The President and Vice-President of the Association of Directors of Public Health (ADPH) have written to Gambling Minister Chris Philp, making recommendations ahead of the Gambling Act review White Paper.

Although the consultation period for recommendations informing the legislative overhaul ended on 1 April, Professor Maggie Rae (President) and Greg Fell (VP) expressed their viewpoint on developing a better public health approach to treat gambling harms.  

Top of the agenda were concerns on the ‘sustainable funding of public health approach to gambling’, that Rae and Fell branded as “deeply problematic and incommensurate to the burden of harms” under its current status. 

The research, education and treatment (RET) funding model – which sees betting firm’s make voluntary contributions to grant making body GambleAware – has been criticised by some, with calls for a mandatory levy to support such programmes mounting. 

Rae and Fell echoed this sentiment in their letter, calling for a ‘clear and published aim for the levy’ backed by evidence to either fund’ health-related activities or on a wider scale ‘change the behaviour of individuals, and/or the industry’.  

“Sustainable funding of public health measures to address gambling harms is obviously critical,” they explained.

“The current situation where gambling research, education and treatment are mainly funded by voluntary contributions from the industry or fines issued by the regulator, is deeply problematic and incommensurate to the burden of harms. 

“It should go without saying that implementation of any funding mechanism should be directly linked in a ring-fenced way to regulatory interventions to reduce harm. If there isn’t a fall in profits then it might be assumed we aren’t reducing harm.”

Transparency was also a key focus with regards to administration and governance of and limitation of direct or indirect industry influence and also concerning monitoring and reviews of a levy and the operations funded by it. 

Much of the ADPH narrative also revolved around understanding ‘the breadth of harm to society’ as a result of gambling, with calls for further transparency on the proposition of levy funding channelled towards harm prevention and reduction.

The duo’s final recommendation on funding called for allocation of resources at the local, regional and national level – Rae and Fell asserted that current research and treatment ‘will have limited impact on population level harm’.

Although the UK Gambling Commission’s (UKGC) consultation and call for recommendations on the Gambling Act review ended two months ago, the topic of RET funding has recently been pushed to the forefront of the agenda – perhaps explaining the ADPH’s late contribution. 

The debate on a statutory levy has seen conflicting viewpoints – GambleAware CEO Zoë Osmond is one of the most notable voices in favour, but leaders of the Northern Gamblng Clinic (NGC) and Social Market Foundation (SMF) thinktank have criticised the organisation for perceived lack of independence from the industry, and have called for RET duties to be transferred to a new organisation.  

Last February, NHS governors informed GambleAware that they would no longer accept grants from the gambling sector to help co-fund UK-wide problem gambling clinics and RET  programmes. 

A further stakeholder perspective was presented by Jordan Lea in a discussion with SBC News last month. The Dealmeout Founder and CEO held criticisms of GambleAware for allegedly allowing funds to sit in its accounts – prompting a response from Zoë Osmond – whilst arguing that the NGC and SMFs calls for a NHS-focused levy would do more harm than good.

Weighing in on the institutional debate, the APHD added that there should be ‘a much stronger role for DHSC in the administration’ of any levy funding, whilst also calling for more involvement of the Office of Health Improvement and Disparities (OHID)  – a new body launched by the government in 2021 to tackle the health inequalities within UK society

Specifically, the APHD argued that the OHID should ‘take a lead role in providing public health advice, warning and education’ related to gambling, and calling for a requirement for the industry to present government-issued warnings and information.

Rae and Vell explained: “Public understanding of the serious nature of gambling and gambling harms has been undermined by a narrative promoted by successive governments and the industry that gambling is enjoyable and safe if people do it in a responsible way and for the right reasons. 

“As with smoking, the public is often led to believe that any addiction is down to personal choice, some individual fault or lack of control.”

The White Paper judgement dictating the regulatory future of UK gambling has been long overdue, with UKGC CEO Andrew Rhodes recently stating that the wait should not be used as an excuse for the industry to avoid tackling problems. 

However, with more voices weighing in on the contentious topic of RET funding, which has to some extent become the cause celebre of the review in recent months, more details may need further hashing out.