Culture, Media and Sport Committee - The Gambling Act 2005: A bet worth taking?<?oasys [np ?> Written evidence submitted by the Responsible Gambling Fund
This submission relates to the Committee’s second term of reference (the Gambling Act and the young and vulnerable).
The Responsible Gambling Fund (RGF) exists to promote understanding of risk and harm from problem gambling, to inform people about these and help the vulnerable to avoid them. It aims to minimize such harm and fund initiatives to help and treat those affected in a coherent fashion based on evidence and recognised good practice. These objectives match those of the 2005 Act and the Committee’s concern for vulnerable people. Although problem gambling rates remain low in the UK, it is clear from prevalence studies that many who would benefit from help are not currently accessing it and many more are at risk of harm.
RGF is a charity established in 2009 to implement the third element of the tripartite structure established to deliver clear separation between formulation of research, education and treatment (RET) policies, the generation of funding and the actual commissioning and funding of RET activities, undertaken respectively by the Responsible Gambling Strategy Board (RGSB, established by the Gambling Commission), the GREaT Foundation (GREaT) and RGF (created from the voluntary arrangements that had previously resided in the Responsibility in Gambling Trust).
RGF funds research and education as well as treatment, takes a strategic approach to problem gamblers’ needs, and evaluates work to ensure that it fulfils its purpose, provides learning and gives value-for-money. During 2010–11 it made grants and contracts worth £5.7 million.
The work of RGF’s first 16 months is summarised at section 2. It is early days, but benefits are already apparent from the more systematic and strategic approach to work on problem gambling sought by the 2008 review. These include developing quality assurance standards for treatment, pilots to broaden the range of care available, such as brief interventions, and a professional development programme with the Royal College of GPs to improve identification of problem gamblers by primary healthcare workers. A programme of harm reduction for young people is building on links with policy and practice developments in the voluntary and statutory youth sector. RGF is developing a standardised reporting framework for collecting data about those seeking help, to inform researchers, practitioners and policy makers about the characteristics, gambling activities and treatment experiences of problem gamblers.
RGF will support the GREaT Foundation’s task of fundraising in the gambling industry by proper accountability for its spending to GREaT and by aiding GREaT in communicating plans and achievements to donors. GREaT has received donations for the minimum guaranteed £5m in the first two years and expects to do so again in 2011–12. The funding targets agreed on establishment of the tripartite system have not yet been met, which has impacted on RGF’s ability to fulfil all expectations of the 2009 Strategy.
Effective working relations between RGF and GREaT are of critical importance, with accountability from RGF to GREaT for its annual grant, and from GREaT to its donors requiring different but complementary activities. RGF will continue to seek arrangements which implement the strategic level of accountability originally agreed (with RGF drawing down funds from GREaT in quarterly tranches on the basis of high-level information about programmes, commitments and spend). The two charities should work together on communicating aims and achievements to respective stakeholders.
Fully operational since spring 2010, RGF has developed effective relationships with many, including care and support deliverers, researchers and medical professionals. It has continued to date to support pre-existing treatment infrastructure providing counselling across much of Britain. For example, the National Problem Gambling Clinic and the Gordon Moody Association have 18 months’ grant funding from April 2011 and we are working closely with GamCare to deliver similar arrangements. We are also exploring with GamCare, as a priority, the potential for providing a two year grant to help build on the success of the industry’s current investment in telephone support, run by GamCare, to develop a National Gambling Helpline, delivering a step change in the level of service provision, coverage and cost-effectiveness.
RGF developed its grantmaking methodology drawing on voluntary and statutory sector best practice, designed for accountability, effectiveness and value-for-money. It is not within RGF’s mandate to give unconditional core funding for programmes of work determined outside a national strategy or insulated from disciplines designed to ensure relevance, effectiveness and value-for-money. Such funding by donation, rather than grants against standard terms and conditions has long been regarded as poor practice in the charitable foundation and grant-making world.
