Preventing and Minimising
Problem Gambling Harm 20072010 Three Year Service Plan
Summary of Submissions
Ministry of Health
8 November 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
1
1
1
2
3
4
Analysis of Submissions
5
2. Summary of Themes
6
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
6
7
8
8
8
14
21
27
4. Needs Assessment
30
5. Problem Gambling Levy Calculations 20072010
31
5.1 Levy amount
5.2 Levy formula
5.3 Levy weightings
31
32
35
6. Other Comments
39
APPENDIX
41
1. Submission names and numbers
2. Editing
41
44
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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 with the 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 Dunedin
during 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
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PREVENTING AND MINIMISING GAMBLING HARM
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
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 numbers
Meeting location
1. Auckland
2. Hamilton
3. Wellington
4. Christchurch
5. Dunedin
6. Wellington (Government agencies)
7. Wellington (Gambling industry)
2.
No. of attendees
38
19
19
25
28
3
9
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 ( www.moh.govt.nz/problemgambling)

Email invitations to submit ( problemgambling@moh.govt.nz)

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.
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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 group
Problem Gambling 14 submissions (1, 77, 80, 82, 83, 84, 88, 212, 215, 218, 277, 279,
Service Providers
759, 761)
13 submissions (8, 9, 15, 20, 78, 86, 87, 214, 216, 278, 281, 351,
Other NGOs
763)
10 submissions (3, 7, 17, 21, 22, 79, 219, 282, 764, 765)
Individual
9 submissions (11, 85, 210, 213, 276,
Industry
280, 284, 285A, 678)
4 submissions (2, 10, 19, 217)
Territorial Local
Authorities (TLAs)
3 submissions (14, 283, 762)
Academic
2 submissions (12, 13)
Core Government
Departments
Total
55 submissions
1.4 Analysis 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.
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PREVENTING AND MINIMISING GAMBLING HARM
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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 threeyear 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.
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2007-2010 SUMMARY OF SUBMISSIONS
Analysis of Submissions
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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
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PREVENTING AND MINIMISING GAMBLING HARM
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
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.
TLAs request 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).
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PREVENTING AND MINIMISING GAMBLING HARM
2007-2010 SUMMARY OF SUBMISSIONS
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 list of 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
19 submitters explicitly note their endorsement of the service plan. Reasons for endorsing
the plan include:

Support for specific sections of the plan, and the Ministry of Health’s initiatives to
mitigate the negative impact of problem gambling on 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])
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Reject service plan
6 submitters 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-todate 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])
26 submitters either did not comment on the service plan, or are not explicit about whether
they endorsed it or not.
3.2.2 Funding amount and allocation
Overall, submitters are divided on the proposed funding of the service plan. Nonindustry 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 groups and localities with no
regional problem gambling public health provider
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2007-2010 SUMMARY OF SUBMISSIONS
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
8 submitters 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
groups and feel the proposed 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])
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PREVENTING AND MINIMISING GAMBLING HARM
2007-2010 SUMMARY OF SUBMISSIONS
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.

For prisoners:
– Including new interventions established by the Department of Corrections and the
Ministry of Health, (i.e. ‘Eight Gambling Screen’ which screens offenders for
gambling problems in order to address root causes).

The provision for more services to cater to the needs of the following specific groups at
a generic level: survivors of trauma (e.g. refugees); migrants; older people; low socioeconomic populations; and people who live in low socio-economic areas.

For specific groups on the whole, reducing barriers to access and filling gaps in service
provision, for Maori, Pacific, refugee and migrant peoples.
(6 service providers [83, 212, 277, 279, 759, 761], 5 other NGOs [9, 78, 86, 87, 763], 1
individual [22], 3 academics [14, 283, 762], 2 core government departments [12, 13],
meetings [1, 2, 3, 4, 5])
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PREVENTING AND MINIMISING GAMBLING HARM
2007-2010 SUMMARY OF SUBMISSIONS
Culturally appropriate response
7 submitters comment that the plan fails to offer a cultural, social and economic response
appropriate to Maori, Pacific and Asian communities. Some suggestions on how to create
stronger linkages with these communities are:

Developing more partnerships with communities and supporting groups to develop their
own models

Having outreach services for and branching out into smaller ethnic communities and
recognising the separate groupings within each wider ethnic community, (e.g. the wider
Asian community consists of many smaller ethnic communities)

Resources in languages other than English

Acknowledging cultural differences between Maori and Pacific.
(3 service providers [83, 84, 212], 3 other NGOs [9, 86 87], 1 industry [11]).
More funding for at-risk groups
5 submitters express the need for the allocation of sufficient funding for extra services
targeted for specific groups. Comments reflecting this include:

Funding for provision of dedicated services for specific groups

Increasing percentage of funding allocated for specific groups, (e.g. one submitter
comments that 20% of the total budget should be provided to address health
inequalities and high problem gambling with Pacific and to develop Pacific capacity)

Funding for schools to provide information on problem gambling in their lifestyle skills
curriculum.
(2 service providers [215, 761], 2 other NGOs [15, 20], 1 academic [14]).
More research for at-risk groups
4 submitters wish to extend research to include specific groups. Consideration needs to be
given to creating research opportunities that encompass all types of ethnic groups, with an
emphasis on culturally appropriate research to aid these groups in preventing and minimising
gambling harm.
(2 service providers [212, 761], 1 industry [280], 1 other NGO [78]).
More advocacy services
2 submitters comment that there are insufficient advocacy services in place for specific
groups, specifically for Maori, Pacific and Asian sub-groups.
(1 service provider [212], 1 other NGO [87]).
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PREVENTING AND MINIMISING GAMBLING HARM
2007-2010 SUMMARY OF SUBMISSIONS
3.2.4 Innovation in service plan
13 submitters comment on innovation in the service plan, from generic comments on
the lack of innovation to more specific detail of how to make the plan more innovative.
6 submitters comment that the service plan lacks innovation, and there is a need for more
innovative alternatives to treatment and service provision. 2 submitters suggest the provision
of more Ministry of Health staff for additional policy and innovation resources, especially if
this will also result in robust effectiveness data.
(2 service providers [218, 279], 3 other NGOs [9, 281, 763], 1 individual [219]) meeting [3, 7])
9 submitters make specific comments relating to innovation including:

Strategies to address low access rates and barriers to access, (e.g. provider and
community initiated projects)

Development of a screening tool to identify other linked factors that influence gambling
(e.g. alcohol, smoking)

Innovative intervention programmes for prison

More research to find innovative solutions around problem gambling in casinos, as this
is a projected growth area

Online internet based individual and group counselling and self-directed learning
models

