NHS clinicians: Mandatory RET levy must replace “failed” voluntary system

The report’s authors, Prof Henrietta Bowden-Jones, the director of the National Problem Gambling Clinic and Dr Matt Gaskell, clinical lead for the NHS Northern Gambling Service, said the levy was needed to replace “informal and unpredictable” voluntary payments.

Currently, businesses licensed by the Gambling Commission must make an annual financial contribution to one or more organisations on a list approved by the regulator, including a contribution to each area of research, prevention and treatment.

However, the Commission says that it does “not specify an amount which may be contributed as this could be seen as imposing a levy, which is a power reserved for parliament.”

However, the authors argued that this had been ineffective, pointing out that some operators had made “risible” contributions.

The report added that the funding structure meant that research, education and treatment providers were reliant on the industry and thus couldn’t effectively plan ahead as they do not have guaranteed stable funding.

“The unpredictability of the voluntary system means that the industry maintains a degree of inappropriate control over funding, which diminishes the independence and agency of those service providers who are in receipt of its contributions,” the authors added.

As a result, the report argued that the current model is “not fit for purpose”.

Instead, it called for a statutory levy. The 2005 Gambling Act explains that if the government felt that the voluntary funding model wasn’t working, it could introduce “alternative funding mechanisms… including a levy”. 

Under the Gambling Act, the secretary of state for Digital, Culture, Media and Sport has the power to determine the rate at which the levy would be set, though this would also have to be approved by the Treasury.

The report argued that a Joint Advisory Levy Board should also be created, in order to oversee the levy. This body, it says, would be “led by the Department of Health and Social Care” with consultation from a number of other gambling harm experts. This, it says, would ensure that those responsible for healthcare would have a greater influence when it came to treating gambling harm.

The authors went on to explain how they thought such a levy should be implemented. Rather than a single rate for every licensee, it said a “polluter pays” model should be put in place.

They said that a fixed rate would “make no distinction between different sectors of the industry, regardless of the market realities facing each sector and the link between those realities and harm”.

In addition, the report noted that the levy could create “asymmetries” if applied on top of existing taxes, particularly as many online operators are based outside the UK and not subject to UK taxes, while land-based operators do not typically have this option.

To implement this system, the authors argue that the Joint Advisory Levy Board should assess the relationship between certain gambling products and harm and then “allocate the levy accordingly”.

A number of other groups have come out in support of a statutory levy, including GambleAware and the House of Lords Select Committee on Gambling.

As the main beneficiary of industry funding, GambleAware has also received criticism. Last month, the NHS announced it would cease its dual commissioning and funding arrangement with the GambleAware charity for specialist gambling clinics from 1 April.

The report said that not only should the levy be introduced, but that this should be done immediately rather than waiting for the Gambling Act Review to be completed.

“There is no reason for the government to vacillate any longer on this matter, or to use the ongoing review of the 2005 Gambling Act as a reason for further delay in introducing a formal, integrated framework for RET funding,” it said. 

“A statutory levy is already provided for in the existing legislation and there is widespread support from almost all major voices in the gambling reform debate for a levy to be introduced.”

Besides its recommendation of a levy, the report also discusses the measurement of gambling harm. It notes that the currently common measurements, such as the Problem Gambling Severity Index, measure harm for the individual gambler, but not harm that may be caused to loved ones or society at large.

As a result, the report said that there is “a need for a stronger evidence base to define, categorise, measure and reduce gambling-related harm”.

It said that one major current failing is that reports intended to examine gambling-related harm often looked at the same pieces of secondary research. Instead, it said there was a need for more primary data such as randomised controlled trials on interventions.

The authors also said that while research, education and treatment were important, prevention of gambling harm and full recovery from its effects also needed more focus. As a result, it said the Gambling Commission should replace the RET acronym with PRETR to include prevention at the start of the process and recovery at the end.

The Social Market Foundation published a report on the industry in general in 2020. This report  called for, among other things, a £100 monthly “soft cap” on deposits, after which affordability checks must be carried out for further spending.

Last year, another SMF report argued that tighter regulation of the sector may lead to economic benefits, as money spent on gambling may instead go towards sectors with higher economic multipliers.