Preventing and Minimising Problem Gambling Harm 2007-2010 Three Year Service Plan Summary of Submissions
Ministry of Health
8November 2006
preventing and minimising gambling harm 2007-2010 summary of submissions
Contents
1. Introduction
1.1 Background
1.2 Consultation process
1.3 Submissions received
1.4 Analysis of submissions
1.5 Report structure
Analysis of Submissions
2. Summary of Themes
2.1 Overarching themes
2.1 Overview of stakeholder feedback
3. Feedback on Three-Year Service Plan 2007-2010
3.1 Introduction
3.2 Overall perceptions of the service plan
3.3 Public Health
3.4 Intervention services
3.5 Research
4. Needs Assessment
5. Problem Gambling Levy Calculations 2007-2010
5.1 Levy amount
5.2 Levy formula
5.3 Levy weightings
6. Other Comments
APPENDIX
1. Submission names and numbers
2. Editing
1
preventing and minimising gambling harm 2007-2010 summary of submissions
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 withthe 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 Dunedinduring 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
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 attendees
- Auckland
- Hamilton
- Wellington
- Christchurch
- Dunedin
- Wellington (Government agencies)
- Wellington (Gambling industry)
- 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 (
Email invitations to submit ( )
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.
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 groupProblem 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
1.4Analysis 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.
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.
Analysis of Submissions
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
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.
TLAsrequest 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).
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 listof 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
19submitters explicitly note their endorsement of the service plan. Reasons for endorsing the plan include:
Support for specific sections of the plan, andthe Ministry of Health’s initiatives to mitigate the negative impact of problem gamblingon 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])
Reject service plan
6submitters 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])
26submitters either did not comment on the service plan, or are not explicit about whether they endorsed it or not.
3.2.2Funding 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 groupsand localities with no regional problem gambling public health provider
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
8submitters 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 groupsand feel theproposed 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 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.