Despite its respect for GamCare, which in 2010–11 was awarded a grant equivalent to 40% of RGF’s total expenditure, RGF is deeply concerned that it has not thus far engaged with RGF grant arrangements, and is working hard to resolve this impasse. Facilitated discussions are taking place as this submission is sent. A further note will be added after the deadline if necessary.
Origins and Purpose
1. RGF’s charitable objects are public benefit by research into the types of addictive gambling, causes of problem gambling and the effectiveness of treatments and education/harm prevention initiatives, and by funding help including treatment and advice for those vulnerable or in need because of gambling.
2. With the RGSB and GREaT, RGF is part of voluntary arrangements for RET negotiated in 2008 as an alternative to the introduction of a statutory levy under powers in the 2005 Act. RGF draws on a strategy developed by RGSB and its expert panels: to help deliver value-for-money, the two share premises, secretariat, several board members and a Chair, Baroness Neuberger. RGF trustees include experts in treatment and research, a past Chair of the Gambling Commission, the Chief Executive of the National Lottery Commission, an emeritus professor of Law and a past Chief Charity Commissioner.
3. Before the creation of the current structure in 2008, a Gambling Commission review1 had concluded after consultation: that research and education were underfunded in relation to treatment; that existing treatment concentrated too much on historical and ad hoc arrangements; that not enough attention had been paid to commissioning work to meet evidence-based needs; and that there had been insufficient emphasis on evaluation, setting goals and measuring outcomes against them.2
4. RGF is developing programmes to fill gaps in research and education, and to address past shortcomings in the specification and evaluation of treatment. This involves moving away from grant arrangements which required little structured evaluation of results and therefore gave limited assurance about effectiveness and value-for-money. RGF is moving to a commissioning approach, in which the outcomes required are specified with reference to a national strategy, delivery and cost are systematically monitored, effectiveness and value-for-money are properly evaluated and lessons for the future are captured. Such lessons are shared between providers, used to inform the gambling industry, fed into the strategic work of RGSB, and through it into the work of the Gambling Commission and its advice to Government.
5. RGF uses the single annual grant it receives from the GREaT Foundation to offer grants and contracts, working through partnerships. Grants may be awarded after open competitive or limited application processes, or from targeted invitations to apply. Each workstream uses the best delivery mechanism, judged on practical, financial, pragmatic, and quality reasons.
6. RGF’s research programme aims to provide the evidence base to allow effective education/harm prevention and treatment to be designed and delivered. It is intended to inform RGF’s future planning, RGSB’s strategy development, and where applicable, the Gambling Commission and others.
7. A three-part study on gaming machines has started by mapping the distribution of machines and “overlaying” this across socio-demographic data, aiming to provide better evidence for debates about gambling in particular neighbourhood types. The findings will inform other studies, including the analysis of treatment methods and National Gambling Helpline data about the gambling behaviour of those seeking help. A second project will enhance understanding of particular machine features and how consumers interact with them. A third will examine consumer self-limitation and self-exclusion, and how gamblers themselves, gambling operators, and the regulator can support pragmatic and effective approaches.
8. Map-the-Gap, to be published summer 2011, will assess current knowledge of areas including consumer self-help; advertising; specific demographic groups; effectiveness of prevention/education initiatives; and best practice in corporate social responsibility. The report will assess the applicability of existing studies to the UK situation and aid the RGSB in research strategy development.
9. During 2011–12 RGF will support research in existing key areas, plus those from Map-the-Gap, using secondary analysis of the data from BGPS 2010. Priority will go to those that inform RGF’s treatment and harm-prevention programmes. To broaden research capacity, RGF continues to make grants to PhD students.
Education and Harm Prevention
10. Work underway includes development of harm prevention with students and with parents and children. Work with the Royal College of GPs will train GPs to identify harm and risk and support those affected. This will be broadened to other “front-line” care-providers. Other workforce activity includes National Occupational Standards for those working with gamblers at risk and others affected. A three-year programme of work with youth organisations will use their experience of communicating risk and identifying and advising vulnerable young people.
