A report published earlier this year by the UK’s Office of Health Improvement and Disparities (OHID), which estimated the societal cost of the country’s gambling industry, has been somewhat savaged by Regulus Partners.
In its critique, strategic advisory Regulus has come to some scathing conclusion of the public health body’s review of British gambling and its impact and society, in particular highlighting what it believes is an unsound methodology and biases among its authors.
Though the National Lottery is the largest lottery operator in the UK, the country is home to other lottery providers such as The Health Lottery and Postcode Lottery, and many retail bookmakers offer their own versions, such as the popular Irish Lotto product.
As a segment of the wider UK gambling sector, lotteries could be impacted by the judgements of the upcoming Gambling Act review White Paper, and any potential influence the OHID study may have had on the legislative overhaul.
No method to the methodology
According to Regulus, the OHID report – an update on a study by its predecessor, Public Health England (PHE) – contained several ‘clear and obvious’ errors throughout its methodology, particularly concerning statistics around homelessness and the extent of problem gambling.
The firm was also unimpressed with the OHID’s application of the term ‘harmful gambling’ to anyone with a Problem Gambling Severity Index (PGSI) of one or more.
This means that low risk gamblers, moderate gamblers and problem gamblers, as defined by the PGSI itself, are considered to be suffering from ‘harmful gambling’.
However, one of the most widely reported conclusions of the OHID report, which gained significant traction both in the UK and internationally, was its assessment of gambling-related suicide.
The report estimated that there are between 117 and 496 suicides per year due to gambling, amounting to a financial cost of between £241.1m to £961.7m.
Central to this belief was the OHID use of a Swedish study, which examined the records of 2,099 patients classed as ‘pathological gamblers’ receiving hospital treatment between 2005 and 2016.
Regulus’ lambasted the application of the Swedish study to English gamblers as one of several ‘unscientific assumptions’ made by the report.
Another major ‘assumption’ flagged by Regulus is that the PGSI definition of ‘problem gamblers’ was equated by the OHID to the Diagnostic and Statistical Manual of Mental Disorders, Fourth Edition (DSM-IV) definition of ‘pathological gamblers’.
As a result of this association, the OHID based its highest estimation of suicide on the assumption that Swedish patients with a recognised psychiatric disorder are at the same risk of suicide as English PGSI-defined problem gamblers who do not have such a disorder but do suffer from gambling harm.
“The logical implication of the OHID approach is therefore, that severity of both gambling problems and psychiatric disorder has no bearing on suicide risk, Regulus asserted.
“While analogies are imprecise, this is conceptually similar to assuming that people who are overweight have the same health risks as people who are clinically obese.”
It was however noted that the lower estimation made by the PHE/OHID was based on sounder rationale using the Swedish survey – due to the 117 figure is based on the application of Swedish mortality ratios to those in England who have been diagnosed as having a pathological gambling disorder.
However, Regulus maintained that both high and low estimates are ‘unreliable’ for several reasons, the first of which being that people receiving hospital treatment for Gambling Disorder are not representative of all people with a gambling disorder.
On this note, Regulus added that people seeking treatment for gambling disorders will typically have more severe cases that cannot be applied across the full demographic of bettors, and that those currently in treatment may not be representative of all those actively seeking treatment.
One of the key conclusions of the OHID report, it could be argued its most defining and highly publicised conclusion, was that British society has incurred a cost of around £1bn to £1.8bn as a result of negative betting and gaming outcomes.
This figure includes the cost of treatment and rehabilitation of problem gamblers, costs of crime, and deaths associated with gambling-related harm, the latter of which chiefly concerned suicides.
Regulus siding with the regulator
Regulus asserted in its critique that the UK Gambling Commission’s (UKGC) assessment of the aforementioned PHE report could be easily applied to the OHID version.
The UKGC commented at the time: “Given the (mostly acknowledged) limitations, it’s surprising that the £1.27bn cost of the gambling industry has been promoted by PHE as one of the main findings from the entire review.
“This may be due to its status as being one of the few conclusions that is ‘new’, a desire to emphasise the need for further research to strengthen the evidence base or intending to ensure gambling is considered as a public health issue.”
In Regulus’ view, the financial conclusions of the report are not based on sound evidence and methodology, and in some cases have omitted findings from other bodies, which cast the industry in a better light.
For example, the OHID argument that gambling costs the UK £508m a year via gambling-associated depression was taken apart by Regulus, which asserted that a causal relationship between betting and depression cannot be determined, due to the mental health issue having ‘multi-directional’ drivers.
Additionally, the report was criticised for failing to consider or mention NHS Health Survey studies, which found that ‘non-problem gamblers’ (who make up ‘around 90% of people who gamble’) are less likely than the general population to suffer depression.
As well as underpinning its conclusions and evidence on some assumptions and errors, however, Regulus has also accused OHID and its PHE predecessor – as having conducted the reviews with an underlying bias against the industry.
For example, the group pointed to examples of the PHE having called for gambling to be recognised as a ‘public health issue’ in the past. Of distinction, Marguerite Regan, Project Leader for both the PHE and OHID reviews, has previously stated that there is a need for ‘a compelling narrative’ to ‘ support advocacy and action” on gambling.
Regulus ascertained: “We have identified a number of instances where those involved with the project appear to reveal the presence of underlying agendas and predetermined views on the desirability of gambling as a legitimate pastime for adults.
“It seems reasonable to assume that the presence of such a priori views served to colour the analysis undertaken by both sets of research teams.”
The firm expressed that this could lead one to agree with the UKGC’s remark that the report was conducted “to ensure gambling is considered a public health issue”, and not to provide sound evidence to influence policy decisions.
UK gambling has been standing at a crossroads for the past two years since the Gambling Act review began in December 2020, and the direction which it will take is speculated to be revealed this week.
After 28 months in the pipeline, having been overseen by three Prime Ministers, four DCMS Secretaries and five Parliamentary Under-Secretaries, speculation suggests that the White Paper will be published this week, when the extent of the OHID’s influence will become clear.
