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Preventing and Minimising Problem Gambling Harm 2007-2010 Three Year Service Plan

Summary of Submissions

Ministry of Health

8 November 2006

P R E V E N T I N G A N D M I N I M I S I N G G A M B L I N G H A R M 2 0 0 7 - 2 0 1 0 S U M M A R Y O F S U B M I S S I O N S

Contents

1. Introduction 11.1 Background 11.2 Consultation process 11.3 Submissions received 21.4 Analysis of submissions 31.5 Report structure 4

Analysis of Submissions 5

2. Summary of Themes 62.1 Overarching themes 62.1 Overview of stakeholder feedback 7

3. Feedback on Three-Year Service Plan 2007-2010 8

3.1 Introduction 83.2 Overall perceptions of the service plan 83.3 Public Health 143.4 Intervention services 213.5 Research 27

4. Needs Assessment 30

5. Problem Gambling Levy Calculations 2007-2010 31

5.1 Levy amount 315.2 Levy formula 325.3 Levy weightings 35

6. Other Comments 39

APPENDIX 411. Submission names and numbers 412. Editing 44

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1. Introduction

1.1 Background

Parliament passed the Gambling Act in 2003. One of the Act’s purposes is to ‘prevent and minimise the harm caused by gambling, including problem gambling’. The Ministry of Health was allocated responsibility for developing and implementing an integrated problem gambling strategy, which the Act states must include:

Measures to promote public health by preventing and minimising harm from gambling

Services to treat and assist problem gamblers and their families and whanau

Independent scientific research associated with gambling, (e.g. longitudinal research on the social and economic impacts of gambling, particularly the impacts on different cultural groups)

Evaluation.

The Ministry of Health assumed responsibility for funding and co-ordinating problem gambling services in July 2004. The services are funded through a Vote: Health allocation. The Crown recovers the cost of developing and implementing the strategy through a levy on gambling operators.

The current funding plan expires on 30 June 2007. The Ministry sought feedback on these draft documents to enable further implementation of its strategic plan 2004-2010:

Three-Year Service Plan 2007-2010

Problem Gambling Needs Assessment 2006

Problem Gambling Levy Calculations 2007-2010.

These three documents were presented together for the purposes of consultation.

1.2 Consultation process

In accordance with the Act’s requirements, the Ministry of Health conducted a two-stage consultation process:

1. Public meetings

Five public meetings were held in Auckland, Hamilton, Wellington, Christchurch and Dunedin during the consultation period. Two further meetings were held in Wellington with government officials and representatives from the gambling industry.

The public meetings aimed to: Set the context and provide attendees with a brief update of the Ministry’s work plan to

date

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Provide opportunities for participants to discuss the questions posed by the Ministry, and outlined in the draft document for consultation

Provide a forum for the Ministry to clarify any specific components on the document and its rationale or approach.

Table 1: Details of attendee numbersMeeting location No. of attendees1. Auckland 382. Hamilton 193. Wellington 194. Christchurch 255. Dunedin 286. Wellington (Government agencies) 37. Wellington (Gambling industry) 9

2. Written submissions

Opportunity was given for other members of the public and key stakeholders to feed in written submissions via:

Placement of the consultation document on the Ministry of Health’s problem gambling webpage ( www.moh.govt.nz/problemgambling)

Email invitations to submit ( [email protected])

Written correspondence.The consultation period for written submissions was 4 August to 29 September 2006.

1.3 Submissions received

In total, 978 submissions representing a range of groups and individuals were received.

A significant number of duplicate submissions were received. As agreed with the Ministry of Health, multiple identical submissions, (i.e. duplicates), were treated as one submission. This ensures that all original comments are treated equally.

The following details the duplicate submissions and the submission analysed and coded:

3 to 6 (analysed as ‘3’)

9 to16 (analysed as ‘9’)

19 and 211 (analysed as ‘19’)

18, 75, 76, 81, 219, 220, 221, 222, 760, 766 (analysed as ‘219’). Note: Some of these submissions also provided non-duplicate information, which was duly analysed and coded

22 to 74, 89 to 209, 223 to 275, 286 to 311, 313 to 350, 352 to 677, 679 to 758, 767 to 979 (analysed as ‘22’). Note: 607 filled out by same person as 581.

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mailto:[email protected]

http://www.moh.govt.nz/problemgambling


The following table summarises the number of submissions analysed by submitter category.

A total of 55 submissions were analysed.

Table 2: Number of submissions analysed by stakeholder group Problem Gambling Service Providers

14 submissions (1, 77, 80, 82, 83, 84, 88, 212, 215, 218, 277, 279, 759, 761)

Other NGOs 13 submissions (8, 9, 15, 20, 78, 86, 87, 214, 216, 278, 281, 351, 763)

Individual 10 submissions (3, 7, 17, 21, 22, 79, 219, 282, 764, 765)Industry 9 submissions (11, 85, 210, 213, 276,

280, 284, 285A, 678)Territorial Local Authorities (TLAs)

4 submissions (2, 10, 19, 217)

Academic 3 submissions (14, 283, 762)Core Government Departments

2 submissions (12, 13)

Total 55 submissions

1.4 Analysis of submissions

Submissions received on the Preventing and Minimising Gambling Harm 2007-2010 consultation document were thoroughly reviewed and considered.

Codes were developed for comments, issues and recommendations raised by more than one submitter. A code is defined as a comment, issue or recommendation that explicitly or implicitly was stated by submitters in submissions, either relevant to, or out of scope of the consultation document. Submitters were assigned one or more codes, depending on the content of their submission. If appropriate, one-off points made by submitters were also noted.

This report details the key themes arising across submissions on the consultation document. It endeavours to capture in a concise and exact form the content, tone and flavour of written submissions.

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1.5 Report structure

This report summarises the analysis of submissions and is set out as follows:

Section 2 provides an overview of key themes, and themes by stakeholder groups

Section 3 sets out a summary of themes and issues raised by submitters on the three-year service plan

Section 4 details feedback on the needs assessment

Section 5 summarises feedback on the problem gambling levy amount, formula and weightings

Section 6 details one-off comments and other themes

Appended is a list of those who agreed to be named in this report and editing comments.

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Analysis of Submissions

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2. Summary of Themes

2.1 Overarching themes

Across the submissions, there is a diverse and differing range of opinion about the service plan, needs assessment and levy calculations. Detailed below is a summary of the key themes emerging.

Service Plan

Divided opinion on funding allocation for the plan. Non-industry related submitters tend to comment that there is inadequate funding to meet current and future service demand. However, industry perceives that the service plan lacks a strong business case to support the proposed plan and its funding allocation

Too much focus on treatment and not enough on prevention. Industry are seeking greater recognition of their harm minimisation initiatives in the plan

Greater focus on at-risk groups, especially Maori, Pacific and Asian, in relation to culturally appropriate prevention initiatives, service needs, and research

Support for the social marketing programme, in general. However, there is a perception that more funding is needed to achieve the desired outcomes

Support for public health initiatives, with some submitters seeking greater restrictions on the gambling industry

Support for workforce development. However, funding for workforce development is perceived as inadequate. There are also requests for more access to workforce development opportunities via levy funding for NGOs, community and gambling industry staff

Need for more audit and evaluation to assess effectiveness of service provision

Requests for more funding for research are countered by other statements that funding allocation is too great. There are also some concerns about whether the proposed research projects will result in outcomes that minimise problem gambling harm.

Needs Assessment

Needs assessment is not seen to link strongly to the service plan.

Levy Formula and Calculations

Levy formula is perceived as overly simplistic, given the complexity of problem gambling

Request for more frequent forecasting, given the potential for rapid change in the environment

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Divided opinion on levy amount from those who feel it is too low, to adequately address the harm caused by gambling, to those who feel it is excessive, given declining presentations to services and gambling opportunities

Divided opinion on the preferred levy weighting.

2.1 Overview of stakeholder feedback

Detailed below is a high level summary of the consistent themes emerging across the different stakeholder groups. The groups are not homogenous and differences do exist within them, and are noted where they are especially marked.