11. Funding has been offered to three major treatment providers as described above. During 2010–11 they, and many providers indirectly funded via GamCare, participated in developing clinical governance standards, a national data-reporting framework and the first external evaluation of the impact of the funding of organisations by RGF and its predecessors.
National Gambling Helpline
12. Strategy 2009 developed the recommendation in the RET review for a National Gambling Helpline. The industry has funded the development and maintenance of an existing telephone line, run by GamCare. We now believe the time is right to seek a new level of service, coverage and cost-effectiveness, reflecting advice from the Helpline Association, to maximise the return on the industry’s investment.
13. RGF is therefore committed to funding this step change in provision, working with service providers to deliver a helpline which reflects the best practice in the field, with proven value for money, and which builds in effective mechanisms of data collection and analysis to inform the development of treatment and harm prevention. This helpline must:
have a memorable and easily-found name;
provide information about gambling-related harm; and
and offer immediate support and suggestions to those seeking help for themselves or others.
14. In 2010–11 RGF developed the specification for this service and offered the opportunity to GamCare by single tender, to put it in the best possible position to contribute its expertise to delivering the development that will deliver greatest value for the industry’s investment.
15. The eventual transition to the National Gambling Helpline will be undertaken with expert guidance from the Helpline Association and from partners in the voluntary sector and industry who will be promoting the new service. The transition will be phased, to reduce costs of “refreshment” of existing promotional materials.
Treatment and Harm Prevention projects
16. During 2010–11 RGF committed £1.6 million to its Gambling Risk and Harm Minimisation (GRaHM) pilot programme. Three organisations have been awarded grants for work over three years bringing together local community providers to promote early identification of gambling-related harm and develop alternative help for those who may not engage with, or require, counselling, and to identify high risk groups not currently accessing services. Brief interventions, similar to those used for other addictions, will be tested for cost-effectiveness as will group work, self-help and targeted activity. Evaluation will consider how successful programmes can be sustained after initial investment and the possibilities for replication elsewhere.
2011–12 and beyond
17. RGSB and external views, and the early work of the GRaHM pilots, suggest benefits if the three workstreams of RET are not seen as exclusive activities. In line with approaches to interventions in public health generally, RGF sees that prevention, education and treatment services can form a continuum, in terms of their relevance for individuals who have experienced and/or are at risk of gambling-related harm. (see diagram below). RGF may not fund all elements, but will seek to evaluate and support (financially or otherwise) development of most aspects, perhaps as pilots or as evidence of efficacy is proven.
18. Competitive commissioning for treatment services will be central to work in 2012–13. RGF will by then have consulted stakeholders about the outcomes it seeks. RGF will make grants on best-value criteria, and fund projects that demonstrate cost-effective and efficient services.
19. The Harm Prevention programme will build on earlier work on ways to minimise risk in vulnerable groups, including children and young people, who may be affected through their own gambling, or as affected family members. We hope also to work with the criminal justice system, with prisons, the court and probation services.
20. Research will continue to be targeted on gaps identified by Map the Gap and to inform treatment and prevention initiatives and the RGSB’s strategy development.
21. The funding target agreed with the industry was initially set at £5 million, £6 million and £7.2 million for the financial years 2009–10, 2010–11 and 2011–12. To date, GREaT has successfully raised the guaranteed sum of £5 million from its donors per financial year. With little impartial information available about the efficacy and cost of helping those affected by gambling related harm, these funding levels were agreed to allow RGF to begin its work. RGF will, during 2011–12, report on new indicators of what has been achieved with investments to date, (subject to treatment providers’ participation) and will be supporting systems and research to better inform future funding targets. A funding agreement is in place between the GREaT Foundation and RGF which sets out mutual financial and accountability expectations and the funding targets above.
22. RGF has the equivalent of 3.5 full time members of staff and shares an executive with the RGSB. It supplements this team with the expertise of trustees and RGSB Board and Panel members, and specialists bringing knowledge and experience—and external perspective—that it could not affordably hold within the small staff complement.