Greater collaboration between all stakeholders to develop innovative tools for harm
identification and minimisation in the gambling environment.
(4 service providers [84, 759, 760, 761], 3 other NGOs [9, 78, 278], 1 individual [219])
3 submitters also request a contestable/discretionary fund for piloting genuine innovative
practice over and above the standard contracted services offered by providers.
(3 service providers [84, 218, 761])
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2007-2010 SUMMARY OF SUBMISSIONS
3.3 Public Health
3.3.1 Public Health Service
Of those submitters that comment on public health services, the majority are offering
their support for the public health focus. Some comment on the need to support the
latter with restrictions on gambling opportunities. Funding is also mentioned with some
arguing for more money for public health, especially for at-risk groups, while others
argue that there is no need to increase funding allocation.
Support investment in public health
9 submitters note their support for the Ministry’s proposed investment in a public health
approach including the need to address the underlying social, economic, cultural and
environmental determinants of health. A few mention the need for specific focus on Maori
and other at-risk groups in developing and supporting a public health approach to reducing
problem gambling harm.
(3 service provider [277, 279, 218], 1 other NGOs [278], 1 individual [219], 1 TLAs [2], 2
industry [276, 285A], 1 academic [762])
More restrictions on gambling
13 submitters request that a public health approach be supported with more restrictions on
gambling access and its marketing and advertising, especially for at-risk groups. Further,
some suggest that the gambling industry be more transparent and accurate in their
disclosure to customers over the probability of winning, and they undertake more harm
minimisation initiatives. Others comment on the need for more rigorous enforcement and
prosecutions by the Department of Internal Affairs of establishment owners not abiding by the
law.
(4 service providers [82, 84, 279, 759], 5 other NGOs [8, 9, 78, 87, 278], 4 individuals [7, 8,
282, 764])
Conversely, submitters from the gambling industry comment that reducing opportunities to
gamble does not stop problem gamblers gambling, therefore harm is not reduced by
reducing gambling opportunities.
(2 industry [85, 284])
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2007-2010 SUMMARY OF SUBMISSIONS
Funding comments
As noted earlier, funding is a key theme with some submitters indicating a need for increased
funding, specifically:

The current funding for community development action strategies is inadequate

There is uncertainty about whether District Health Boards (DHBs) are receiving
sufficient funds for public health services

More investment for mental health resources.
One industry submitter recommends no changes to public health funding.
(5 service providers [80, 215, 218, 277, 279], 1 individual [17], 1 industry [285A])
Industry’s harm minimisation initiatives not recognised
5 submitters comment that industry’s compliance to harm prevention regulations is not
considered in the plan, and that these regulated initiatives are not being evaluated.
(5 industry [11, 85, 210, 280, 284])
Other comments
Other comments mentioned relating to public health services include:

Need to work with and inform TLAs, including support for them to develop problem
gambling harm prevention policies and the allocation of $7 million for developing policy
and social and health impact assessments and monitoring programmes
(1 service provider [279],2 TLAs ([19], 217], meeting [5]).

DHBs should have responsibility and associated funding for delivery at a regional level.
(1 individual [17]

The gambling industry and their products to be better monitored to reduce problem
gambling harm.
(1 individual [22])
3.3.2 Workforce development
Workforce development comments relate to the need for more funding, specific training
for practitioners dealing with at-risk ethnic groups, staff turnover, qualifications, and the
inclusion of NGO, community and gambling industry staff in levy-funded workforce
training.
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PREVENTING AND MINIMISING GAMBLING HARM
2007-2010 SUMMARY OF SUBMISSIONS
Funding comments
8 submitters mention the need to increase funding levels for workforce development,
specifically:

Increase funding to improve the remuneration and working conditions of public health
workers

Expectation that costs will be high initially then taper off, but the proposed allocation of
$320,000 is split evenly over the next 3 years

Additional funding needed to increase the number of community development workers
and public health advocates.
(4 service providers [82, 83, 84, 759], 2 other NGO [15, 20], 2 individuals [7, 17])
Conversely, one submitter notes that the proposed funding level will support capacity
building and increasing competencies in the existing workforce. (1 industry [285A])
Industry workforce development
2 submitters comment on the need for workforce development in the industry to continue to
develop and support harm minimisation initiatives in gambling environments.
(1 service providers [761] 1 other NGO [86], meeting [7])
Training for practitioners dealing with at-risk groups
Two submitters comment on the need to focus on training requirements for practitioners
dealing with specific at-risk groups, in particular Maori and Pacific, for example:

Training and developmental needs for Maori and Pacific people working in public
health

Provision of funding for development of national Pacific cultural competencies
framework for the gambling area

Funding and provision of cultural supervision in workforce development.
(2 service providers [80, 215])
Need for qualifications
2 mention the need for undergraduate and postgraduate training in public health relating to
problem gambling.
(2 service providers [88, 215])
Other comments
Other one-off-comments relating to workforce development include:
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PREVENTING AND MINIMISING GAMBLING HARM
2007-2010 SUMMARY OF SUBMISSIONS

Queries about how new jobs will be created as service demand increases, and the
management of staff turnover

Need to align workforce development with Public Health Workforce Development Plan
(PHWFP)

Workforce development should be aligned with DAPANZ and HPCAA.
(1 service provider [82], 3 other NGOs [86, 87, 278], 1 industry [285A])
3.3.3 Social marketing programme
Overall, there is support for the proposed social marketing programme, although some
submitters feel it requires additional funds to be effective. Conversely, others are less
supportive until a more thorough cost and needs assessment has been completed, and
its alignment with other problem gambling mechanisms is defined.
Support
18 submitters indicate a level of support for the proposed investment in a social marketing
programme to promote and support public awareness and debate on gambling issues.
(7 service providers [84, 88, 215, 218, 277, 279, 759], 5 other NGOs [9, 15, 20, 78, 87], 3
individuals [22, 79, 219], 2 industry [280, 285A], 1 academic [14])
Don’t support
4 submitters are less supportive of the proposed social marketing programme. This reflects
comments that the programme should not seek to promote an anti-gambling message as
gambling is a lawful pastime and non-harmful for the majority of people. Further, there is a
need to consider and evaluate other potential mechanisms, how the programme fits with
existing harm minimisation initiatives and current service provision, e.g.:

A cost benefit analysis of a social marketing programme versus other methods

Only acceptable if part of an agreed and measurable integrated problem gambling
strategy

Review harm minimisation initiatives and how they inform the design of the social
marketing programme

An evaluation of existing problem gambling services before a social marketing
programme commences and attracts people to these services