Stakeholder groups are listed from highest number of analysed submissions to lowest.

Service providers offer a diverse range of comments relating to requests for more funding to: maintain current service levels given the introduction of new services; pay qualified staff due to workforce developments; meet the needs of at-risk groups; and advertise their services to overcome barriers to access.

Other NGOs comment on the need for greater focus on prevention and minimisation of harm in the plan. They also note the need for more funding for services based on need, greater focus on at-risk groups and workforce development.

Individuals offer a diverse range of comments. In the main, they are seeking more problem gambling services as well as more restrictions on the gambling industry.

Industry comment on the lack of a thorough and detailed needs assessment to underpin the development of the 2007-2010 service plan. They are critical of funding allocations in an environment where presentations and gambling opportunities are declining. Industry offer differing recommendations on the levy weighting dependent on their perspective. A few note the need to maintain the current levy for a year, while a thorough needs assessment is conducted.

TLAs request information and data to allow them to consider their gambling venue and racing board policies in terms of possible effects on gambling behaviour. There is also a request for more access to problem gambling services for those more rurally isolated.

Academics offer a diverse range of feedback including more funds for research, greater focus and involvement of Maori in the development of the service plan and in receiving appropriate services, workforce development, and greater focus on families affected by problem gambling.

Core government departments offer specific comments relating to areas of particular relevance to them, (e.g. youth and prisoners).

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3. Feedback on Three-Year Service Plan 2007-2010

3.1 Introduction

Overall, this section details feedback on the three-year service plan 2007-2010. As in subsequent sections, it details key themes arising across analysed submissions and their supporting comments, followed by a list of submission numbers detailing who made the comments. In the main, the sub-section headings reflect the lay out of the three-year service plan, with the exception of audit and evaluation which is combined into Section 3.4.6. It also pulls out three key recurring themes: amount of funding, focus on at-risk groups, and innovation.

3.2 Overall perceptions of the service plan

3.2.1 Endorsement of plan

Overall, 24 submitters endorse the three-year service plan, and only 6 reject it outright. Note: not all submitters comment on the service plan, or if they did, stated whether or not they endorsed it.

Endorse service plan

19 submitters explicitly note their endorsement of the service plan. Reasons for endorsing the plan include:

Support for specific sections of the plan, and the Ministry of Health’s initiatives to mitigate the negative impact of problem gambling on the most vulnerable sectors of society

Focus on prevention as well as treatment, and a holistic and complex societal approach to the reduction of problem gambling

Focus on workforce development to cater for specific problem gambling needs

Agreement of the need to minimise problem gambling harm.

(8 service providers [13, 84, 86, 212, 218, 278, 279, 759], 4 other NGOs [86, 214, 278, 761], 4 individuals [7, 17, 21, 282], 2 academics [14, 283], 1 government department [13])

5 submitters endorse the service plan with some reservations particularly related to its funding, and adequacy of service coverage, (discussed in more detailed below).

(3 service providers [77, 83, 277], 1 industry [276], 1 government department [12])

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Reject service plan

6 submitters explicitly reject the service plan outright because:

The service plan focuses mainly on treatment and to a much lesser extent on the prevention and minimising of gambling harm. A more central role is preferred for preventing and minimising problem gambling harm, given its high burden on individuals, their families and social services. Note: This one-off comment is also made by 5 other NGO submitters, who did not reject the service plan outright. [9, 15, 20, 281, 763]

Fails to address wider regulatory issues, or acknowledge the mental health aspect of problem gambling

Maori were not involved in the development of the plan, and there is no recognition of He Korowai Oranga, as an overarching framework for developing a public health strategy to remove public gambling harm from Maori environments

There is a lack of evidence and insufficient linkages between the needs assessment, the proposed service plan and the levy. One submitter advocates that the consultation document needs to be withdrawn and a revised proposal submitted based on up-to-date service delivery and intervention data, presentation and expenditure data, and following the identification of the key drivers of change in presentations.

(2 other NGOs [78, 87], 1 individual [765], 2 industry [210, 280], 1 academic [762])

26 submitters either did not comment on the service plan, or are not explicit about whether they endorsed it or not.

3.2.2 Funding amount and allocation

Overall, submitters are divided on the proposed funding of the service plan. Non-industry submissions tend to feel that the plan is under-funded, while industry feel there is a lack of evidence to support the proposed funding level and its allocation.

This section summarises overarching themes relating to the funding allocation in the service plan. Funding comments about specific services are detailed in the following sections.

Funding is not adequate

17 submitters comment that proposed funding is not adequate to maintain existing and new services. This reflects a number of concerns, specifically:

Potential increases in service use due to new public health initiatives, (i.e. the social marketing programme)

Additional funding is required for increased investment in public health with an emphasis on public health services for specific at-risk groups and localities with no regional problem gambling public health provider

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Funding not covering service providers’ operating and compliance costs

No additional funds for emerging service needs generally and for Maori, Pacific, and Asian peoples

Excess capacity does not exist if the true scale of problem gambling harm, and barriers to accessing services are recognised, and effort is made to overcome these barriers.

(4 service providers [77, 218, 277, 279], 10 other NGOs [9, 15, 20, 78, 87, 214, 281, 351, 763, 765], 3 individuals [79, 282, 219], meetings [1, 3, 4, 5])

Lack of valid evidence to support funding

8 submitters comment that allocation of funding is not based on thorough evaluation of effectiveness and outcomes of the 2004-07 service plan.

These submitters comment that it is good business practice to evaluate the effectiveness of previous interventions before determining future funding and allocation of funding. Further, a lack of valid evidence and a lack of delivery of research and evaluation to inform the development of the service plan, and annual reporting to Parliament on levy expenditure is not in keeping with the intent of the Act. They comment that these annual reports to Parliament should include measurement and evaluation of the actual cost of outcomes for the strategy and the service plan, and ideally be made available to key stakeholders for comment.

They also comment that as service demand is decreasing and with perceived excess capacity, the rationale for maintaining the current level of funds is undermined.

(7 industry [11, 85, 210, 213, 276, 280, 285A])

3.2.3 More focus on at-risk groups

Overall, 25 submitters comment that more attention needs to be paid to specific at-risk groups and feel the proposed investment for them is inadequate. This reflects concerns that these groups are targeted by various types of gambling industry in their environments, and that they face cultural, language, economic and other barriers in accessing help. These at-risk groups include:

Maori, Pacific, Asian, specific Asian population groups, prisoners, youth, survivors of trauma, refugees, older people and low socio-economic populations.

In this context, submitters request greater investment in problem gambling prevention services for Maori, Pacific and Asian communities. Further, submitters comment on the need for culturally appropriate and dedicated services around research, practice

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models and interventions for these specific groups and their wider sub-groups, (e.g. Asian sub-groups).

(8 service providers [83, 84, 212, 215, 277, 279, 761, 759], 8 other NGOs [9, 15, 20, 78, 86, 87, 281, 763], 2 individual [21, 22], 2 industry [11, 280], 3 academics [14, 283, 762], 2 core government department [12, 13], meetings [1, 2, 3, 4, 5])

Detailed below are core themes relating to their overall concern:

More dedicated services for at-risk groups

16 submitters note the need for more dedicated services for at-risk groups, (e.g. Maori, Pacific, Asian, prisoners, and youth). Specifically:

For Asian and specific Asian sub-groups:– Forming partnerships with Asian communities and respective sub-groups within

the Asian population to minimise gambling harm – Establishing Asian problem gambling advisory group– Having more Asian input into national co-ordination of services– Enabling more direct interaction with individuals/families affected by problem

gambling.

For Maori:– Focusing on the provision of services for Maori in localities where there is

currently no regional problem gambling public health provider– Consideration of the contracting of Te Herenga Waka O Te Ora Whanau to

establish a Maori Working Group with wide iwi and Maori community representation to develop a Maori specific service plan for 2007-2010 to remove gambling harm from Maori whanau, hapu, iwi and communities

– Purchasing a specific public health strategy for Maori, as new information released by the Ministry of Health demonstrates this need.