23. The RET Review suggested that the new system, despite the additional costs of evaluation and full accountability compared with the predecessor body RiGT, should be able to be run by spending a similar proportion of its total expenditure on running costs. Unaudited figures for 2010–11 indicate that the combined running costs of GREaT and RGF were 10% of total expenditure (RiGT in 2008/09 was 10% - RET Review). Of this, RGF’s running costs were under £350,000, or 6% of its own expenditure for the year.
24. The 2008 RET Review highlighted an uneven degree of acceptance across the gambling industry that although gambling is a mainstream leisure activity, it does carry a risk of significant personal and/or social harm. By contrast, many of the major commercial operators now fully recognise the importance of a socially responsible approach to the ways on which they market their products. This is reflected in part by industry membership of RGSB and of its Research Panel.
25. The 2010 British Gambling Prevalence Survey confirms that though a small proportion of all gamblers display problems or are at risk of harm, the risk has continued to be present. But it is also appears that some parts of the industry continue to regard all RET activity as a commercial threat, believing that research in particular will expose them to criticism. For this reason they would prefer to see their donations going only towards the treatment of those with the most severe problems. But the properly conducted, independent, and peer-reviewed research that RGF funds need not pose any threat to the responsible operator. On the contrary, it may show that some popularly-held beliefs about problem gambling are misplaced; at the very least it may identify what interventions can be most effective in treating those who do present problems with their gambling, a goal to which RGF believes that all in the industry subscribe. In these circumstances, what RGF can do is seek to demonstrate value for money in what it funds and offer accountability to GREaT and the industry, while also looking to GREaT and its contributors to accept, as the 2008 arrangements envisaged, that the industry has a responsibility to support RET into problem gambling.
Funding from industry
26. With lower levels of funds than hoped, some aspects of the RGSB’s Strategy cannot yet be addressed. There is little flexibility within the budget for 2011/12 for RGF to review the proportion of funding to each area of activity.
27. RGF’s move away from unconditional core funding with few strings attached to commissioning work in support of a national strategy, and the new emphasis on monitoring and evaluating effectiveness and value-for-money, has meant adopting best practice for making and managing grants. This approach which makes providers accountable for their spending and results, is nothing which anyone receiving substantial funding from foundations or Lottery distributors would find unfamiliar.
28. It is, however, a fairly radical departure from the arrangements in place under the predecessor arrangements although RIGT was proposing just such a move. It is therefore perhaps not surprising that a period of adjustment has proved to be necessary in the move from the previous, essentially donation-based, system. We continue to work with existing providers to help with the transition to a modernised regime.
29. However, GamCare has found the adjustment particularly difficult, perhaps inevitably, given the limited accountability requirements of past funding. RGF will continue to seek a solution to the poor relationship with GamCare, and at the time of submission is engaged in a facilitated discussion with GamCare with this aim.
30. RGF recognises the strong appetite for improved communication about problem gambling and how RGSB/RGF address it, with a particular emphasis on dispelling myths and doubts about the value of RET in the industry. In particular, there is work to be done to explain that research commissioned by the RGF contains no inherent threat to the industry, but can assist in the identification and minimisation of harm, thus supporting responsible gambling. RGF welcomes the part that GREaT and the Gambling Commission can play in promoting such communication. GREaT should be well placed to robustly affirm that RGF is using industry donations properly and to provide summaries and news in appropriate language and media for those who contribute. RGF communicates with a range of stakeholders and interest groups and will necessarily be addressing the voluntary and statutory sectors, academics and clinicians, amongst others, as well as the gambling industry.
31. The work of the RGF, while it does not depend on the provisions of the 2005 Act, directly furthers its object of protecting the vulnerable. In problem gamblers’ interests, RGF has worked purposefully and with impact to make the 2008 voluntary arrangements for RET work, but it has encountered difficulty and its sustainability is not assured. The implications are discussed above and the main points summarised on the first page of this submission.
1 Final report and recommendations, Gambling Commission, 17 October 2008.
2 Report, para 1.4.