Link to Expert Advisory Group work on how marketing of gambling can be consistent
with the Act.
These submitters also request stakeholders are consulted about the social marketing
programme, and that it should only be launched after agreement by all stakeholders.
(4 industry [210, 213, 280, 284], meeting [7])
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While there is general support for the social marketing programme, submitters critique the
programme as per the intent of the submission process.
Funding not enough for programme to be effective
12 submitters comment that the proposed funding is insufficient for the social marketing
programme to be effective in achieving the outcomes sought. They comment that in
comparison to the Victoria campaign, ‘Like Minds, Like Mine’ and LTNZ’s road safety
programme, and the amount that the New Zealand Lotteries Commission spend on
advertising and marketing, the proposed budget is low.
1 submitter recommends that there should be an annual budget allocation, (for
communication activities including evaluation), of $2.5 million, to enable moderate media
visibility for approximately 16-20 weeks per annum. They recommend that funding for the
social marketing programme be spread throughout the period of the service plan, and not
decreased to a third in the final year. However, other submitters recommend a budget of $20
million.
Further, there is need for additional funding for effective local public health initiatives and the
training of the public health workforce to support the campaign.
(6 service providers [82, 84, 88, 277, 279, 759], 3 other NGOs [15, 20, 78], 2 individuals [79,
219], 1 academic [14], meeting [4])
No additional funding for potential increased presentation to services
11 submitters note there is no contingency fund in services for the increase in presentations
as a result of the social marketing programme. A few submitters note that the Victoria social
marketing programme resulted in 26% increase in presentations.
Comment is made that the social marketing programme should focus on reducing barriers to
accessing and utilising services, given the 12% presentation rate. In this context, some
service providers argue the need for additional marketing and advertising budget to create
greater awareness of their services to complement the social marketing programme.
(6 service providers [84, 87, 218, 277, 279, 759], 4 other NGOs [9, 15, 20, 78], 1 individual
[219])
Lacks details
6 submitters note a lack of detail relating to the proposed social marketing programme, which
makes it difficult to offer considered feedback. Related to the latter, one submitter comments
that the programme needs to have clearer objectives.
(3 other NGOs [9, 15, 78], 3 industry [213, 280, 210])
Target at-risk groups
5 submitters comment that specific at risk groups need to be effectively targeted by the social
marketing programme, i.e.:
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PREVENTING AND MINIMISING GAMBLING HARM
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
Consultation and pre-testing of the social marketing programme to ensure its
effectiveness with Asian people

Culturally appropriate delivery of messages to Pacific peoples and communities by
focusing on face-to-face delivery, messages in Pacific languages and via media such
as radio, and less focus on web-based messages.
(2 service providers [78, 215], 1 other NGO [9], 1 individual [79], 1 industry [213])
Needs evaluating
2 submitters note the need for a formative evaluation component in the social marketing
programme to effectively develop and implement it, and an annual programme monitoring to
assess its results; estimated at $50,000 excluding GST per annum.
(2 service providers [84, 277])
3.3.4 Behaviour change survey
Two submitters suggest that the behaviour change indicators survey is conducted in the final
year of the service plan to identify real changes in gambling behaviour. They comment that
conducting the survey in year one (2008) will not allow enough time for gambling behaviour
to have changed.
One notes that the funding allocated to the survey in the second year is too low, as it is at a
lower cost than the current pilot.
(2 service providers [277, 759], 1 academic [283], meeting [4])
3.3.5 Resources
2 submitters comment that public health gambling resources should be based on evidence
and be designed to appeal across culturally diverse audiences as well as socio-economic
levels, age, and gender.
(1 service provider [215], 1 NGO [351])
1 submitter suggests developing resources that support host responsibility activities, and
align with the social marketing programme.
(1 industry [285A])
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3.3.6 National co-ordination
Comments relating to the national co-ordination service are split between those who support
the need and those who don’t.
2 submitters endorse the need for a national co-ordination service as it will enable the better
co-ordination of service providers with researchers at design and dissemination stages of
research. However, one submitter comments that the Ministry of Health should maintain this
function as a national policy role, as the establishment of another organisation will lead to
duplication of administration and management structures.
Another submitter comments that the effectiveness of this role is limited by sole focus on
service providers. Further, they recommend that funding for this service is increased by
$100,000 to allow for an additional full time equivalent, and expansion of the range of
organisations with whom they work.
(1 service provider [761], 1 individual [17], 1 industry [285A])
Conversely, one submitter argues that there is no reference to a need for national
coordination in needs assessment, and considers that the role detailed in the service plan is
that of the Ministry of Health and not a new 'body'. They go on to note that the coordination
of service providers is not one of the purposes provided for within the Act, and if needed
should be provided for by the service providers.
(1 industry [280])
3.3.7 Conference support
1 submitter notes that the funding for conference support for an international conference is
inadequate, and suggests that based on previous experience should be about 2.5 times
more. Other comments relate to conference support for the intervention stream, and for a
three yearly Pacific gambling conference.
1 submitter recommends that the Ministry of Health seek enhancements to the quality of the
organisation, facilitation and content of the annual international problem gambling
conference.
Another suggests broadening this category to allow for the inclusion of other events such as
the International Think Tank run by the Gambling Helpline and AUT University.
(3 service providers [80, 215, 218], 1 academic [283], 1 industry [285A], meeting [4])
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PREVENTING AND MINIMISING GAMBLING HARM
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3.4 Intervention services
3.4.1 Intervention services (secondary and tertiary prevention)
Comments on intervention services reflect issues of supply and demand, services for
families and whanau impacted by problem gambling, access enablers, recognition of
industry’s harm minimisation initiatives, and targeting of specific populations.
Supply and demand debate
6 submitters comment that funding for intervention services will not meet the likely increase
in demand, or current demand, or reduce barriers to accessing services. Further, there is no
provision for clinical services or the recognition that a successful public health approach will
lead to increased activity and presentation.
(2 service providers [77, 279], 2 other NGOs [9, 78], 2 individuals [282, 219], meetings [1, 5])
Conversely, others comment that there is excess capacity and demand is decreasing and
this should be reflected in funding allocation. These submitters recommend that service
providers should be funded at actual levels of demand and not forecasted demand.
There is also concern that intervention services are allocated the bulk of the budget, but they
are only one component of the overall strategy. Further, the services have not been audited
and evaluated and their effectiveness is therefore unknown. On this basis, it is argued that
these services should not receive additional funding until their effectiveness is established.
In this context, the Ministry of Health is criticised for not properly monitoring problem
gambling intervention services, and that new services continue to be funded despite
decreasing demand.
(5 industry [11, 85, 210, 280, 285A], meeting [7])
Funding for advertising
5 submitters request more funding for advertising and marketing to promote their services
and assist in reducing access barriers, (e.g. $250,000 per annum).
(2 service providers [218, 279], 2 individual [219], 1 academic [14])
Improving access
4 submitters comment on the need to increase opportunities to access problem gambling
services for those more isolated or facing access barriers, (e.g. people in rural areas or those
from more at-risk groups). In this context, the suggestion is made of the potential of online
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PREVENTING AND MINIMISING GAMBLING HARM
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self-help material to increase support for problem gamblers, as well as phone and workbook
initiatives.
(1 service provider [279], 2 other NGOs [761, 218], 1 TLAs [10])
Other comments:

Greater collaboration and integration of service delivery in the plan
(1 service provider [279])

$100,000 funding to support Gambling Anonymous (GA) and re-establish GamAnon to
provide cost-free awareness resource through its members 'twelve stepping' via book
depository, newsletter, full-time GA administered and travel costs
(1 academic [14])

A screening tool like the ‘8’ gambling screening tool to identify smoking, alcohol, and
co-morbidities
(1 academic [14]).