For Pacific:– Having more services. One submitter disagrees that equitable placement of

services for Pacific peoples has been achieved. They comment that this reflects that there are only two services in Auckland and Hamilton to meet Pacific peoples’ needs.

For youth:– Developing youth specific interventions – Funding to address any issues arising from the 2007 Youth Survey.

For prisoners:– Including new interventions established by the Department of Corrections and the

Ministry of Health, (i.e. ‘Eight Gambling Screen’ which screens offenders for gambling problems in order to address root causes).

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The provision for more services to cater to the needs of the following specific groups at a generic level: survivors of trauma (e.g. refugees); migrants; older people; low socio-economic populations; and people who live in low socio-economic areas.

For specific groups on the whole, reducing barriers to access and filling gaps in service provision, for Maori, Pacific, refugee and migrant peoples.

(6 service providers [83, 212, 277, 279, 759, 761], 5 other NGOs [9, 78, 86, 87, 763], 1 individual [22], 3 academics [14, 283, 762], 2 core government departments [12, 13], meetings [1, 2, 3, 4, 5])

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Culturally appropriate response

7 submitters comment that the plan fails to offer a cultural, social and economic response appropriate to Maori, Pacific and Asian communities. Some suggestions on how to create stronger linkages with these communities are:

Developing more partnerships with communities and supporting groups to develop their own models

Having outreach services for and branching out into smaller ethnic communities and recognising the separate groupings within each wider ethnic community, (e.g. the wider Asian community consists of many smaller ethnic communities)

Resources in languages other than English

Acknowledging cultural differences between Maori and Pacific.

(3 service providers [83, 84, 212], 3 other NGOs [9, 86 87], 1 industry [11]).

More funding for at-risk groups

5 submitters express the need for the allocation of sufficient funding for extra services targeted for specific groups. Comments reflecting this include:

Funding for provision of dedicated services for specific groups

Increasing percentage of funding allocated for specific groups, (e.g. one submitter comments that 20% of the total budget should be provided to address health inequalities and high problem gambling with Pacific and to develop Pacific capacity)

Funding for schools to provide information on problem gambling in their lifestyle skills curriculum.

(2 service providers [215, 761], 2 other NGOs [15, 20], 1 academic [14]).

More research for at-risk groups

4 submitters wish to extend research to include specific groups. Consideration needs to be given to creating research opportunities that encompass all types of ethnic groups, with an emphasis on culturally appropriate research to aid these groups in preventing and minimising gambling harm.

(2 service providers [212, 761], 1 industry [280], 1 other NGO [78]).

More advocacy services

2 submitters comment that there are insufficient advocacy services in place for specific groups, specifically for Maori, Pacific and Asian sub-groups.

(1 service provider [212], 1 other NGO [87]).

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3.2.4 Innovation in service plan

13 submitters comment on innovation in the service plan, from generic comments on the lack of innovation to more specific detail of how to make the plan more innovative.

6 submitters comment that the service plan lacks innovation, and there is a need for more innovative alternatives to treatment and service provision. 2 submitters suggest the provision of more Ministry of Health staff for additional policy and innovation resources, especially if this will also result in robust effectiveness data.

(2 service providers [218, 279], 3 other NGOs [9, 281, 763], 1 individual [219]) meeting [3, 7])

9 submitters make specific comments relating to innovation including:

Strategies to address low access rates and barriers to access, (e.g. provider and community initiated projects)

Development of a screening tool to identify other linked factors that influence gambling (e.g. alcohol, smoking)

Innovative intervention programmes for prison

More research to find innovative solutions around problem gambling in casinos, as this is a projected growth area

Online internet based individual and group counselling and self-directed learning models

Greater collaboration between all stakeholders to develop innovative tools for harm identification and minimisation in the gambling environment.

(4 service providers [84, 759, 760, 761], 3 other NGOs [9, 78, 278], 1 individual [219])

3 submitters also request a contestable/discretionary fund for piloting genuine innovative practice over and above the standard contracted services offered by providers.

(3 service providers [84, 218, 761])

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3.3 Public Health

3.3.1 Public Health Service

Of those submitters that comment on public health services, the majority are offering their support for the public health focus. Some comment on the need to support the latter with restrictions on gambling opportunities. Funding is also mentioned with some arguing for more money for public health, especially for at-risk groups, while others argue that there is no need to increase funding allocation.

Support investment in public health

9 submitters note their support for the Ministry’s proposed investment in a public health approach including the need to address the underlying social, economic, cultural and environmental determinants of health. A few mention the need for specific focus on Maori and other at-risk groups in developing and supporting a public health approach to reducing problem gambling harm.

(3 service provider [277, 279, 218], 1 other NGOs [278], 1 individual [219], 1 TLAs [2], 2 industry [276, 285A], 1 academic [762])

More restrictions on gambling

13 submitters request that a public health approach be supported with more restrictions on gambling access and its marketing and advertising, especially for at-risk groups. Further, some suggest that the gambling industry be more transparent and accurate in their disclosure to customers over the probability of winning, and they undertake more harm minimisation initiatives. Others comment on the need for more rigorous enforcement and prosecutions by the Department of Internal Affairs of establishment owners not abiding by the law.

(4 service providers [82, 84, 279, 759], 5 other NGOs [8, 9, 78, 87, 278], 4 individuals [7, 8, 282, 764])

Conversely, submitters from the gambling industry comment that reducing opportunities to gamble does not stop problem gamblers gambling, therefore harm is not reduced by reducing gambling opportunities.

(2 industry [85, 284])

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Funding comments

As noted earlier, funding is a key theme with some submitters indicating a need for increased funding, specifically:

The current funding for community development action strategies is inadequate

There is uncertainty about whether District Health Boards (DHBs) are receiving sufficient funds for public health services

More investment for mental health resources.

One industry submitter recommends no changes to public health funding.

(5 service providers [80, 215, 218, 277, 279], 1 individual [17], 1 industry [285A])

Industry’s harm minimisation initiatives not recognised

5 submitters comment that industry’s compliance to harm prevention regulations is not considered in the plan, and that these regulated initiatives are not being evaluated.

(5 industry [11, 85, 210, 280, 284])

Other comments

Other comments mentioned relating to public health services include:

Need to work with and inform TLAs, including support for them to develop problem gambling harm prevention policies and the allocation of $7 million for developing policy and social and health impact assessments and monitoring programmes

(1 service provider [279],2 TLAs ([19], 217], meeting [5]).

DHBs should have responsibility and associated funding for delivery at a regional level.

(1 individual [17]

The gambling industry and their products to be better monitored to reduce problem gambling harm.

(1 individual [22])

3.3.2 Workforce development

Workforce development comments relate to the need for more funding, specific training for practitioners dealing with at-risk ethnic groups, staff turnover, qualifications, and the inclusion of NGO, community and gambling industry staff in levy-funded workforce training.

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Funding comments

8 submitters mention the need to increase funding levels for workforce development, specifically:

Increase funding to improve the remuneration and working conditions of public health workers

Expectation that costs will be high initially then taper off, but the proposed allocation of $320,000 is split evenly over the next 3 years

Additional funding needed to increase the number of community development workers and public health advocates.

(4 service providers [82, 83, 84, 759], 2 other NGO [15, 20], 2 individuals [7, 17])

Conversely, one submitter notes that the proposed funding level will support capacity building and increasing competencies in the existing workforce. (1 industry [285A])

Industry workforce development

2 submitters comment on the need for workforce development in the industry to continue to develop and support harm minimisation initiatives in gambling environments.

(1 service providers [761] 1 other NGO [86], meeting [7])

Training for practitioners dealing with at-risk groups

Two submitters comment on the need to focus on training requirements for practitioners dealing with specific at-risk groups, in particular Maori and Pacific, for example:

Training and developmental needs for Maori and Pacific people working in public health

Provision of funding for development of national Pacific cultural competencies framework for the gambling area

Funding and provision of cultural supervision in workforce development.

