁰⁴, reflecting a growing potential for people to come forward for treatment and support from a wide range of settings. The Greater Manchester collaborative held a Gambling Harms Inquiry day to explore how gambling harms arise and how people can be better supported.

Although this represents progress in exploring ways that gambling harm reduction activities can be integrated within existing services, there is still a lot of work to do to achieve national system wide changes and secure long-term funding which is not dependent upon voluntary contributions.

In addition to the constraints associated with the voluntary system of funding, one of the key barriers to progress is a lack of data at local authority level. Without this it is difficult for local authorities, who have responsibility for public health, to identify the communities within their population who are most at risk of harm, develop effective prevention policy and strategies, and make the case for prioritising action.

There are some key changes that would help to change this. One is to achieve progress on including a gambling participation and harm questions in the Public Health Outcomes Framework (PHOF) and their equivalents in Scotland and Wales. The PHOF provides annual outcome data for each local authority in England. The information could be obtained via the ONS Labour Force Survey which is UK-wide and as such would also provide consistent data for the devolved nations. Inclusion in PHOF would trigger incentives for local action by local authorities.

Similarly, NHS records do not yet include an option for health practitioners to code gambling harms co-occurring with other harms or mental health conditions. The University College London treatment needs and gap analysis may contribute to the work that needs be led by statutory bodies and we look forward to reporting next year on how this work has been used¹⁰⁵.

We acknowledge that slow progress may be because public bodies have had to re-direct resources towards tackling the effects of Covid-19. The long-term impacts of Covid are yet to be fully understood (such as increased household debt, effects on mental health), but the need for robust data especially at local authority level is likely to be important to both national and local public health Covid-19 recovery planning.

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¹⁰⁰ Foundation Evaluation of Surrey Prisons Gambling Service (opens in new tab), GambleAware, January 2021

¹⁰¹ Hertfordshire pilot on gambling and crime releases final report and recommendations (opens in new tab), GamCare, March 2021

¹⁰² Gambling Commission welcomes new local public health approach to reduce gambling harm in North West, Gambling Commission, January 2021

¹⁰³ Feature Article – Yorkshire and Humber’s Public Health Framework for gambling related harm reduction, Gambling Commission, 2019

¹⁰⁴ A public health approach to reducing gambling harms in Glasgow (opens in new tab), The Health and Social care Alliance, May 2020

¹⁰⁵ Treatment needs and gap analysis in Great Britain, synthesis of findings from a programme of studies (opens in new tab), NatCen, May 2020

7 Increased education and awareness raising activity

Prevention of harm has become even more of a mainstream narrative this year, as more women and sports celebrities¹⁰⁶,¹⁰⁷ have come forward and contributed their stories¹⁰⁸. There has been a notable increase in the number and range of activities in relation to education and awareness raising. This has included activities targeting particular groups, including people from South Asian communities, women¹⁰⁹, students, family members¹¹⁰ and children and young people¹¹¹. These initiatives range from face-to-face workshops to an increasing range of remote learning and digital offers. It is also positive that these activities are increasingly combined with evaluations to learn about what works and why.

Other examples of activity include¹¹³:

• GambleAware has delivered the next phase of their BetRegret campaign. This has focused on young men with high engagement in sports betting. Adverts promote ‘tapping out’ from a betting app as a method of moderating behaviour. The initial independent evaluation results show high levels of awareness of the adverts amongst this target group, and some evidence of behaviour change. It is also noted that this campaign is primarily delivered on TV, whereas operators tend to favour online marketing and advertising when targeting this demographic group. GambleAware will continue to invest in further phases of the campaign roll-out.

• A collaboration between unions, local authorities, local NHS Trusts and Boards and third sector organisations¹¹⁴ to raise awareness of harmful gambling ‘Bet you Can Help’ has been offering remote training for employers and a pledge to address gambling-related harms in the workplace¹¹⁵.

• YGAM is delivering student awareness raising hubs in universities - particularly targeting freshers’ week to increase awareness of gambling harms.

• A number of third sector organisations are involved in work in schools across the three nations. These include:

• Ofqual Level 2 Population Wide Education course on gambling harms for those aged 16+.

• The Curriculum for Excellence in Scotland will also include reference to gambling harms.

• FastForward’s educational development programme in Scotland.

• GambleAware’s work with AQA on embedding gambling harms into its A level Psychology syllabus

• PSHE Association are working with the Department for Education (England) to develop components on gambling for the PHSE curriculum and an evidence review by PSHEA and GambleAware to identify best practice in school-based gambling harm prevention.