Funding of intervention services should be done through DHB’s.
(1 industry [285A])
3.4.2 Helpline
There are only limited comments on the Helpline, primarily to do with funding.
2 submitters advocate for more funding to accommodate a future increase in demand for this
service, and for advertising the service. However, another recommends that funding is
reduced by 25%, given the decline in use.
Other comments include:

Suggestion to move the Pacific helpline to an independent Pacific organisation

Need for an Asian helpline service, and online support.
(2 service providers [215, 218], 1 academic [283], 1 industry [285A]).
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3.4.3 Psychosocial interventions and support
A range of comments are made about psychosocial interventions and support,
including the level of proposed funding, support for families harmed by problem
gambling, and inclusion of budgeting services as a specialist service.
Funding
5 submitters argue that services and practitioners need more funding to be maintained or
increased to cope with demand. However, one submitter argues that with the decrease in
demand, funding for psychosocial interventions and support should be reduced by 25% to
reflect the decline in access to all intervention services.
(2 service providers [77, 82], 1 individual [3], 1 industry [285A], 1 academic [14])
Family services
3 submitters comment on the need for resources to fund specialist services for family and
whanau affected by problem gambling.
(1 other NGO [278], 1 individual [22], 1 academic [14])
Family budgeting services
1 submitter comments on the need for family budgeting to be included as a specialist
intervention service, and for these workers to have training provision relating to assessment
and action if a problem gambler presents.
(1 other NGO [214])
3.4.4 Problem gambling information system
Only a few submitters comment on the problem gambling information system, offering
a diverse range of opinions.
Comments are summarised below:

Need to create an ethnic specific public health database to trace trends in attitudes and
responses of Pacific groups
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PREVENTING AND MINIMISING GAMBLING HARM
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
For public health and service providers to be involved in the development of the
system, and encouraged to share gambling intervention service information collected

Concern that gambling service clients will be identified by their National Health
Indicator Numbers

Require budget allocation for compliance costs

Concern that performance monitoring is based solely on quantitative data from the
system to the exclusion of qualitative approaches. Further, there is a perception that
the system has been developed in-house within the Problem Gambling Committee, that
it does not have the confidence of service providers, and that it requires independent
auditing and evaluation.
(3 service providers [215, 218, 759], 1 industry [280])
3.4.5 Workforce development and training
While there is general support for workforce development, submitters comment on the
need for more clarity on its objectives, more funding, and a wider range of groups to
receive training in problem gambling.
No clear objectives
6 submitters comment that the proposed workforce development lacks clear direction and
objectives, and thus for some there is insufficient information to comment in-depth. One
submitter comments that the workforce development is ongoing and this needs to be
acknowledged in the plan, especially given the high turnover of staff.
(2 service providers [219, 759], 2 other NGOs [9, 78], 2 individual [7, 219])
Funding
9 submitters comment that funding for workforce development is inadequate, specifically:

Inadequate budget to achieve workforce development aims. One submitter estimates
a further $200,000 is required for the development of the problem gambling workforce

No allowance for funding increases for services to pay for a more qualified and skilled
workforce that will eventuate from the workforce development strategy

More funding to target workforce gaps in current service provision, specifically the
needs of Maori and Pacific workforce.
(2 service providers [215, 759], 5 other NGOs [9, 15, 20, 78, 87], 1 industry [284], 1
academic [14], meeting [3])
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Workforce to receive training
11 submitters comment on who receives workforce training, and how. Submitters request
that workforce development opportunities are made available to community and NGOs to
develop their staff. In this context, a few request the Ministry of Health to consider using
existing training programmes in communities, and to place focus on practical skills as well as
an academic focus.
1 submitter suggests that workforce development should include training at multiple levels
including public health workers, clinicians, frontline bar and casino staff, and community
activists. The latter is supported by 3 submitters who request funding to train gambling
industry staff about harm minimisation.
One submitter notes the need to support the training of Asian people to conduct problem
gambling research.
(1 service providers [88], 4 other NGOs [78, 214, 281, 763], 2 individuals [219, 22], 3 industry
[11, 213, 284], 1 academic [14])
3.4.6 Audit and evaluation
Overall, there is concern about the lack of audit and evaluation of existing intervention
services.
Identification of best practice
14 submitters see the need for more projects focusing on evaluation, and the identification of
‘best practice’, so evidence-based-practices for providers can be developed. Submitters also
point out that projects need to include monitoring components.
(3 service provider [83, 218, 279], 4 other NGOs [15, 20, 78, 214], 2 individuals [17, 219], 2
industry [85, 210], 1 academic [283], 1 TLAs [2])
Lack of evaluation of intervention services
6 submitters comment specifically that expenditure on intervention services has not been
audited and evaluated. They comment there is a lack of credible evidence on the outcomes
achieved by the expenditure of the levy to date, (i.e. to identify if the costs are necessary and
reasonable). The latter is seen as critical for accountability and to ensure ongoing
improvements to the problem gambling programme.
Industry submitters note that there is wide variation in cost per user of different treatments,
and best practice for intervention services has not been established. They continue that it is
inappropriate to spend money on intervention services without proper evaluation.
Consequently, they perceive that the Ministry of Health has not met the reporting
requirements laid down in 2004 by the Gambling Commission, and there is a failure to
comply with the Gambling Act.
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(6 industry [11, 85, 213, 276, 280, 285A])
Conversely, several NGO submitters comment there is inadequate budget to establish which
service providers are effective and efficient, or to undertake a national evaluation
programme.
Other comments
Other comments relating to audit and evaluation for public health and intervention services
include:

More funding

Provision of funding for cultural, financial audits of Pacific problem gambling treatment
services

Commitment to 'ring fence’ the intervention services budget so that if some services
close after evaluation, the funding remains available for others to access

Evaluations and audit should be funded at 5% of service budget

Funding of an outcomes framework, identifying indicators or measures of gambling
related harm relevant across the gambling and problem gambling sectors

Maori involvement in monitoring and evaluating the Gambling Act 2003

Funding to determine the effectiveness of service plans in achieving the strategy’s
goals