(2 service providers [80, 215])

Need for qualifications

2 mention the need for undergraduate and postgraduate training in public health relating to problem gambling.


Other comments

Other one-off-comments relating to workforce development include:

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Queries about how new jobs will be created as service demand increases, and the management of staff turnover

Need to align workforce development with Public Health Workforce Development Plan (PHWFP)

Workforce development should be aligned with DAPANZ and HPCAA.

(1 service provider [82], 3 other NGOs [86, 87, 278], 1 industry [285A])

3.3.3 Social marketing programme

Overall, there is support for the proposed social marketing programme, although some submitters feel it requires additional funds to be effective. Conversely, others are less supportive until a more thorough cost and needs assessment has been completed, and its alignment with other problem gambling mechanisms is defined.

Support

18 submitters indicate a level of support for the proposed investment in a social marketing programme to promote and support public awareness and debate on gambling issues.

(7 service providers [84, 88, 215, 218, 277, 279, 759], 5 other NGOs [9, 15, 20, 78, 87], 3 individuals [22, 79, 219], 2 industry [280, 285A], 1 academic [14])

Don’t support

4 submitters are less supportive of the proposed social marketing programme. This reflects comments that the programme should not seek to promote an anti-gambling message as gambling is a lawful pastime and non-harmful for the majority of people. Further, there is a need to consider and evaluate other potential mechanisms, how the programme fits with existing harm minimisation initiatives and current service provision, e.g.:

A cost benefit analysis of a social marketing programme versus other methods

Only acceptable if part of an agreed and measurable integrated problem gambling strategy

Review harm minimisation initiatives and how they inform the design of the social marketing programme

An evaluation of existing problem gambling services before a social marketing programme commences and attracts people to these services

Link to Expert Advisory Group work on how marketing of gambling can be consistent with the Act.

These submitters also request stakeholders are consulted about the social marketing programme, and that it should only be launched after agreement by all stakeholders.

(4 industry [210, 213, 280, 284], meeting [7])

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While there is general support for the social marketing programme, submitters critique the programme as per the intent of the submission process.

Funding not enough for programme to be effective

12 submitters comment that the proposed funding is insufficient for the social marketing programme to be effective in achieving the outcomes sought. They comment that in comparison to the Victoria campaign, ‘Like Minds, Like Mine’ and LTNZ’s road safety programme, and the amount that the New Zealand Lotteries Commission spend on advertising and marketing, the proposed budget is low.

1 submitter recommends that there should be an annual budget allocation, (for communication activities including evaluation), of $2.5 million, to enable moderate media visibility for approximately 16-20 weeks per annum. They recommend that funding for the social marketing programme be spread throughout the period of the service plan, and not decreased to a third in the final year. However, other submitters recommend a budget of $20 million.

Further, there is need for additional funding for effective local public health initiatives and the training of the public health workforce to support the campaign.

(6 service providers [82, 84, 88, 277, 279, 759], 3 other NGOs [15, 20, 78], 2 individuals [79, 219], 1 academic [14], meeting [4])

No additional funding for potential increased presentation to services

11 submitters note there is no contingency fund in services for the increase in presentations as a result of the social marketing programme. A few submitters note that the Victoria social marketing programme resulted in 26% increase in presentations.

Comment is made that the social marketing programme should focus on reducing barriers to accessing and utilising services, given the 12% presentation rate. In this context, some service providers argue the need for additional marketing and advertising budget to create greater awareness of their services to complement the social marketing programme.

(6 service providers [84, 87, 218, 277, 279, 759], 4 other NGOs [9, 15, 20, 78], 1 individual [219])

Lacks details

6 submitters note a lack of detail relating to the proposed social marketing programme, which makes it difficult to offer considered feedback. Related to the latter, one submitter comments that the programme needs to have clearer objectives.

(3 other NGOs [9, 15, 78], 3 industry [213, 280, 210])

Target at-risk groups

5 submitters comment that specific at risk groups need to be effectively targeted by the social marketing programme, i.e.:

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Consultation and pre-testing of the social marketing programme to ensure its effectiveness with Asian people

Culturally appropriate delivery of messages to Pacific peoples and communities by focusing on face-to-face delivery, messages in Pacific languages and via media such as radio, and less focus on web-based messages.

(2 service providers [78, 215], 1 other NGO [9], 1 individual [79], 1 industry [213])

Needs evaluating

2 submitters note the need for a formative evaluation component in the social marketing programme to effectively develop and implement it, and an annual programme monitoring to assess its results; estimated at $50,000 excluding GST per annum.


3.3.4 Behaviour change survey

Two submitters suggest that the behaviour change indicators survey is conducted in the final year of the service plan to identify real changes in gambling behaviour. They comment that conducting the survey in year one (2008) will not allow enough time for gambling behaviour to have changed.

One notes that the funding allocated to the survey in the second year is too low, as it is at a lower cost than the current pilot.

(2 service providers [277, 759], 1 academic [283], meeting [4])

3.3.5 Resources

2 submitters comment that public health gambling resources should be based on evidence and be designed to appeal across culturally diverse audiences as well as socio-economic levels, age, and gender.

(1 service provider [215], 1 NGO [351])

1 submitter suggests developing resources that support host responsibility activities, and align with the social marketing programme.

(1 industry [285A])

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3.3.6 National co-ordination

Comments relating to the national co-ordination service are split between those who support the need and those who don’t.

2 submitters endorse the need for a national co-ordination service as it will enable the better co-ordination of service providers with researchers at design and dissemination stages of research. However, one submitter comments that the Ministry of Health should maintain this function as a national policy role, as the establishment of another organisation will lead to duplication of administration and management structures.

Another submitter comments that the effectiveness of this role is limited by sole focus on service providers. Further, they recommend that funding for this service is increased by $100,000 to allow for an additional full time equivalent, and expansion of the range of organisations with whom they work.

(1 service provider [761], 1 individual [17], 1 industry [285A])

Conversely, one submitter argues that there is no reference to a need for national coordination in needs assessment, and considers that the role detailed in the service plan is that of the Ministry of Health and not a new 'body'. They go on to note that the coordination of service providers is not one of the purposes provided for within the Act, and if needed should be provided for by the service providers.

(1 industry [280])

3.3.7 Conference support

1 submitter notes that the funding for conference support for an international conference is inadequate, and suggests that based on previous experience should be about 2.5 times more. Other comments relate to conference support for the intervention stream, and for a three yearly Pacific gambling conference.

1 submitter recommends that the Ministry of Health seek enhancements to the quality of the organisation, facilitation and content of the annual international problem gambling conference.

Another suggests broadening this category to allow for the inclusion of other events such as the International Think Tank run by the Gambling Helpline and AUT University.

(3 service providers [80, 215, 218], 1 academic [283], 1 industry [285A], meeting [4])

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3.4 Intervention services

3.4.1 Intervention services (secondary and tertiary prevention)

Comments on intervention services reflect issues of supply and demand, services for families and whanau impacted by problem gambling, access enablers, recognition of industry’s harm minimisation initiatives, and targeting of specific populations.

Supply and demand debate

6 submitters comment that funding for intervention services will not meet the likely increase in demand, or current demand, or reduce barriers to accessing services. Further, there is no provision for clinical services or the recognition that a successful public health approach will lead to increased activity and presentation.

(2 service providers [77, 279], 2 other NGOs [9, 78], 2 individuals [282, 219], meetings [1, 5])

Conversely, others comment that there is excess capacity and demand is decreasing and this should be reflected in funding allocation. These submitters recommend that service providers should be funded at actual levels of demand and not forecasted demand.

There is also concern that intervention services are allocated the bulk of the budget, but they are only one component of the overall strategy. Further, the services have not been audited and evaluated and their effectiveness is therefore unknown. On this basis, it is argued that these services should not receive additional funding until their effectiveness is established. In this context, the Ministry of Health is criticised for not properly monitoring problem gambling intervention services, and that new services continue to be funded despite decreasing demand.