• ARA are leading a Youth Outreach Programme for young people and professionals working with young people in Wales.

Although the expansion in educational and awareness raising activity is positive, consistency, co-production, evaluation and strategies for long term funding are vital. Messages must be consistent and clearly targeted, so consumers are not confused by mixed messages and we must understand better what works. The role to be played by the Department for Education (England) in establishing these principles at a strategic level remains unclear.

The gambling industry itself also needs to be more transparent about the data it uses to assess the effectiveness of player messaging about safer gambling and other actions it takes to protect its customers from harm. Without this openness it is not possible to understand what impact is being achieved through the industry’s own actions.

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¹⁰⁶ Former England goalkeeper Peter Shilton admits gambling addiction ruled his life (opens in new tab), Plymouth Herald, July 2020

¹⁰⁷ TalkBanStop – with Michael Chopra (opens in new tab), January 2021

¹⁰⁸ Women and gambling - Women’s hour (opens in new tab), January 2021

¹⁰⁹ Women’s programme (opens in new tab), GamCare

¹¹⁰ GamFam (opens in new tab) - website

¹¹¹ Gambling (opens in new tab), Royal Society for Public Health

¹¹² Don’t bet your life on it (opens in new tab) - website.

¹¹³ Action map, Gambling Commission

¹¹⁴ Beacon Counselling Trust (opens in new tab) - website

¹¹⁵ Harmful gambling workplace charter, interim report, Beacon Counselling Trust, November 2020

Treatment and support

1 Treatment and support

Summary of findings – Treatment and Support

Strengths

• increased involvement of people with lived experience
• some limited expansion of treatment and support in new areas
• increased momentum in primary care involvement alongside whole systems approaches.

Weaknesses

• the evidence base for treatment is developing but incomplete
• lack of agreed screening interventions to identify those at risk
• limited evidence of interventions to monitor and support ongoing recovery
• services are not well integrated
• clarification of referral pathways still required
• limited data on who needs treatment and support
• lack of progress on independent quality assurance
• evidence of poor follow up support emerging
• low take up of treatment and lack of awareness of support available.

2 Expansion of treatment and support services in new areas

GambleAware oversee a network of gambling treatment services, much of which is provided through GamCare and its provider network and some through the NHS. In recent years, this treatment system has made many welcome developments to the availability of its services, including:

• 24-hour operation of the National Gambling Helpline¹¹⁶
• delivery of a programme tailored to the needs of women¹¹⁷
• expansion of an NHS led specialist treatment service for children¹¹⁸
• establishing a lived experience network to inform its development.

Steps have also been taken to obtain more insights into barriers to access for key groups with specific research carried out into the needs of women¹¹⁹ and ethnic minorities¹²⁰.

There is growing recognition that individuals from ethnic minority groups may experience greater levels of gambling harms but not come forward for existing treatment services. This has led to the development of new support led by individuals with lived experience from those communities. Such initiatives reflect the well-established model of treatment and support in New Zealand, where those from Maori and Pacific Island communities provide support for those harmed by gambling in collaboration with mental health practitioner colleagues¹²¹.

There has been growing activity in the provision of identification, treatment and support from local projects across England, Wales and Scotland. In Cheshire, the police force has expanded their work and are now collaborating with twelve other forces in England to develop screening, signposting and awareness training of gambling harms amongst their staff, offering better support for those in custody suites. Examples of other successful pilots include the work of ARA in Wales on early interventions¹²² as well as treatment and the Primary Care Gambling Service in England.

Access to the right support at the right time remains patchy and there continues to be a lack of clarity on how successful pilots will be expanded across Great Britain and how they will be funded in the longer term. The voluntary system of funding impedes long term planning and adequate infrastructure to support these critical new treatment and support services.