Funding to develop and pilot a Pacific gambling service evaluation model, and a
gambling screen to identify Pacific peoples
(2 service providers [84, 215], 3 other NGOs [9, 20, 78], 1 individual [22], 1 academic [762],
1 industry [285A], meeting [1, 4])
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3.5 Research
Submitters’ reactions towards the research budget and agenda are mixed reflecting
comments on the level of proposed funding relative to other activities, potential
research outcomes, as well as suggested research projects.
Level of funding
9 submitters comment that in general research is over-funded. They suggest that the
proposed research budget should be reallocated to prevention, treatment and/or education
needs. Further, some feel there is a lack of identified need for the research projects to
support their proposed budgets.
(6 other NGOs [9, 15, 78, 87, 281, 763], 2 individual [17, 219], 1 industry [213])
5 submitters perceive that research into problem gambling is under-funded. These
submitters point out that without larger budgets researchers will be unable to carry out robust
and in-depth studies, (e.g. face-to-face interviews or longitudinal studies). Concern is also
raised over researchers having to use funding from different sources to fund research
projects, and the possible conflicts this may cause in completing projects.
An adequate research budget is also vital in making informed policy decisions, especially as
many stakeholders are unable to fund research themselves.
(2 service providers [84, 279,], 2 TLAs [2, 19], 1 academic [283]).
Research deliverables
Some submitters question the ability of the proposed research projects to result in outcomes
that will minimise problem gambling harm. Some submitters suggest there needs to be more
focus on provider, local government and community initiated research and/or action research
in the plan. The latter is seen to be consistent with the community development approach
promoted in the plan.
Suggested research topics / projects
There are a number of suggestions around possible research projects and topics,
specifically:
Socio-economic

Funding for socio-economic research as it is fundamental to understanding interrelated
determinants to and impacts of problem gambling
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PREVENTING AND MINIMISING GAMBLING HARM

2007-2010 SUMMARY OF SUBMISSIONS
Fine-grained localised social impact assessments to feed into the development and
review of TLAs’ gambling venue policies. A request for low-cost, simple options, or
specific funding.
At risk groups

Inclusion of research methodology in projects that are culturally and linguistically robust

All gambling research should over-sample Pacific populations to enable ethnic specific
analysis

Pan-Pacific prevalence survey within Pacific social and cultural contexts to build on
existing Pacific studies

Socio-economic impact study for Pacific populations

In-depth study using qualitative methodology to help unfold complex issues
surrounding Asian gambling

Research into gambling products, associated gambling behaviours and subsequent
application of host responsibility policy amongst Asian populations.
Legislative / policy

More research into the effects of legislation on gambling, (e.g. Smokefree, Racing Act,
Gambling Act)

Effectiveness of the variety of machine number caps implemented by TLAs on the
incidence of problem gambling

Amount of money lost in machines by TLA areas

More focus on effective monitoring and reporting of problem gambling as inaccurate
numbers will result in inaccurate funding for people in need.
Gambling types and related problems

Research on problematic aspects and/or features of particular gambling types, (e.g.
pokies) and environments

Investigation of the average distance/time problem gamblers travel to gambling
machines, and relationship between distance and incidence of problem gambling.
Pilot projects

Funding for pilot projects to be tested and evaluated.
National evaluation of intervention services

Funding for national evaluation programme of problem gambling intervention services.
Gambling Trusts

Research that tests anecdotal evidence that gambling trusts have shifted focus of fund
distribution towards nationally based activities, (analysis of how the support of national
organisations filters down to local level)

Distribution of gambling trust funds and the relationship of benefits of income source.
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PREVENTING AND MINIMISING GAMBLING HARM
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Other research projects

Additional funding for a feasibility study to ascertain practicality of conducting a national
face-to-face gaming survey for currently allocated funding

A thorough investigation into the barriers to presenting

Taking a wide perspective to identify the complexity of the problem, (e.g. social,
environmental, cultural).
(5 service providers [80, 212, 215, 279, 761], 4 other NGOs [15, 20, 214, 351], 4 individuals
[7, 22, 79,219], 2 industry [213, 284], 4 TLAs [2, 10, 19, 217],1 academic [283]).
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4. Needs Assessment
Overall, there is little specific comment about the needs assessment detailed in the
consultation document.
Some comment that the needs assessment is excellent, but that it does not translate into the
service plan which is described as more of the same.
(1 service provider [218], meeting [1])
Others mention that there are insufficient linkages between the needs assessment, the
proposed service plan, and calculations of levy rates. One submitter comments it is more an
environment scan rather than an assessment of problem gamblers’ needs.
(2 industry [280, 210])
Others support that the needs assessment addresses problem gambling with public health
lens recognising its complexity, in accordance with Gambling Act
(1 service provider [218], 1 individual [3])
Other one-off comments debate the content of and/or validity of the findings of the needs
assessment content, (e.g. the relationship between population density, relative social
deprivation, and gambling opportunities). These comments are not listed given the needs
assessment has been externally peer reviewed.
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5. Problem Gambling Levy Calculations 2007-2010
5.1 Levy amount
There is divided opinion on the levy amount from those who feel it is too low to those
who feel it is excessive, given declining presentations to services and gambling
opportunities.
14 submitters agree that the levy needs to be increased, so that the harm caused by
gambling can be more effectively prevented, minimised and treated. Submitters cite a
number of issues:



Increasing the levy will increase funding available so more services can be offered to
properly meet the current shortfall of services, as well as the expected increase in
demand from new public health initiatives
The levy is low in relation to gamblers’ losses, the overall harm caused by the gambling
industry, and the level of industry profit
The levy is one method to control the growth of gambling, given the lack of other
controls over advertising, the levy needs to be increased in order to limit harm.
(6 service providers [77, 82, 84, 215, 279, 759], 3 other NGOs [9, 78, 281], 5 individuals [3,
79, 219, 765, 766])
Conversely, 2 submitters comment that the proposed increase in the levy is excessive and
not justified, given the decline of presentation to intervention services, and gambling
opportunities. Further, 7 submitters state that insufficient research, evaluation and analysis
has been conducted to forecast future trends and thus set the levy for the 2007-2010 period.
Some also view this as a failure by the Ministry of Health to fulfil its obligations set down in
the Gambling Act.
(7 industry [11, 85, 210, 276, 280, 284, 285A], meeting [7])
2 submitters comment that given the lack of robust analysis to support changes to the levy,
there should be no increase to the levy. They propose maintaining the levy for the next 12
months as this analysis is completed.
(2 industry [210, 213])
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5.2 Levy formula
Overall, there is support across the stakeholder groups for an industry levy to prevent and
minimise harm caused by problem gambling. However, there is some confusion about how
the levy is calculated, its relationship to other funding pools as well as the calculations
around the recent levy under recovery. Across submitters a number of key themes relating
directly to the levy emerge as detailed below.
5.2.1 Levy formula needs to be more detailed and robust
23 submitters comment that the current levy formula is overly simplistic, given the
complexity of problem gambling and requires a more detailed and thorough analysis.
No recognition of wider harm
8 submitters comment the formula focuses on individuals with gambling problems and is not
factoring in the wider harm caused to problem gamblers’ families or their specific
communities. Consequently, the funding required to address these wider problems is not
being collected, or being distributed back to the specific communities so they can address
the problem.
(2 service providers [80, 761], 1 other NGOs [281], 1 individual [282],) 2 TLAs [19, 217], 2
academic [14, 283])
Non-linear relationship between expenditure and harm
2 submitters perceive the relationship of ‘expenditure’ with ‘harm’ is inconsistent, non-linear,
and unsupported. The more a gambler spends does not always relate to more harm, and not
all gamblers who spend a lot of money on gambling are ‘problem gamblers’. Therefore high
expenditure sectors in the industry are disadvantaged as they end up paying more in levies.
(2 industry [276, 285A])
Presentations an inaccurate proxy for harm
2 submitters feel that the use of presentations is an accurate measure of ‘problem gamblers’.
(2 industry [210,276])
Conversely, 11 submitters feel using the number of presentations as a proxy for harm is
inaccurate. This reflects that only 12% of problem gamblers are currently seeking help, and
possibly even less for groups with significant barriers to accessing help for gambling
problems, (e.g. Asian, Pacific peoples, and Maori). The point is also being made that
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‘presentations’ recorded are not discriminating between those who are problem gamblers
and non-gambling clients, (e.g. family members of problem gamblers).
However, one industry submitter comments that the current formula ‘disincentivises' host
responsibility to forward referrals to intervention services.
(4 service providers [1, 212, 218, 279], 1 other NGO [281], 3 individuals [22, 79, 219], 3
academic [14, 283, 762], 2 industry [11, 285A])
Formula is too homogeneous
4 submitters perceive the present formula as categorising all people contacting problem
gambling services under a single umbrella. Service users, level of harm, their mode of
gambling and required treatments need to be more clearly defined, with an assessment
carried out by trained professionals. They note that the more accurate the analysis of
problem gamblers, their gambling behaviour and costs associated with their treatment, the
more accurate fund collection and its distribution.
In this context, there is support for the model proposed by Woodlands Trust.
(1 service providers [1], 3 industry [11, 210, 213])
There is also comment that the calculation of the levy should follow a process where a
detailed needs assessment informs the development of a service plan, which in turn informs
the calculation of the levy to fund that plan.
(5 service providers [1, 80, 212, 218, 279], 1 other NGO [281], 4 individuals [22, 79, 219,
282], 6 industry [85, 210, 213, 276, 280, 285A], 2 TLA [19, 217], 3 academics [14, 283, 762])
5.2.2 Levy is not fair across industry
11 submitters, from both industry and providers, are concerned that different sectors
within the gambling industry are not being assessed accurately.
Level of harm
4 submitters note that without accurate assessment of the harm being done by each sector,
the accompanying levy that each sector should pay becomes inaccurate and therefore unfair.
(1 service providers [84], 1 individual [21], 2 industry [210, 280])
Focus of harm
The present formula is viewed as targeting sectors where ‘acute’ problem gambling
behaviour occurs, for example in the non-casino gambling machine industry. Some
submitters identified that there is less accountability for sectors that are ‘normalising’
gambling behaviour or providing ‘introductions’ to gambling such as the lotto products.
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(3 service providers [83, 88, 759], 1 other NGO [86], 1 industry [85])
There is also concern that the formula is masking differences in gambling behaviour between
different groups. For example, Asian gamblers predominately gamble in casinos, yet overall
this is not the normal pattern of problem gambling behaviour. There is also concern that
some groups have below average presentations, (e.g. Asian, Pacific Island). The outcome of
this is that some sectors such as casinos are not seen as creating harm on the whole, but for
certain groups such as Asian gamblers casinos are causing significant harm. Classing
problem gamblers as one group penalises industry sectors unfairly.
(2 service providers [77, 212])
It is suggested that some members of the industry, such as ‘clubs’, should be levied in a
different manner considering their fundamental differences to more commercial operations.
Linked to the latter are requests for greater recognition of contribution other members of the
gambling industry make back to the communities in the form of grants.
(3 industry [210, 213, 280])
There is also concern over the impact of the growing and unlevied ‘other’ sector, especially
internet based gambling and private gambling, (e.g. poker). At present, harm caused by
these other sectors is being paid for the remaining sectors. This is seen as unfair by some
submitters.
(2 industry [85, 285A], 1 other NGO [8].
Treatment calculations
The present ‘cost for treatment’ calculations also need more detail. It is suggested that
administrative costs of running a service is separated from the per treatment cost. This will
allow administrative costs to be shared equally across the industry. Additionally, the formula
does not account for the differences in the cost of treatments for gambling addictions to
different industry sectors.
(2 industry [85, 210])
(7 service providers [77, 82, 83, 84, 88, 212, 759], 1 other NGOs [86], 1 individual [21], 1
academic [14], 5 industry [85, 210, 213, 280, 285A])
5.2.3 Frequency of forecasting
Request for more frequent forecasting to enhance accuracy.
6 submitters suggest that the levy be calculated more frequently to better respond to the
unforeseeable effects that are occurring in both the gambling industry, (e.g. legislation such
as ‘Smokefree’), and problem gambling, (e.g. possible increased demand due to the social
marketing programmes). This reflects that inaccurate calculations result in the levy being
34
PREVENTING AND MINIMISING GAMBLING HARM
2007-2010 SUMMARY OF SUBMISSIONS
recovered from the ‘wrong’ sectors in the industry, as well as the wrong amount being
collected to treat the harm actually done.
Infrequent forecasting is seen as resulting in projections that do not accord with the actual
expenditure and presentations. These forecasting inaccuracies are perceived as a major
cause of the recent under-recovery of the levy. Although, the under-recovery arose from a
lower than forecasted performance in some sectors of the gambling industry, (e.g. noncasino gambling sector), the recovery is being spread equally over the entire industry. This
is seen as unfair by some submitters.
While the levy is currently calculated every three years, the Gambling Act allows for shorter
timeframes, if warranted. Calculating the levy more frequently will bring it in line with other
Government levies, such as the annual ACC levy.
(6 industry [11, 85, 213, 284, 285A, 678])
5.3 Levy weightings1
Opinion is fairly evenly divided on the preferred levy weighting.
5.3.1 Support for 20:80 weighting ratio
15 submitters support the 20:80 weighting ratio.
The 20:80 ratio is seen as preferable for a number of reasons:
1

The cost of providing treatment is not a direct relationship to the number of people
seeking help