(5 industry [11, 85, 210, 280, 285A], meeting [7])

Funding for advertising

5 submitters request more funding for advertising and marketing to promote their services and assist in reducing access barriers, (e.g. $250,000 per annum).

(2 service providers [218, 279], 2 individual [219], 1 academic [14])

Improving access

4 submitters comment on the need to increase opportunities to access problem gambling services for those more isolated or facing access barriers, (e.g. people in rural areas or those from more at-risk groups). In this context, the suggestion is made of the potential of online

22


self-help material to increase support for problem gamblers, as well as phone and workbook initiatives.

(1 service provider [279], 2 other NGOs [761, 218], 1 TLAs [10])

Other comments:

Greater collaboration and integration of service delivery in the plan

(1 service provider [279])

$100,000 funding to support Gambling Anonymous (GA) and re-establish GamAnon to provide cost-free awareness resource through its members 'twelve stepping' via book depository, newsletter, full-time GA administered and travel costs

(1 academic [14])

A screening tool like the ‘8’ gambling screening tool to identify smoking, alcohol, and co-morbidities

(1 academic [14]).

Funding of intervention services should be done through DHB’s.

(1 industry [285A])

3.4.2 Helpline

There are only limited comments on the Helpline, primarily to do with funding.

2 submitters advocate for more funding to accommodate a future increase in demand for this service, and for advertising the service. However, another recommends that funding is reduced by 25%, given the decline in use.

Other comments include:

Suggestion to move the Pacific helpline to an independent Pacific organisation

Need for an Asian helpline service, and online support.

(2 service providers [215, 218], 1 academic [283], 1 industry [285A]).

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3.4.3 Psychosocial interventions and support

A range of comments are made about psychosocial interventions and support, including the level of proposed funding, support for families harmed by problem gambling, and inclusion of budgeting services as a specialist service.

Funding

5 submitters argue that services and practitioners need more funding to be maintained or increased to cope with demand. However, one submitter argues that with the decrease in demand, funding for psychosocial interventions and support should be reduced by 25% to reflect the decline in access to all intervention services.

(2 service providers [77, 82], 1 individual [3], 1 industry [285A], 1 academic [14])

Family services

3 submitters comment on the need for resources to fund specialist services for family and whanau affected by problem gambling.

(1 other NGO [278], 1 individual [22], 1 academic [14])

Family budgeting services

1 submitter comments on the need for family budgeting to be included as a specialist intervention service, and for these workers to have training provision relating to assessment and action if a problem gambler presents.

(1 other NGO [214])

3.4.4 Problem gambling information system

Only a few submitters comment on the problem gambling information system, offering a diverse range of opinions.

Comments are summarised below:

Need to create an ethnic specific public health database to trace trends in attitudes and responses of Pacific groups

For public health and service providers to be involved in the development of the system, and encouraged to share gambling intervention service information collected

24


Concern that gambling service clients will be identified by their National Health Indicator Numbers

Require budget allocation for compliance costs

Concern that performance monitoring is based solely on quantitative data from the system to the exclusion of qualitative approaches. Further, there is a perception that the system has been developed in-house within the Problem Gambling Committee, that it does not have the confidence of service providers, and that it requires independent auditing and evaluation.

(3 service providers [215, 218, 759], 1 industry [280])

3.4.5 Workforce development and training

While there is general support for workforce development, submitters comment on the need for more clarity on its objectives, more funding, and a wider range of groups to receive training in problem gambling.

No clear objectives

6 submitters comment that the proposed workforce development lacks clear direction and objectives, and thus for some there is insufficient information to comment in-depth. One submitter comments that the workforce development is ongoing and this needs to be acknowledged in the plan, especially given the high turnover of staff.

(2 service providers [219, 759], 2 other NGOs [9, 78], 2 individual [7, 219])

Funding

9 submitters comment that funding for workforce development is inadequate, specifically:

Inadequate budget to achieve workforce development aims. One submitter estimates a further $200,000 is required for the development of the problem gambling workforce

No allowance for funding increases for services to pay for a more qualified and skilled workforce that will eventuate from the workforce development strategy

More funding to target workforce gaps in current service provision, specifically the needs of Maori and Pacific workforce.

(2 service providers [215, 759], 5 other NGOs [9, 15, 20, 78, 87], 1 industry [284], 1 academic [14], meeting [3])

Workforce to receive training

11 submitters comment on who receives workforce training, and how. Submitters request that workforce development opportunities are made available to community and NGOs to

25


develop their staff. In this context, a few request the Ministry of Health to consider using existing training programmes in communities, and to place focus on practical skills as well as an academic focus.

1 submitter suggests that workforce development should include training at multiple levels including public health workers, clinicians, frontline bar and casino staff, and community activists. The latter is supported by 3 submitters who request funding to train gambling industry staff about harm minimisation.

One submitter notes the need to support the training of Asian people to conduct problem gambling research.

(1 service providers [88], 4 other NGOs [78, 214, 281, 763], 2 individuals [219, 22], 3 industry [11, 213, 284], 1 academic [14])

3.4.6 Audit and evaluation

Overall, there is concern about the lack of audit and evaluation of existing intervention services.

Identification of best practice

14 submitters see the need for more projects focusing on evaluation, and the identification of ‘best practice’, so evidence-based-practices for providers can be developed. Submitters also point out that projects need to include monitoring components.

(3 service provider [83, 218, 279], 4 other NGOs [15, 20, 78, 214], 2 individuals [17, 219], 2 industry [85, 210], 1 academic [283], 1 TLAs [2])

Lack of evaluation of intervention services

6 submitters comment specifically that expenditure on intervention services has not been audited and evaluated. They comment there is a lack of credible evidence on the outcomes achieved by the expenditure of the levy to date, (i.e. to identify if the costs are necessary and reasonable). The latter is seen as critical for accountability and to ensure ongoing improvements to the problem gambling programme.

Industry submitters note that there is wide variation in cost per user of different treatments, and best practice for intervention services has not been established. They continue that it is inappropriate to spend money on intervention services without proper evaluation. Consequently, they perceive that the Ministry of Health has not met the reporting requirements laid down in 2004 by the Gambling Commission, and there is a failure to comply with the Gambling Act.

(6 industry [11, 85, 213, 276, 280, 285A])

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Conversely, several NGO submitters comment there is inadequate budget to establish which service providers are effective and efficient, or to undertake a national evaluation programme.

Other comments

Other comments relating to audit and evaluation for public health and intervention services include:

More funding

Provision of funding for cultural, financial audits of Pacific problem gambling treatment services

Commitment to 'ring fence’ the intervention services budget so that if some services close after evaluation, the funding remains available for others to access

Evaluations and audit should be funded at 5% of service budget

Funding of an outcomes framework, identifying indicators or measures of gambling related harm relevant across the gambling and problem gambling sectors

Maori involvement in monitoring and evaluating the Gambling Act 2003

Funding to determine the effectiveness of service plans in achieving the strategy’s goals

Funding to develop and pilot a Pacific gambling service evaluation model, and a gambling screen to identify Pacific peoples

(2 service providers [84, 215], 3 other NGOs [9, 20, 78], 1 individual [22], 1 academic [762], 1 industry [285A], meeting [1, 4])

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3.5 Research

Submitters’ reactions towards the research budget and agenda are mixed reflecting comments on the level of proposed funding relative to other activities, potential research outcomes, as well as suggested research projects.

Level of funding

9 submitters comment that in general research is over-funded. They suggest that the proposed research budget should be reallocated to prevention, treatment and/or education needs. Further, some feel there is a lack of identified need for the research projects to support their proposed budgets.

(6 other NGOs [9, 15, 78, 87, 281, 763], 2 individual [17, 219], 1 industry [213])

5 submitters perceive that research into problem gambling is under-funded. These submitters point out that without larger budgets researchers will be unable to carry out robust and in-depth studies, (e.g. face-to-face interviews or longitudinal studies). Concern is also raised over researchers having to use funding from different sources to fund research projects, and the possible conflicts this may cause in completing projects.

