GambleAware response to statutory industry levy consultation

Following the closure of the consultation on the structure, distribution and governance of the statutory levy on gambling operators, Zoë Osmond, CEO of GambleAware, said:  

“GambleAware welcomes the introduction of a statutory industry levy to fund gambling harms research, prevention and treatment (RPT). This is something we have long called for and it marks an important step-change in efforts to tackle gambling harms.  

“Following years of uncertainty, the levy will provide clarity of funding for the gambling harms sector, support long-term planning and prevent duplication of work. We hope this means we can finally move on from the unhelpful distraction of debates about independence and funding, to now focus on working collaboratively to ensure the best system is in place to protect people from harm.  

“The levy has the potential to transform the prevention and treatment of gambling harms for those at-risk and their loved ones in Great Britain. However, there are several core elements of the proposed approach that we believe will not facilitate this transformation and could impact service provision and access for those in need.

“Firstly, to ensure the levy is as effective as possible, a National Strategy for the Prevention and Treatment of Gambling Harms must be developed to underpin the new system. This is not in the proposals, but without one it will not be possible to transform the capacity and capability and develop an integrated system of prevention and treatment.  

“A public health approach is the most effective and cost-efficient way of addressing societal issues like gambling harms. Our preference would be to have a single Prevention and Treatment Commissioner to ensure increased awareness of the issue and equal accessibility of services across England, Scotland and Wales. In the absence of this, it is essential that the Treatment and Prevention Commissioners work closely together within an agreed strategic and governance framework, to ensure the system is working as effectively as possible. Retention of the third sector’s expertise and in prevention and treatment be essential to reduce the strain on NHS services.  

“We will ensure that GambleAware’s strategic commissioning skills, experience, capacity and capability support the foundation of the new prevention commissioning body. We are committed to working collaboratively with partners across the Government, third sector, local authorities, the NHS and counterparts in Scotland and Wales during the transition period and in the longer term to ensure the new system works as effectively as possibly.  

“In our view, the current proposed funding allocations do not adequately reflect the potential population-level benefits of shifting spend upstream to focus more on prevention and early intervention, which is at the heart of a public health approach. In order to have a meaningful impact on gambling harm at a population level across Great Britain, prevention must be reprioritised with additional funding. At a minimum, there should be an equal focus on both prevention and treatment.  

“The current definitions of treatment and prevention used in the consultation fail to recognise that prevention is broken into primary, secondary and tertiary approaches which continue through to treatment and care. Under the current proposals, important interventions which are usually defined as Tier 1 and Tier 2* prevention, like the National Gambling Helpline, will fall under the remit of the Treatment Commissioner. 

"We recommend the co-commissioning of Tier 1 and Tier 2 interventions, including the Helpline, and propose that the delivery of national public awareness campaigns and digital early interventions should be included within the remit of the Prevention Commissioner. This will help ensure increased awareness of the issue and equal accessibility of services across England, Scotland and Wales.  

“As well as the third sector, there a range of other key stakeholders from primary care, the health and social care sector, local authorities, the criminal justice system, and, most importantly, people with lived experience of gambling harm. Their expertise must be sought, and their voices heard.  

“Lastly, a smooth and stable transition to the new system is vital. Leaning on the established expertise of the third sector will be critical, and clarity on funding for both GambleAware and the wider sector is urgently needed to prevent any disruption to the existing support and treatment services, which help hundreds of people every day.  

“We hope these issues will be addressed so that the transformational potential of the levy can be realised, and we can truly secure a society free from gambling harms."  

If you’re worried about how gambling makes you feel, we can help. For free and confidential advice, tools and support, search GambleAware or contact the National Gambling Helpline, available 24/7, on 0808 8020 133.

*For clarity, using a public health model definition, primary prevention includes upstream population interventions such as behaviour change campaigns and education; secondary prevention includes interventions such as workforce training, debt advice services. Tier 1 interventions which provide information and advice such as the Helpline, Tier 2 treatment which includes screening including in general practice, and referral to specialist treatments, extended brief interventions, triage, aftercare; tertiary prevention includes Tier 3 which is structured, psychosocial treatment delivered as community based- outpatient, and Tier 4 which is residential treatment.