Gordon Moody Association – Written evidence (GAM0032)

Our key purpose is ‘to provide high quality, innovative therapeutic support to those affected by problem gambling including raising awareness of the issues of gambling related harm’. Underpinning our purpose, we developed a core set of values in 2018, which are integral to how we deliver our services:

1.              Non-judgemental – ensuring that we listen to people, respect them and value their beliefs

2.              Empowerment – equipping our service users with the knowledge, skills and abilities to improve and enhance their lives

3.              Passion – being dynamic, committed, enthusiastic and caring

4.              Honesty – being open and transparent

5.              Open to change – evolving our approach, being forward thinking and open to innovative new ideas

We currently provide a range of treatment services as summarised below:

• Specialist residential treatment programme – 2-week assessment followed by 12-week therapeutic programme providing 18 units in the West Midlands and south London based on a Therapeutic Community model
• Halfway House Accommodation and relapse prevention support for up to 14 people for up to 3 months following residential therapeutic treatment
• Outreach support for ex-residents who have moved on. We provide them with face to face, telephone and on-line support
• Mixed Model of Care (MMOC) – offers a retreat programme and counselling providing 3 programmes a year for up to 36 women and 1 programme a year for up to 12 men.
• Gambling Therapy providing on-line support and advice for those problem gamblers outside of Great Britain, supported by our GT App.

1.                                                     Gambling Act - We at Gordon Moody see little evidence of crime and disorder other than individual activity perpetrated in the pursuit of feeding an addiction. We reference this below.  We have no evidence to say that gambling is being conducted unfairly.  However, we do believe that more could be done to educate the young and vulnerable as to the risks of not just gambling, but other risky lifestyle activities including emerging genres such as ‘gaming’.
2.                                                     Legislation and regulations need to be revised to reflect the massive shift in how people are gambling and to include the regulation of gaming.  Products such as loot boxes need to be taken seriously and the risks that they pose introducing children into the habits and normalisation of taking risks with money or money’s worth. When the 2005 Gambling Act was drafted, there was no ability to gamble on mobile devices as there is today, and despite the best intentions, the 2005 Act has proved unable to keep up or adapt to evolving technology. Whether this is through an extension of the current act or a new act altogether, there needs to be a set of regulations and legislation for the digital age.

The table below shows the areas of gambling for those who entered our residential centres in 2017/18 (2018/19 data pending). 

3.               Regulation - In our experience we have no awareness or examples of poor regulation, either off-shore or on-shore. We have in the past seen examples of remote operators marketing to problem gamblers, but that practice has been addressed via stricter regulation and operators improving their processes and procedures.

4.              Legal duty of care - Whilst all gambling operators have a responsibility to protect their customers from the harm of gambling, we do not believe that they have, or should have a legal duty of care.  The issue of gambling addiction is a health related one and should therefore fall under the remit of other statutory bodies who provide that duty of care.  In our view, health and social care issues cannot be deemed to be a legal duty for private sector businesses.   We do believe however, that more could be done to identify those who’s gambling is out of control and when doing so, provide them with relevant pause for reflection and signposting.

5.               Social and economic costs of gambling - The average age range of residents in 2016/17 was 36 for the residential treatment centres and the table shows the ages that most started gambling. (this is self-reported data).

Residents who were in treatment with us during 16/17 had gambled £3.6m average for a total of 74 residents.  Total debt amongst this group at that time was £1.2m.  Between 2011-2017, 319 people reported gambling £12,208,379 between them.

The cost to society should not only be counted in terms of the financial cost to an individual.  Impact on their loved ones and family members should also be measured in terms of the devastating impact it can have on their own mental health, physical health, family relationships, employment and quality of life - thus demonstrating the wider social impact of problem gambling.

However, it should be remembered and recognised that Problem Gambling is rarely a solus condition and is in many instances a symptom of a problem rather than the cause. As mentioned above, problem gambling is a mental health issue which carries much wider implications and complications, as with many, if not most other addictions. It is therefore incorrect to singularly blame gambling in isolation for the entire costs related to every problem gambler and their relationship network.