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¹¹⁶ National Gambling Helpline to operate 24-hours a day (opens in new tab), GamCare, September 2019

¹¹⁷ Women’s programme (opens in new tab), GamCare

¹¹⁸ NHS to launch young people’s gambling addiction service, NHS, June 2019

¹¹⁹ Women in focus: a secondary data analysis of the gambling Treatment and Support Study (opens in new tab), YouGov, July 2020

¹²⁰ Gambling among adults from Black, Asian and Minority Ethnic communities: a secondary analysis of the Gambling Treatment and Support Study (opens in new tab), YouGov, December 2020

¹²¹ New Zealand National Gambling Study (opens in new tab), AUT Gambling and Addictions Research Centre, September 2020

¹²² PCGS Presentation at GA Conference March 2021

¹²³ Primary Care Gambling Service (opens in new tab) - website

¹²⁴ Pilot embedding questions about gambling harm into online triage platforms, accessed by patients for GP response, Hurley Group/NHSE, Action Map, Gambling Commission, November 2020

3 The evidence base for treatment is developing but incomplete

The NIHR systematic review of the literature on interventions was published in January 2021¹²⁵. It captured over 1,080 records and found only 30 peer reviewed papers that met its criteria for inclusion. Overall, the review found poor quality reporting on gambling treatment studies and high attrition rates in the studies.

CBT showed the most evidence of effectiveness as an intervention¹²⁶. Two clear gaps in evidence were identified – lack of screening interventions to identify individuals at risk and lack of evidence of ongoing support after initial treatment. No whole population screening studies were identified. There were no interventions to support on-going recovery and prevent relapse. One review reported over 50% of all incident problem gambling cases were previous problem gamblers who had relapsed¹²⁷.

Like many others in the sector, ABSG look forward to PHE’s forthcoming evidence review, due to be published in the summer of 2021. This review will provide a comprehensive review of the quantitative and qualitative literature on gambling-related harms, risk factors associated with gambling harms and an analysis of the economic costs associated with gambling harms in the UK. These outputs will provide an important springboard for future work across the system. They will inform policy development, provide further context for measuring the aims of the National Strategy and inform the NICE guidelines work.

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¹²⁵ Interventions to reduce the public health burden of Gambling Related Harms: A mapping review of the international evidence (opens in new tab), Blank et al, NIHR/University of Sheffield (accessed 14 April 2021)

¹²⁶ Gambling and substance use (opens in new tab), Petry et al, ScienceDirect, 2017

¹²⁷ Predictors of relapse in problem gambling: a prospective cohort study (opens in new tab), Smith et al, 2015

4 Need for more integrated treatment services

ABSG have previously referred to the challenges which GambleAware as a third sector organisation face in creating and sustaining an effective well-functioning treatment and system. Advice in 2019¹²⁸ and the first Progress Report in 2020¹²⁹ advocated for a central coordinating role for statutory health and care services working alongside the third sector. ABSG welcomes the on-going commitment shown in GambleAware's recently published five-year strategy to collaborate with NHS partners¹³⁰. In particular, the strategy states that in the ‘mid-term’ NHS/Statutory services will take a greater lead on treatment for gambling harms and in the ‘long-term’ NHS/Statutory services will lead the market, with on-going support from the third sector¹³¹.

Making these changes would place treatment provision on an equal footing with other more established addictions services, access a wider range of professional expertise, more treatment options and greater opportunities to employ for those with lived experience to work within multi-disciplinary teams¹³²,¹³³.

It would also ensure that those in need of help could more easily and readily access a clear treatment pathway. Projects are underway which will provide insights into how more joined up provision could be achieved, such as the Primary Care Gambling Service (Case Study 6) and the Gambling with Lives Effective Care Pathways project (Case Study 7), led by people with lived experience.

It is disappointing to note that the recent announcement of a grant allocation to local authorities in England did not make reference to improving uptake of treatment services for gambling addiction alongside drug and alcohol misuse services¹³⁴.

One area of concern is the continued use of the term ‘National Gambling Treatment Service’ to describe GambleAware-funded services. This appears to be a misnomer, with no equivalents in other third sector-led addiction services. We are concerned this branding of a ‘national service’ creates confusion with NHS services and gives the impression that the desired levels of integration have already been achieved. It creates a risk that national statutory organisations do not take the optimal leadership role in providing integrated treatment services.