An adequate research budget is also vital in making informed policy decisions, especially as many stakeholders are unable to fund research themselves.

(2 service providers [84, 279,], 2 TLAs [2, 19], 1 academic [283]).

Research deliverables

Some submitters question the ability of the proposed research projects to result in outcomes that will minimise problem gambling harm. Some submitters suggest there needs to be more focus on provider, local government and community initiated research and/or action research in the plan. The latter is seen to be consistent with the community development approach promoted in the plan.

Suggested research topics / projects

There are a number of suggestions around possible research projects and topics, specifically:

Socio-economic

Funding for socio-economic research as it is fundamental to understanding interrelated determinants to and impacts of problem gambling

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Fine-grained localised social impact assessments to feed into the development and review of TLAs’ gambling venue policies. A request for low-cost, simple options, or specific funding.

At risk groups

Inclusion of research methodology in projects that are culturally and linguistically robust

All gambling research should over-sample Pacific populations to enable ethnic specific analysis

Pan-Pacific prevalence survey within Pacific social and cultural contexts to build on existing Pacific studies

Socio-economic impact study for Pacific populations

In-depth study using qualitative methodology to help unfold complex issues surrounding Asian gambling

Research into gambling products, associated gambling behaviours and subsequent application of host responsibility policy amongst Asian populations.

Legislative / policy

More research into the effects of legislation on gambling, (e.g. Smokefree, Racing Act, Gambling Act)

Effectiveness of the variety of machine number caps implemented by TLAs on the incidence of problem gambling

Amount of money lost in machines by TLA areas

More focus on effective monitoring and reporting of problem gambling as inaccurate numbers will result in inaccurate funding for people in need.

Gambling types and related problems

Research on problematic aspects and/or features of particular gambling types, (e.g. pokies) and environments

Investigation of the average distance/time problem gamblers travel to gambling machines, and relationship between distance and incidence of problem gambling.

Pilot projects

Funding for pilot projects to be tested and evaluated.

National evaluation of intervention services

Funding for national evaluation programme of problem gambling intervention services.

Gambling Trusts

Research that tests anecdotal evidence that gambling trusts have shifted focus of fund distribution towards nationally based activities, (analysis of how the support of national organisations filters down to local level)

Distribution of gambling trust funds and the relationship of benefits of income source.

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Other research projects

Additional funding for a feasibility study to ascertain practicality of conducting a national face-to-face gaming survey for currently allocated funding

A thorough investigation into the barriers to presenting

Taking a wide perspective to identify the complexity of the problem, (e.g. social, environmental, cultural).

(5 service providers [80, 212, 215, 279, 761], 4 other NGOs [15, 20, 214, 351], 4 individuals [7, 22, 79,219], 2 industry [213, 284], 4 TLAs [2, 10, 19, 217],1 academic [283]).

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4. Needs Assessment

Overall, there is little specific comment about the needs assessment detailed in the consultation document.

Some comment that the needs assessment is excellent, but that it does not translate into the service plan which is described as more of the same.

(1 service provider [218], meeting [1])

Others mention that there are insufficient linkages between the needs assessment, the proposed service plan, and calculations of levy rates. One submitter comments it is more an environment scan rather than an assessment of problem gamblers’ needs.

(2 industry [280, 210])

Others support that the needs assessment addresses problem gambling with public health lens recognising its complexity, in accordance with Gambling Act

(1 service provider [218], 1 individual [3])

Other one-off comments debate the content of and/or validity of the findings of the needs assessment content, (e.g. the relationship between population density, relative social deprivation, and gambling opportunities). These comments are not listed given the needs assessment has been externally peer reviewed.

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5. Problem Gambling Levy Calculations 2007-2010

5.1 Levy amount

There is divided opinion on the levy amount from those who feel it is too low to those who feel it is excessive, given declining presentations to services and gambling opportunities.

14 submitters agree that the levy needs to be increased, so that the harm caused by gambling can be more effectively prevented, minimised and treated. Submitters cite a number of issues:

Increasing the levy will increase funding available so more services can be offered to properly meet the current shortfall of services, as well as the expected increase in demand from new public health initiatives

The levy is low in relation to gamblers’ losses, the overall harm caused by the gambling industry, and the level of industry profit

The levy is one method to control the growth of gambling, given the lack of other controls over advertising, the levy needs to be increased in order to limit harm.

(6 service providers [77, 82, 84, 215, 279, 759], 3 other NGOs [9, 78, 281], 5 individuals [3, 79, 219, 765, 766])

Conversely, 2 submitters comment that the proposed increase in the levy is excessive and not justified, given the decline of presentation to intervention services, and gambling opportunities. Further, 7 submitters state that insufficient research, evaluation and analysis has been conducted to forecast future trends and thus set the levy for the 2007-2010 period. Some also view this as a failure by the Ministry of Health to fulfil its obligations set down in the Gambling Act.

(7 industry [11, 85, 210, 276, 280, 284, 285A], meeting [7])

2 submitters comment that given the lack of robust analysis to support changes to the levy, there should be no increase to the levy. They propose maintaining the levy for the next 12 months as this analysis is completed.

(2 industry [210, 213])

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5.2 Levy formula

Overall, there is support across the stakeholder groups for an industry levy to prevent and minimise harm caused by problem gambling. However, there is some confusion about how the levy is calculated, its relationship to other funding pools as well as the calculations around the recent levy under recovery. Across submitters a number of key themes relating directly to the levy emerge as detailed below.

5.2.1 Levy formula needs to be more detailed and robust

23 submitters comment that the current levy formula is overly simplistic, given the complexity of problem gambling and requires a more detailed and thorough analysis.

No recognition of wider harm

8 submitters comment the formula focuses on individuals with gambling problems and is not factoring in the wider harm caused to problem gamblers’ families or their specific communities. Consequently, the funding required to address these wider problems is not being collected, or being distributed back to the specific communities so they can address the problem.

(2 service providers [80, 761], 1 other NGOs [281], 1 individual [282],) 2 TLAs [19, 217], 2 academic [14, 283])

Non-linear relationship between expenditure and harm

2 submitters perceive the relationship of ‘expenditure’ with ‘harm’ is inconsistent, non-linear, and unsupported. The more a gambler spends does not always relate to more harm, and not all gamblers who spend a lot of money on gambling are ‘problem gamblers’. Therefore high expenditure sectors in the industry are disadvantaged as they end up paying more in levies.

(2 industry [276, 285A])

Presentations an inaccurate proxy for harm

2 submitters feel that the use of presentations is an accurate measure of ‘problem gamblers’.

(2 industry [210,276])

Conversely, 11 submitters feel using the number of presentations as a proxy for harm is inaccurate. This reflects that only 12% of problem gamblers are currently seeking help, and possibly even less for groups with significant barriers to accessing help for gambling problems, (e.g. Asian, Pacific peoples, and Maori). The point is also being made that

33


‘presentations’ recorded are not discriminating between those who are problem gamblers and non-gambling clients, (e.g. family members of problem gamblers).

However, one industry submitter comments that the current formula ‘disincentivises' host responsibility to forward referrals to intervention services.

(4 service providers [1, 212, 218, 279], 1 other NGO [281], 3 individuals [22, 79, 219], 3 academic [14, 283, 762], 2 industry [11, 285A])

Formula is too homogeneous

4 submitters perceive the present formula as categorising all people contacting problem gambling services under a single umbrella. Service users, level of harm, their mode of gambling and required treatments need to be more clearly defined, with an assessment carried out by trained professionals. They note that the more accurate the analysis of problem gamblers, their gambling behaviour and costs associated with their treatment, the more accurate fund collection and its distribution.

In this context, there is support for the model proposed by Woodlands Trust.