During 2017/18 88 residents told us that they had committed a crime in order to funding their gambling with 28 of them having received a criminal conviction.  The average cost per prisoner was estimated by NOMS in 2015/16 to be £35,182.  10 of the28 residents reported they had received custodial sentences with an overall cost to society of some £351,820.

The table below shows the employment status of those in treatment with us during 2017/18.

6.               Social and economic benefits of gambling - We have no comment to make on this point as we have no data regarding this.

7.              Levy - The Gordon Moody Association (GMA) has been managing a waiting list for treatment for many years now. Our waiting list is one of the few (if not the only) genuine registers of known problem gamblers as they have been assessed by ourselves as needing treatment.  The GMA is physically restricted by the number of bed spaces in its residential treatment facilities, so to be able to address the waiting list for treatment we would need to have the funding to facilitate more bed spaces. We are aware that for several years there has been unallocated funds in the RET resource pool, but our requests to increase capacity for treatment have never been followed through by the commissioners.

The GMA does lose contact with many on the waiting list before a vacancy becomes available to them, and we feel that the system is subsequently letting these people (who have asked for our help) down.

We would suggest that more RET funding is not the answer. But we would say that the funding that we have available to us collectively already should be spent where it is need by those asking for our help.

Any requests for further funding, whatever the mechanism for raising it, should be supported by hard evidence that it is going to make a genuine difference. Far too many people and organisations cast around arbitrary numbers that the Gambling Industry should be contributing to RET without any factual support. This does not help those in genuine need of our help.

8.               Research - Research in the UK needs to be better co-ordinated with the impact of that research being used to improve services and to improve the gambling harm minimisation approaches.  Far too often over recent years the research that has been carried out only leads to more research and does not produce any outcomes. The closer to actual gambling activity that research can be carried out, the more accurate the results will be, and the more effective the outcomes. 

Research should be used for everyone’s education and to raise awareness as well as identify what other needs there may be. One clear portal for all gambling related harm should be developed so that any research can be referred to easily.

9.               Children and young people - We need to get with the times around how young people now live their lives on-line. It will take time to understand the implications of the on-line world and gambling addiction so research should start now to consider the longer-term impact. We know that ‘gaming’ and ‘gambling’ are often conflated by parents and by school teachers thus skewing our understanding of what is really going on.  Education is imperative as part of the education agenda along with other issues that are carried out as part of PHSE in schools.  There are surely lessons to be learnt from alcohol and smoking impact campaigns that can be considered along with health and wellbeing input (PHE & NHS).

10.               Education - We have not done nearly enough in the area of education over recent years. You will be aware that there is a charity called YGAM whose sole purpose is to facilitate the education of children in ‘digital resilience and awareness’. This education includes gambling and gaming and the internet generally. This charity has not been funded by the RET commissioners for many years now and is an example of where existing unspent funds could have been used to great effect. Public health awareness campaigns explaining the risks (much like the smoking ones) and where to go to get help can only be beneficial.  The stigma needs to be broken down and lessons learnt from the mental health field who have been making good progress over recent years to address an issue that has been stigmatised for many years.

11.               Treatment - At GMA we have been involved in two pieces of research with the University of Lincoln which look at predictors of treatment drop out and trends and patterns based on 15 years of data relating to those who have been in treatment with us.

We believe that our treatment models do work as we see excellent outcomes for those who either come into our residential treatment centres, who access our Retreat and Counselling Programme or our international Gambling Therapy service.