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¹²⁸ The Responsible Gambling Strategy Board’s advice on the National Strategy to Reduce Gambling Harms 2019–2022, RGSB, 19 February 2019

¹²⁹ ABSG Progress Report 2020, ABSG, 26 June 2020

¹³⁰ GambleAware Organisational Strategy (opens in new tab), 2021-26

¹³¹ (Page 9) GambleAware Organisational Strategy (opens in new tab), 2021-26

¹³² IAPT positive practice guide for working with people who use drugs and alcohol, DrugScope (opens in new tab), NHS National Treatment Agency for Substance Misuse, January 2012

¹³³ Alcohol Care Teams (opens in new tab), NHS England

¹³⁴ Public health grants to local authorities 2020-21 (opens in new tab), Gov.uk, March 2020

¹³⁵ The care pathway: concepts and theories: an introduction, Schrivers et al, 2012

¹³⁶ Project design phase for Treatment Pathway collaboration project, National Strategy to Reduce Gambling Harms Actions Map, Gambling Commission (accessed 14 April 2021)

¹³⁷ Clinical pathways as a quality strategy, Potter et al, 2019

5 Clarification of referral pathways required

ABSG has noted weaknesses in the current arrangements. These are driven in part by funding arrangements and geographical coverage, but also lack of full agreement on triage assessments and cut-off thresholds for referrals between the different organisations providing treatment and support services. Whilst there is commitment in principle to joint-working between the NHS and the third sector in some parts of the UK, there is an urgent need for more work to improve the level of integration and mutual trust that is essential to effective referral pathways – both into gambling treatment and support services – and between the providers currently offering these services.

GambleAware’s Annual Treatment Statistics for 2019/20, shown in the following table, indicate that over 90% of those accessing treatment and support from the current system self-refer. No other service or source provides a significant number of referrals. This suggests that mainstream providers may not know where to signpost those who need help. This suggests that referral routes need to be strengthened, both between providers in the gambling-specific services provided by GambleAware and the NHS, but also with the wider network of organisations who provide supporting services and come into contact with people who may need more specialist treatment or help.

The data in Table 2 also supports concerns about the accessibility of treatment, with a relatively small number accessing treatment when compared to numbers estimated to be problem or moderate risk gamblers.

Table 1: Referrals to GambleAware funded treatment services 2019/20¹³⁸

Referrals from	Number	Percentage (%)
Self-referral	6,879	92.2%
Other service or agency	152	2.0%
Prison	109	1.5%
GP	107	1.4%
Mental health NHS Trust	70	0.9%
Other primary health care	65	0.9%
Probation service	23	0.3%
Social services	16	0.2%
Employer	12	0.2%
Police	9	0.2%
Others (including): Drug misuse services, Carer, Independent sector mental health services, Jobcentre Plus, A&E department.	17	0.2%
Total	7,459	100%

Data in Table 2 also shows a very low number of onward referrals. In total, fewer than 100 clients (1.6%) were referred on for other forms of treatment over twelve months. Again, this appears to show a treatment system operating largely independently of wider services, rather than in a joined-up manner that would characterise a genuinely national treatment system.

Table 2: Reasons for exit from GambleAware funded services 2019/20¹³⁹

Reason for exit	Number	Percentage (%)
Completed scheduled treatment	3,905	66.3%
Dropped out	1,542	26.2%
Discharged by agreement	330	5.6%
Referred on to other services (assessed and treated)	82	1.4%
Referred on (assessed only)	13	0.2%
Not known	13	0.2%
Deceased	2	0.0%
Total	5,887	100%

One of the consequences of the delay to NICE guidelines is that there is still ambiguity on referral protocols. Efforts have been made by the partners but this ambiguity makes it difficult to have confidence that service users are always directed to support that best meets their needs. In the meantime, we recommend that progress is accelerated towards establishing clear referral pathways between all partners responsible for delivering treatment and support services for those experiencing gambling harms. What is required going forward is a clear map of a gambling treatment ‘ecosystem’ with roles defined and understood.

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¹³⁸ (Page 23) Annual Statistics from the National Gambling Treatment Service (GB), 1st April 2019 to 31st March 2020 (opens in new tab), GambleAware, October 2020

¹³⁹ (Page 25) Annual Statistics from the National Gambling Treatment Service (GB), 1st April 2019 to 31st March 2020 (opens in new tab), GambleAware, October 2020

6 Triage and completed treatments

Despite best efforts by the partners, this data illustrates the lack of clearly agreed criteria and thresholds for movement through referral pathways that continue to present challenges in the current treatment and support system.

GamCare currently receives calls to the National Problem Gambling Helpline and, when appropriate, offer an onward referral for assessment by one of the network’s treatment providers. At this stage a second assessment is made by the provider. There is also an agreed pathway in place with the Gordon Moody Association with data sharing agreements and software portals to facilitate this.