(1 service providers [1], 3 industry [11, 210, 213])

There is also comment that the calculation of the levy should follow a process where a detailed needs assessment informs the development of a service plan, which in turn informs the calculation of the levy to fund that plan.

(5 service providers [1, 80, 212, 218, 279], 1 other NGO [281], 4 individuals [22, 79, 219, 282], 6 industry [85, 210, 213, 276, 280, 285A], 2 TLA [19, 217], 3 academics [14, 283, 762])

5.2.2 Levy is not fair across industry

11 submitters, from both industry and providers, are concerned that different sectors within the gambling industry are not being assessed accurately.

Level of harm

4 submitters note that without accurate assessment of the harm being done by each sector, the accompanying levy that each sector should pay becomes inaccurate and therefore unfair.

(1 service providers [84], 1 individual [21], 2 industry [210, 280])

Focus of harm

The present formula is viewed as targeting sectors where ‘acute’ problem gambling behaviour occurs, for example in the non-casino gambling machine industry. Some submitters identified that there is less accountability for sectors that are ‘normalising’ gambling behaviour or providing ‘introductions’ to gambling such as the lotto products.

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(3 service providers [83, 88, 759], 1 other NGO [86], 1 industry [85])

There is also concern that the formula is masking differences in gambling behaviour between different groups. For example, Asian gamblers predominately gamble in casinos, yet overall this is not the normal pattern of problem gambling behaviour. There is also concern that some groups have below average presentations, (e.g. Asian, Pacific Island). The outcome of this is that some sectors such as casinos are not seen as creating harm on the whole, but for certain groups such as Asian gamblers casinos are causing significant harm. Classing problem gamblers as one group penalises industry sectors unfairly.


It is suggested that some members of the industry, such as ‘clubs’, should be levied in a different manner considering their fundamental differences to more commercial operations. Linked to the latter are requests for greater recognition of contribution other members of the gambling industry make back to the communities in the form of grants.

(3 industry [210, 213, 280])

There is also concern over the impact of the growing and unlevied ‘other’ sector, especially internet based gambling and private gambling, (e.g. poker). At present, harm caused by these other sectors is being paid for the remaining sectors. This is seen as unfair by some submitters.

(2 industry [85, 285A], 1 other NGO [8].

Treatment calculations

The present ‘cost for treatment’ calculations also need more detail. It is suggested that administrative costs of running a service is separated from the per treatment cost. This will allow administrative costs to be shared equally across the industry. Additionally, the formula does not account for the differences in the cost of treatments for gambling addictions to different industry sectors.

(2 industry [85, 210])

(7 service providers [77, 82, 83, 84, 88, 212, 759], 1 other NGOs [86], 1 individual [21], 1 academic [14], 5 industry [85, 210, 213, 280, 285A])

5.2.3 Frequency of forecasting

Request for more frequent forecasting to enhance accuracy.

6 submitters suggest that the levy be calculated more frequently to better respond to the unforeseeable effects that are occurring in both the gambling industry, (e.g. legislation such as ‘Smokefree’), and problem gambling, (e.g. possible increased demand due to the social marketing programmes). This reflects that inaccurate calculations result in the levy being

35


recovered from the ‘wrong’ sectors in the industry, as well as the wrong amount being collected to treat the harm actually done.

Infrequent forecasting is seen as resulting in projections that do not accord with the actual expenditure and presentations. These forecasting inaccuracies are perceived as a major cause of the recent under-recovery of the levy. Although, the under-recovery arose from a lower than forecasted performance in some sectors of the gambling industry, (e.g. non-casino gambling sector), the recovery is being spread equally over the entire industry. This is seen as unfair by some submitters.

While the levy is currently calculated every three years, the Gambling Act allows for shorter timeframes, if warranted. Calculating the levy more frequently will bring it in line with other Government levies, such as the annual ACC levy.

(6 industry [11, 85, 213, 284, 285A, 678])

5.3 Levy weightings1

Opinion is fairly evenly divided on the preferred levy weighting.

5.3.1 Support for 20:80 weighting ratio

15 submitters support the 20:80 weighting ratio.

The 20:80 ratio is seen as preferable for a number of reasons:

The cost of providing treatment is not a direct relationship to the number of people seeking help

Better reflection of the broader approach being taken in the service plan to prevent and minimise gambling harm, and not just treating harm

Presentations do not reflect the cost of treatment for addictions to different gambling modes

10:90 is low compared to gamblers’ losses, harm done, and industry profits

Focusing less on numbers of problem gamblers actually presenting and more on gamblers’ expenditure better reflects that many problem gamblers don’t actually present

Weighting presentations less links better to funding strategies not directly linked to the treatment of those that present, (e.g. prevention programmes).

(8 service providers [80, 83, 84, 88, 212, 218, 277, 759], 3 other NGOs [86, 214, 278], 4 individuals [3, 22, 219, 766], 1 industry [85])

1 Reflecting the closed question in the submission form, Litmus undertook a closed coding process i.e there was no multiple codings.

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5.3.2 Support for 10:90 weighting ratio

11 submitters support the 10:90 weighting ratio for the following reasons:

It better targets the sectors in the gambling industry creating the most harm

It is the ratio agreed to by Cabinet

Any changes to the levy need to be supported by more research.

(2 service providers [215, 279], 3 individuals [7, 21, 765], 5 industry [213, 276, 284, 285A, 678], 1 TLA [10])

5.3.3 Alternative weighting ratio suggested

7 submitters rejected the proposed weightings in favour of an alternative.

Some submitters feel that a ratio did not accurately capture the harm caused beyond treating the problem gamblers that present. Thus, the current ratio does not take into account the impact of problem gambling on families and the wider community, and that the majority of problem gamblers do not present.

(2 service providers [1, 82], 2 other NGOs [281, 763], 1 Individual [282], 1 industry [210], 1 academic [283])

5.3.4 Suggested ratios rejected

5 submitters rejected the proposed weightings with no alternative suggested. Some being of the opinion that the Ministry had failed to properly research the proposed ratios, and the consultation process needs to be repeated2.

(1 service provider [76], 3 other NGOs [9, 78, 87], 1 industry [280])

5.3.5 No preference

5 submitters note that they have no preference for either ratio. These submitters make a number of comments including; there are merits for both weightings, or that there is a lack of information around the ratios to form an opinion, or that they thought they lacked the expertise to comment.

(2 individuals [17, 79], 2 TLAs [2, 19], 1 academic [14])

5.3.6 No comment

12 submissions did not comment on the proposed ratios.

2 While two submitters supported the 20:80 weighting, they also noted a preference for other options, with one referring to a 30:70 weighting – [84, 85].

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(1 service provider [77], 6 other NGOs [8, 15, 20, 216, 351], 1 individual [764], 1 industry [11], 1 TLAs [217], 1 academic [762], 2 core government departments [12, 13])

The following table summarises support for the ratios presented.

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Table 3: Summary of ratio support

Submitter categories

Support 20:80

Support 10:90

Alternative suggested

Reject both, no

alternative

None preferred

No comment Total

Service providers

80, 83, 84, 88, 212, 218, 277, 759

215, 279 1, 82 761 - 77 14

Other NGOs 86, 214, 278 - 281, 763 9, 78, 87 - 8, 15, 20, 216, 351

13

Individuals 3, 22, 219 7, 21, 765 282 - 17, 79 764 10

Industry 85 213, 276, 284, 285A, 678

210 280 - 11 9

TLAs - 10 - - 19, 2 217 4

Academics - - 283 - 14 762 3

Core Government Departments

- - - - - 12, 13 2

Total 15 11 7 5 5 12 55

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6. Other Comments

Service providers should not promote anti-gambling messages if levy funding is received.

(2 industry [85, 213], 1 meeting notes [7])

Concern over the omission of Treaty of Waitangi:– Reiterates that within 2002 Draft National Plan for Minimising Gambling Harm,

the Treaty provided a clear framework for prevention and gambling harm minimisation

– Omission of the Treaty reduces negotiating ability of Maori to ensure their concerns are addressed as tangata whenua.