Better reflection of the broader approach being taken in the service plan to prevent and
minimise gambling harm, and not just treating harm

Presentations do not reflect the cost of treatment for addictions to different gambling
modes

10:90 is low compared to gamblers’ losses, harm done, and industry profits

Focusing less on numbers of problem gamblers actually presenting and more on
gamblers’ expenditure better reflects that many problem gamblers don’t actually
present

Weighting presentations less links better to funding strategies not directly linked to the
treatment of those that present, (e.g. prevention programmes).
Reflecting the closed question in the submission form, Litmus undertook a closed coding process i.e there was no multiple codings.
35
PREVENTING AND MINIMISING GAMBLING HARM
2007-2010 SUMMARY OF SUBMISSIONS
(8 service providers [80, 83, 84, 88, 212, 218, 277, 759], 3 other NGOs [86, 214, 278], 4
individuals [3, 22, 219, 766], 1 industry [85])
5.3.2 Support for 10:90 weighting ratio
11 submitters support the 10:90 weighting ratio for the following reasons:

It better targets the sectors in the gambling industry creating the most harm

It is the ratio agreed to by Cabinet

Any changes to the levy need to be supported by more research.
(2 service providers [215, 279], 3 individuals [7, 21, 765], 5 industry [213, 276, 284, 285A,
678], 1 TLA [10])
5.3.3 Alternative weighting ratio suggested
7 submitters rejected the proposed weightings in favour of an alternative.
Some submitters feel that a ratio did not accurately capture the harm caused beyond treating
the problem gamblers that present. Thus, the current ratio does not take into account the
impact of problem gambling on families and the wider community, and that the majority of
problem gamblers do not present.
(2 service providers [1, 82], 2 other NGOs [281, 763], 1 Individual [282], 1 industry [210], 1
academic [283])
5.3.4 Suggested ratios rejected
5 submitters rejected the proposed weightings with no alternative suggested. Some being of
the opinion that the Ministry had failed to properly research the proposed ratios, and the
consultation process needs to be repeated2.
(1 service provider [76], 3 other NGOs [9, 78, 87], 1 industry [280])
5.3.5 No preference
5 submitters note that they have no preference for either ratio. These submitters make a
number of comments including; there are merits for both weightings, or that there is a lack of
information around the ratios to form an opinion, or that they thought they lacked the
expertise to comment.
(2 individuals [17, 79], 2 TLAs [2, 19], 1 academic [14])
2
While two submitters supported the 20:80 weighting, they also noted a preference for other options, with one referring to a 30:70
weighting – [84, 85].
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PREVENTING AND MINIMISING GAMBLING HARM
2007-2010 SUMMARY OF SUBMISSIONS
5.3.6 No comment
12 submissions did not comment on the proposed ratios.
(1 service provider [77], 6 other NGOs [8, 15, 20, 216, 351], 1 individual [764], 1 industry [11],
1 TLAs [217], 1 academic [762], 2 core government departments [12, 13])
The following table summarises support for the ratios presented.
37
PREVENTING AND MINIMISING GAMBLING HARM
2007-2010 SUMMARY OF SUBMISSIONS
Table 3: Summary of ratio support
Submitter
categories
Support
20:80
Service
providers
80, 83, 84,
88, 212, 218,
277, 759
215, 279
1, 82
761
Other NGOs
86, 214, 278
-
281, 763
9, 78, 87
Individuals
3, 22, 219
7, 21, 765
282
Industry
85
213, 276,
284, 285A,
678
TLAs
-
Academics
Core
Government
Departments
Total
Support
10:90
Alternative
suggested
Reject both,
no
alternative
None
preferred
Total
77
14
-
8, 15, 20,
216, 351
13
-
17, 79
764
10
210
280
-
11
9
10
-
-
19, 2
217
4
-
-
283
-
14
762
3
-
-
-
-
-
12, 13
2
15
11
7
-
No comment
5
5
12
55
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PREVENTING AND MINIMISING GAMBLING HARM
2007-2010 SUMMARY OF SUBMISSIONS
6. Other Comments

Service providers should not promote anti-gambling messages if levy funding is
received.
(2 industry [85, 213], 1 meeting notes [7])
Concern over the omission of Treaty of Waitangi:
– Reiterates that within 2002 Draft National Plan for Minimising Gambling Harm, the
Treaty provided a clear framework for prevention and gambling harm
minimisation
– Omission of the Treaty reduces negotiating ability of Maori to ensure their concerns
are addressed as tangata whenua.
(2 service providers [80, 761], 1 other NGO [86], 2 meeting notes [2, 4])


Comment on principles of the strategy:
– Comments on the seven objectives of the strategic plan, particularly around word
usage and provides editing examples (e.g. ‘enhance’ in title of objective 3 should
have definition stating ‘human resources and funding will be available’)
– Funding required for objectives 4, 5 and 7 of strategic plan
– Little mention of achievement by NGOs of objective 3 in plan.
(1 service provider [215], 2 other NGOs [8, 214])

Consultation process is perceived as flawed:
– Industry members expressed dissatisfaction with lack of engagement by Ministry of
Health in developing consultation document
– Inappropriate for industry to have closed meeting when industry can attend public
meetings.
(1 other NGO [87], 1 individual [282], 1 academic [762], 2 meeting notes [3, 7])

Personal stories regarding gambling harm:
– One problem gambler gives an account of the great losses and hardships
experienced due to being addicted to pokies, (e.g. losing self-respect and inability
to maintain successful relationships with either family, friends or partners).
(1 individual [219])

No mention of DHBs and PHUs involvement throughout plan.
(1 service provider [279])

Lack of control over internet gambling.
(1 other NGO [8], 1 academic [14])

Maori representation on Gambling Commission, and hearings should be open to public.
(1 academic [762])

Environmental health issues regarding non-casino gaming machines.
(1 individual [79])

Funding to support a consumer group to contribute to Ministry of Health’s long-term
strategic plan.
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PREVENTING AND MINIMISING GAMBLING HARM
2007-2010 SUMMARY OF SUBMISSIONS
(1 service provider [218])