Although the current system may work for some, a two-stage triage process is not consistent with established best practice as it means that an individual can pass through several stages until a clear referral can be made. Individuals can move in and out of harm quickly – so a timely triage system is important. Evidence from other addictions services suggests that access to highly specialist expertise at the triage stage can lead to better outcomes in the longer term¹⁴⁰,¹⁴¹. Adoption of a combination of widely used standardised assessment measures are needed such as the PGSI, Enhanced Core 10, GAD-7, PHQ-9. The CORE-10, GAD-7 and PHQ-9 are routinely used within IAPT and mental health services so will align with referral routes into IAPT/mental health provision. We note that progress is being made towards agreeing use of screening and other clinical tools.

The GambleAware National Treatment Statistics for 2019/20 suggest that the number of completed treatments appears to be lower than might be expected. Overall, 26.2% of clients leave the service before the scheduled endpoint of seven sessions. Those who are unemployed have the highest attrition rate at 32% and are the least likely to complete treatment (61%)¹⁴². Affected others who use the service have a lower rate of leaving the service before completion at 13%

Research into the treatment of alcohol and drug use, however, suggests that treatment outcomes generally improve as retention in treatment increases. Treatment completion is also linked to better outcomes¹⁴³. From this research it has been suggested that if clients fail to complete treatment, attrition typically occurs early on in treatment and that retention may be one amongst a number of indicators of a mismatch between the treatment offered and the needs of the client seeking help.

An important next step in the process of developing effective treatment responses for gambling is a more joined up and integrated approach that is centrally co-ordinated by statutory services in collaboration with third sector providers, playing to each other’s strengths and with investment in a wider range of interventions such as social prescribing, bringing recovery communities together and agreeing education and training standards. Such an approach would provide improved co-ordination of services, triage and treatment retention.

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¹⁴⁰ The public health burden of alcohol and the effectiveness and cost-effectiveness of alcohol control policies: an evidence review (opens in new tab), Burton R, Henn C, Lavoie D, et al, Public Health England, 2016

¹⁴¹ Alcohol Care teams, Identification and Brief Advice, Moriarty KJ. Frontline Gastroenterology, 2020: “Alcohol assertive outreach teams (AAOTs) and specialist treatment for dependent drinkers were cost-effective; every £1 invested brings an annual return of £3, which rises to £26 over 10 years. Psychosocial interventions for dependent drinkers can save the overall UK economy £5 for every £1 invested”.

¹⁴² Annual Statistics from the National Gambling Treatment Service (Great Britain) 1st April 2019 to 31st March 2020 (opens in new tab), GambleAware, October 2020

¹⁴³ Relationship between drugs treatment, retention and outcomes, Hser et al, 2004 (opens in new tab)

7 Lack of independent quality assurance

In England, Care Quality Commission (CQC) involvement and assessment has not progressed during the year, in part because of the challenges posed by Covid-19. CQC continue to give assurance that they will engage with the treatment sector and are exploring ways of delivering virtual inspections.

This is a model that could create opportunities to expand engagement and extend the work with gambling treatment services. ABSG continue to stress the importance of external quality assurance in addition to any investment in internal QA processes by individual providers in England, Scotland, and Wales¹⁴⁴.

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¹⁴⁴ Healthcare Improvement Scotland and the Care Inspectorate (opens in new tab) - website

8 Follow-up support

The NIHR review highlighted high levels of recurrence in the treatment literature. Our observations suggest that the protocols for follow up support to prevent recurrence remain unclear, and there is potential for improvement. The current face to face treatment system appears to rely heavily on counselling (98%) compared with only 2% who receive CBT intervention.

The evidence reviewed by NIHR suggests that self-guided therapies alone may have limited impact, particularly over the longer term. A key priority for the coming year will be to invest resources in identifying recurrence risk factors, identifying causes of addictive behaviours and co-occurring conditions such as depression, anxiety, and other mental health challenges as well as debt and other financial consequences.

One recent study found that young people who experience problem gambling are at heightened risk of suicide ideation regardless of other pre-existing conditions¹⁴⁵. In parallel with work by Links Workers and financial advice support attached to GP practices in Scotland¹⁴⁶, the PCGS in England¹⁴⁷ is piloting the value of social prescribing for individuals who use their service.

These pilots, along with new developments such as GamLEARN and player led-digital innovations¹⁴⁸, will inform this under-researched area and offer support at an earlier stage.