(2 service providers [80, 761], 1 other NGO [86], 2 meeting notes [2, 4])

Comment on principles of the strategy:– Comments on the seven objectives of the strategic plan, particularly around word

usage and provides editing examples (e.g. ‘enhance’ in title of objective 3 should have definition stating ‘human resources and funding will be available’)

– Funding required for objectives 4, 5 and 7 of strategic plan– Little mention of achievement by NGOs of objective 3 in plan.

(1 service provider [215], 2 other NGOs [8, 214])

Consultation process is perceived as flawed:– Industry members expressed dissatisfaction with lack of engagement by Ministry

of Health in developing consultation document– Inappropriate for industry to have closed meeting when industry can attend public

meetings.

(1 other NGO [87], 1 individual [282], 1 academic [762], 2 meeting notes [3, 7])

Personal stories regarding gambling harm:– One problem gambler gives an account of the great losses and hardships

experienced due to being addicted to pokies, (e.g. losing self-respect and inability to maintain successful relationships with either family, friends or partners).

(1 individual [219])

No mention of DHBs and PHUs involvement throughout plan.


Lack of control over internet gambling.

(1 other NGO [8], 1 academic [14])

Maori representation on Gambling Commission, and hearings should be open to public.

(1 academic [762])

Environmental health issues regarding non-casino gaming machines.

(1 individual [79])

Funding to support a consumer group to contribute to Ministry of Health’s long-term strategic plan.

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Ministry of Health DOC funding is increased by $100,000 to allow for an additional full-time equivalent.

(1 industry [285A])

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APPENDIX

1. Submission names and numbers

The following is the list of those who gave their permission to be identified in the summary of submission report.

Table 4: Submission names and numbersSubmission number

Organisation Name of submitter

1 Woodlands Trust Dr Vicki Fowler & Mr Bernie Smulders2 Palmerston North City

CouncilAaron Phillips

3 Barry Goodman4 Brenda McQuillan5 Visa Rose6 Philip Townshend8 National Council of

Women of NZLynda Sutherland

9 Sisters of Compassion Monty Arnott

10 Ruapehu District Council Eugene Ferreira11 The Lion Foundation Martin Cheer12 Ministry of Youth

DevelopmentMonique Leerschool

13 Department of Corrections Sue Montgomery14 Abacus Counselling

Training & Supervision LtdSean Sullivan

15 Wellington Community Law Centre

Gary Forrester

16 South East & City Primary Health Organisation (SECPHO)

Justine Thorpe

18 Dunedin Budget Advisory Service

Shirley Woodrow

19 Hamilton City Council Sarah Ward20 Wellington Central Baptist

ChurchRev Jenny McIntoshRev Dr Alan Jamieson

21 John Watson77 Te Kahui Hauora O Ngati

Koata TrustMathew McMillan

78 Wesleycare Tom White79 Russell Phillips

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80 Te Runanga O Kirikiriroa Trust Inc

Naina Watene

81 Stephen McBride82 Salvation Army, Oasis

Centre (Waikato)David Winterbourn

83 Salvation Army, Oasis Centre (Wellington)

Glenton Waugh

84 The Salvation Army, Addictions & Supportive Accommodation Services

Lynette Hutson

85 The Southern Trust John Hockaday86 Te Waka Hauora Roera Komene87 TAIA, Pacific People

Collective & Asian Gambling Services

Verna Winitana

88 The Salvation Army, Oasis Centre

Brent Diack

210 Charity Gaming Assn Francis Wevers211 Hamilton City Council A J Marryatt212 Problem Gambling

Foundation of New Zealand

Mr John Wong

213 Hospitality Association Bruce Robertson214 New Zealand Federation

of Family Budgeting Services Inc.

Mr Jarrod Rendle

215 National Pacific Gambling Stakeholders’ Fono, Niu Development

Pefi Kingi

216 Youth Health Trust Stephen Phillips217 Local Government New

ZealandBasil Morrison

218 Gambling Helpline (New Zealand)

Krista Ferguson

276 NZ Lotteries Commission Warren Salisbury277 Health Sponsorship

CouncilIain Potter

278 South Island Shared Service Agency Ltd

Faye Logan

279 Problem Gambling Foundation of New Zealand

John Stansfield

280 Clubs New Zealand Inc. Jonathan Gee281 Wellington People’s

CentreJocelyn O’Kane

282 Michael Laufiso283 Gambling Research

Centre, Faculty of Health Maria Bellringer

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& Environmental Sciences284 NZ Racing Board Lynley Sinclair285A SkyCity Entertainment

GroupDavid Kennedy

312 Waitakere Assn Gambling Action

Jacquelin Tuatara

351 Waitakere Assn. For Gambling Action Group

John Hubscher

678 Christchurch Casinos Ltd Tim Bergin759 The Salvation Army Oasis

Centre, ChristchurchDale Peach

761 Alcohol Drug Association New Zealand

Char MacPherson

762 University of AucklandFaculty of Medical & Health Sciences

Dr Lorna Dyall

763 Chris Clarke Manager, Newtown Union Health Service764 Roddy Young and John Anderson

764A John Anderson765 Graham Foster766 Roelien de Jong

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2. Editing

Detailed below are one-off editing comments raised by submitters.

General comments Include 'that all non-casino gaming machines will be eliminated by 2010'

Include section that describes the effects of introducing each type of gambling pokies, then casinos, lotto etc

Change 'gaming' to 'gambling' throughout plan

More detail needed for 'best practice' noted on page 4

Wording should be updated to reflect best practice model is an ongoing project.

Specific groups Remove clustering of ethnic groups, e.g. Maori and Pacific peoples.

Workforce development Requires reference for statement on page 4, paragraph 1, sentence 1

Seeks clarification on page 4, paragraph 1 on 'Workforce Development Forum’.

Social marketing Seeks references and/or detail on the estimated effects of the social marketing

programme.

Conference support Suggests wording should include 'event' in conference support section.

Intervention services Requires cost/benefit analysis of different treatments to show transparency of value for

money

Include trend analysis of actual cost and actual demand of treatments over time

Add a diagram to show who the target groups are and what interventions are proposed and in place

Clarify further on how brief and early interventions will work effectively within PHU and NGO services.

Helpline Wording should be modified in line with Helpline contract with the Ministry of Health,

i.e. ‘A national helpline service will continue to provide brief intervention and ongoing motivational support via telephone and other technology/electronic means’. This accommodates work the Helpline does over the internet as well as the phone

Wording should be updated to reflect that some areas have no easily accessible local service, but all areas have access to a national gambling helpline

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Wording of 'not do' should be removed from the ‘Helpline’ description in the Plan, or include what every other service will not do.

Research Explicit reference should be made to theoretical research to support the statement

'there should be decreased demand for intervention services as gambling behaviours change'.

Needs Assessment Requests that clarification be made on the ‘criminogenic needs assessment’ on page

45, (i.e. indicating what this figure means)3.

Levy Need for more detail around data input used to calculate the levy.

Presentations Change wording to reflect that the current services are meeting the need of 12% and

not meeting 88%.

Other comments Requires reference for statement on page 2, paragraph 2 relating to 'smoking ban'

References / detail on estimated return to baseline levels in three/four years

Document should highlight no major regulatory changes that may impact on availability/types of gambling

Change 'should' to 'could' as work of Professor Abbott not proven.

(4 service providers [77, 88, 218, 279], 4 other NGOs [9, 78, 86, 278], 2 individuals [3, 282], 3 industry [213, 280, 284], 1 TLA [2], 1 core government department [13])

3 Criminogenic needs assessment index only identifies risk factors that are directly related to the offending for which the person is in prison. Only 2-3% of prisoners meet this specific criteria based on their gambling behaviour in the 24 hours prior to offending. However, 10% meet the criteria when taking into account their gambling behaviour over a 6 month period prior to offending.

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Documents

Preventing and Minismising Problem Gambling … · Web viewIn this context, some service providers argue the need for additional marketing and advertising budget to create greater