Some of the statistics for 2018/19 are below:

Residential Treatment

•                                 Residential treatment applications totalling 650 – up by 35% from the previous year
•                                 74 people entered our 2-week assessment phase in our rehab centres – 89% completed this part of the programme
•                                 74% completed the residential programme an improvement from 67% last year (substance misuse services are generally around 35% completion rates)
•                                 Service user satisfaction for residential stay – 84%

Specialist Women’s programme (renamed Retreat and Counselling Programme)

•                                 160 referrals for the 3 programmes per year that we run – with 34 taking part
•                                 76% completion rate for the whole programme
•                                 Service user satisfaction of 93%

Men’s pilot

•                                 One cohort per year with 7 attending and 100% completion rate
•                                 Service user satisfaction – 88%

Gambling Therapy

•                                 GT Website visits up from £3.4m to £4.7m
•                                 GT App downloads 10,732 up from £7041
•                                 Over 60 different countries per month use the on-line chat facility
•                                 9 groups facilitated on-line every week internationally
•                                 Increase to 64% using mobile device to access GT

Below are the key findings from the research papers as mentioned above:

Paper 1 - Trends and Patterns in UK treatment seeking gamblers: 2000–2015 – Published September 2018 with Science Direct: https://www.sciencedirect.com/science/article/abs/pii/S0306460318308505

Highlights

•                                   Forms of gambling identified as problem forms have changed over time.

•                                   Increases in Fixed Odds Betting Terminals, Poker, & Sports Betting.

•                                   Decreases in Horse and Dog Racing, and the National Lottery.

•                                   Gamblers more likely to have attempted suicide in recent years.

•                                   Gamblers more likely to report a co-morbid mental health disorder in recent years.

Paper 2 – Predictors of Dropout in Disordered Gamblers in Residential Treatment - 2000-2015 – currently under peer review pending publication

Highlights

•                                   Confirmation of high rates of both enforced and voluntary attrition

•                                   Clinicians need to be aware of the characteristics of those who are at risk of termination and make attempts to retain them in treatment

•                                   Data spans large time period (15 years) however does not give any information regarding those who did not seek treatment nor relapse rates

•                                   First study to investigate dropout rates among a large group of individuals attending the only residential in—patient treatment in the UK.

12.               Suicide and gambling - Research – coroners need to be recording suicide relating to gambling addiction in the same way that they do for drugs and alcohol.  Better and stronger links with mental health services, Samaritans and GP’s awareness of gambling related harm should be as common as their knowledge of drug and alcohol addiction.

13.               Advertising - This is a key area where more empirical evidence is needed so that decisions can be made based on fact rather than hypothesis. Surely, with the wealth of resources put into marketing and advertising research over the years by big conglomerates, there is data out there that will inform any unintended consequence of advertising. If not, then RET funding should be channelled accordingly.

14.               Gambling and Sport - This is a key area where more empirical evidence is needed so that decisions can be made based on fact rather than hypothesis. Surely, with the wealth of resources put into marketing and advertising research over the years by big conglomerates, there is data out there that will inform any unintended consequence of advertising. If not, then RET funding should be channelled accordingly.

15.               Gambling by young people and children - The GMA has been working with the University of Lincoln on a range of papers including ‘psychological correlates in treatment seeking gamblers’; differences in early age onset gamblers vs later age onset gamblers’ was published in Addictive Behaviours journal here:

https://www.sciencedirect.com/science/article/pii/S0306460319300577?dgcid=author. 

              In summary:

• Early age onset gamblers (12 and under) reported increased gambling severity.
• They were more likely to have abused drugs or solvents than the older age of onset group.
• Early age onset gamblers were more likely to have committed an unreported crime.
• They were more likely to have a parent with a gambling problem.
• Age of onset was not associated with treatment completion or dropout.

16.               Lottery - The legal age for the purchase of gambling products should be raised to 18 years old – the fact that today a 16-year old cannot leave school but can purchase unlimited scratch cards at £5 per go for a £10,000 gamble seems inconceivable.

17.               Children - We are not aware of any evidence that playing such machines at the seaside is a gateway to problems in later life. If there is any evidence, then such decisions should be made carefully and based on facts, as many families have enjoyable times and happy memories from interacting with these ‘fun’ products.

18.               Lotteries - We have no comment to make on this question.

19.               Governing the National Lottery - We have no comment to make on this specific question but, we do believe that National Lottery sales should have to meet the same levels of social responsibility using the same responsible gambling measures as other gambling activities. Particularly in the areas of test purchasing, self-exclusion and making interventions when problematic use is noticed. The vulnerable need protection in this area too.

5 September 2019