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¹⁴⁵ Suicidality and gambling among young adults in Great Britain: results from a cross sectional survey (opens in new tab), Wardle et al, 2021

¹⁴⁶ Welfare and advice partnerships (opens in new tab), Scottish Government, March 2021

¹⁴⁷ Primary Care Gambling Service (opens in new tab)

¹⁴⁸ Don’t bet your life on it (opens in new tab)

Conclusions

There have been signs of progress towards reducing gambling harms across Scotland, Wales, and England over the past year. The change in mindset about the risks associated with gambling harms as well as the imperative for a multi-agency effort is underway.

Key stakeholders from statutory and third sector organisations have been working together to take action on prevention and treatment. Public health approaches to addressing harm are emerging in Scotland, Wales and regions in England. However, issues in treatment provision, outcome measurement, independent quality assurance and sustainable independent funding remain unresolved.

The involvement of people with lived experience has increased, both nationally and locally and this needs to continue if the Strategy is to succeed. The Commission has strengthened its regulatory interventions on game design and age limits and there is momentum behind further interventions to improve protection. We look forward to the outcomes of work on industry metrics, affordability, customer interaction and the single customer view.

What is also essential to this change in mindset is more research on products and their relationship to risk. Gambling operators have their own insights and we encourage them to share these. Evidence aligns with the views of those with lived experience that type of play, product design, accessibility and marketing are key and have an impact on habits, levels of spend¹⁴⁹ and harm¹⁵⁰.

ABSG has welcomed the Government’s review of the Gambling Act 2005 and the interest that this has generated in addressing gambling harms. However, the process of updating legislation is lengthy, and the momentum to further strengthen regulatory protections in parallel with the review should continue at pace.

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¹⁴⁹ Exploring online patterns of play, Interim Report (opens in new tab), University of Liverpool, NatCen, March 2021

¹⁵⁰ Biddable Youth (opens in new tab), University of Bristol, 2019

Annex 1: Priority Metrics for measurement of National Strategy to Reduce Gambling Harms

A list of recommended impact and outcome metrics was provided in the Year One Progress report. The following information provides a summary of those recommendations on impact - focusing on the key areas:

• where data is required
• how this could be obtained
• the key partners in the strategy who can make this happen.

Partnerships, led by government departments in the three nations, are best placed to provide the leadership to make progress. Once a baseline is established a key performance indicator (KPI) for reduction could be set. It will be important for this to be done in a way that allows identification of differences by age, ethnicity, geography and other social-economic factors. Without action to establish goals, metrics and a baseline position, there will continue to be limited progress on reporting impact.

Topic	Data sources which could be used to create baseline	KPI goal – to be set once baseline is established	Key partners
Gambling-related suicides	Coroner records and Procurator Fiscal – and research working with coroners/PFs Banks - including data on accounts closed because of mortality. Adult Psychiatric Morbidity Index 2022	It is recommended that challenging targets should be set for: zero gambling-related suicides zero suicide ideation	Coroners and Procurator Fiscals Banks DHSC Research Councils UK and other health and public health research funders.
Gambling-related debt, bankruptcy and other financial harms	Data from the financial services sector Data on people seeking support in relation to debt – where gambling is a contributing factor. Data from other supporting services	Establish goal for % reduction in baseline	Financial sector – including banks and other lenders Citizens Advice and other third sector debt advice and supporting services Trussell Trust (Food banks) Research Councils UK and other health and public health research funders.
gambling-related homelessness	Data on homelessness caused by or associated with gambling. Public Health Outcomes Framework	Establish goal for % reduction in baseline	Local authorities Shelter and other third sector organisations Public Health England, Public Health Scotland, Public Health Wales. Research Councils UK and other health and public health research funders.
gambling-related loss of employment	Data on factors leading to unemployment and negative impacts on employment.	Establish goal for % reduction in baseline	JobCentrePlus Department for Work and Pensions Chambers of Commerce Citizens Advice Bureau Research Councils UK and other health and public health research funders.
Gambling-related domestic abuse and partner violence	Data on links between gambling and domestic violence.	Establish goal for % reduction in baseline	Courts Police Third sector e.g., NSPCC, Refuge Police. NHS Research Councils UK and other health and public health research funders.
Establish baseline data on gambling-related crime	Numbers of convictions and arrests where gambling is an associated factor.	Establish goal for % reduction in baseline	Courts Police Prisons Research Councils UK and other health and public health research funders.
Gambling-related mental health	Numbers seeking support for mental health problems where gambling is an associated factor.	Establish goal for % reduction in baseline	NHS Mental health support services and charities – e.g., MIND Research Councils UK and other health and public health research funders.