Ministry of Health DOC funding is increased by $100,000 to allow for an additional fulltime equivalent.
(1 industry [285A])
40
PREVENTING AND MINIMISING GAMBLING HARM
2007-2010 SUMMARY OF SUBMISSIONS
APPENDIX
1. Submission names and numbers
The following is the list of those who gave their permission to be identified in the summary of
submission report.
Table 4: Submission names and numbers
Submission Organisation
Name of submitter
number
1
Woodlands Trust
Dr Vicki Fowler & Mr Bernie Smulders
2
Palmerston North City
Aaron Phillips
Council
3
Barry Goodman
4
Brenda McQuillan
5
Visa Rose
6
Philip Townshend
8
National Council of
Lynda Sutherland
Women of NZ
9
Sisters of Compassion
Monty Arnott
10
11
12
Ruapehu District Council
The Lion Foundation
Ministry of Youth
Development
Department of Corrections
Abacus Counselling
Training & Supervision Ltd
Eugene Ferreira
Martin Cheer
Monique Leerschool
15
Wellington Community
Law Centre
Gary Forrester
16
South East & City Primary
Health Organisation
(SECPHO)
Justine Thorpe
18
Dunedin Budget Advisory
Service
Hamilton City Council
Wellington Central Baptist
Church
Shirley Woodrow
13
14
19
20
21
77
78
79
Te Kahui Hauora O Ngati
Koata Trust
Wesleycare
Sue Montgomery
Sean Sullivan
Sarah Ward
Rev Jenny McIntosh
Rev Dr Alan Jamieson
John Watson
Mathew McMillan
Tom White
Russell Phillips
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PREVENTING AND MINIMISING GAMBLING HARM
2007-2010 SUMMARY OF SUBMISSIONS
Table 4: Submission names and numbers
Submission Organisation
Name of submitter
number
80
Te Runanga O Kirikiriroa
Naina Watene
Trust Inc
81
Stephen McBride
82
Salvation Army, Oasis
David Winterbourn
Centre (Waikato)
83
Salvation Army, Oasis
Glenton Waugh
Centre (Wellington)
84
The Salvation Army,
Lynette Hutson
Addictions & Supportive
Accommodation Services
85
The Southern Trust
John Hockaday
86
Te Waka Hauora
Roera Komene
87
TAIA, Pacific People
Verna Winitana
Collective & Asian
Gambling Services
88
The Salvation Army,
Brent Diack
Oasis Centre
210
Charity Gaming Assn
Francis Wevers
211
Hamilton City Council
A J Marryatt
212
Problem Gambling
Mr John Wong
Foundation of New
Zealand
213
Hospitality Association
Bruce Robertson
214
New Zealand Federation
Mr Jarrod Rendle
of Family Budgeting
Services Inc.
215
National Pacific Gambling Pefi Kingi
Stakeholders’ Fono, Niu
Development
216
Youth Health Trust
Stephen Phillips
217
Local Government New
Basil Morrison
Zealand
218
Gambling Helpline (New
Krista Ferguson
Zealand)
276
NZ Lotteries Commission
Warren Salisbury
277
Health Sponsorship
Iain Potter
Council
278
South Island Shared
Faye Logan
Service Agency Ltd
279
Problem Gambling
John Stansfield
Foundation of New
Zealand
280
Clubs New Zealand Inc.
Jonathan Gee
281
Wellington People’s
Jocelyn O’Kane
Centre
282
Michael Laufiso
283
Gambling Research
Maria Bellringer
Centre, Faculty of Health
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PREVENTING AND MINIMISING GAMBLING HARM
2007-2010 SUMMARY OF SUBMISSIONS
Table 4: Submission names and numbers
Submission Organisation
Name of submitter
number
& Environmental Sciences
284
NZ Racing Board
Lynley Sinclair
285A
SkyCity Entertainment
David Kennedy
Group
312
Waitakere Assn Gambling Jacquelin Tuatara
Action
351
Waitakere Assn. For
John Hubscher
Gambling Action Group
678
Christchurch Casinos Ltd
Tim Bergin
759
The Salvation Army Oasis Dale Peach
Centre, Christchurch
761
Alcohol Drug Association
Char MacPherson
New Zealand
762
University of Auckland
Dr Lorna Dyall
Faculty of Medical &
Health Sciences
763
Chris Clarke
Manager, Newtown Union Health Service
764
Roddy Young and John Anderson
764A
765
766
John Anderson
Graham Foster
Roelien de Jong
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PREVENTING AND MINIMISING GAMBLING HARM
2007-2010 SUMMARY OF SUBMISSIONS
2. Editing
Detailed below are one-off editing comments raised by submitters.
General comments

Include 'that all non-casino gaming machines will be eliminated by 2010'

Include section that describes the effects of introducing each type of gambling pokies,
then casinos, lotto etc

Change 'gaming' to 'gambling' throughout plan

More detail needed for 'best practice' noted on page 4

Wording should be updated to reflect best practice model is an ongoing project.
Specific groups

Remove clustering of ethnic groups, e.g. Maori and Pacific peoples.
Workforce development

Requires reference for statement on page 4, paragraph 1, sentence 1

Seeks clarification on page 4, paragraph 1 on 'Workforce Development Forum’.
Social marketing

Seeks references and/or detail on the estimated effects of the social marketing
programme.
Conference support

Suggests wording should include 'event' in conference support section.
Intervention services

Requires cost/benefit analysis of different treatments to show transparency of value for
money

Include trend analysis of actual cost and actual demand of treatments over time

Add a diagram to show who the target groups are and what interventions are proposed
and in place

Clarify further on how brief and early interventions will work effectively within PHU and
NGO services.
Helpline

Wording should be modified in line with Helpline contract with the Ministry of Health,
i.e. ‘A national helpline service will continue to provide brief intervention and ongoing
motivational support via telephone and other technology/electronic means’. This
accommodates work the Helpline does over the internet as well as the phone

Wording should be updated to reflect that some areas have no easily accessible local
service, but all areas have access to a national gambling helpline
44
PREVENTING AND MINIMISING GAMBLING HARM

2007-2010 SUMMARY OF SUBMISSIONS
Wording of 'not do' should be removed from the ‘Helpline’ description in the Plan, or
include what every other service will not do.
Research

Explicit reference should be made to theoretical research to support the statement
'there should be decreased demand for intervention services as gambling behaviours
change'.
Needs Assessment

Requests that clarification be made on the ‘criminogenic needs assessment’ on page
45, (i.e. indicating what this figure means)3.
Levy

Need for more detail around data input used to calculate the levy.
Presentations

Change wording to reflect that the current services are meeting the need of 12% and
not meeting 88%.
Other comments

Requires reference for statement on page 2, paragraph 2 relating to 'smoking ban'

References / detail on estimated return to baseline levels in three/four years

Document should highlight no major regulatory changes that may impact on
availability/types of gambling

Change 'should' to 'could' as work of Professor Abbott not proven.
(4 service providers [77, 88, 218, 279], 4 other NGOs [9, 78, 86, 278], 2 individuals [3, 282],
3 industry [213, 280, 284], 1 TLA [2], 1 core government department [13])
3
Criminogenic needs assessment index only identifies risk factors that are directly related to the offending for which the person is in
prison. Only 2-3% of prisoners meet this specific criteria based on their gambling behaviour in the 24 hours prior to offending.
However, 10% meet the criteria when taking into account their gambling behaviour over a 6 month period prior to offending.
45