NZCT's submission to the Ministry of Health on its gambling harm minimisation strategy

NZCT's submission to the Ministry of Health on its gambling harm minimisation strategy

NZCT has made a submission to the Ministry of Health on its proposed Strategy to Prevent and Minimise Gambling Harm 2019/20 to 2021/22 and the problem gambling levy rates for the next three years.

NZCT's position is as follows.

  • We support the prioritisation of research into online gambling and new technology, such as facial recognition.

  • We consider practical and affordable technologies that help venues prevent and minimise gambling harm should be the highest priority for Ministry investment.

  • We consider there can be better value for money in the Ministry's current spending. More should be spent on realistic and practical solutions, and less on research that tells us nothing new and advocacy from service providers that undermines the sector.

  • We also would like to see greater accountability and transparency in the $18.Sm annual levy spending.

  • We consider the funding appropriation of $55.339m is not appropriate given that the $Sm underspend from the current levy period is being retained. We want to see this underspend returned to the levy payers, as guidelines suggest.

  • We do not support the proposals to establish a consumer network, new counselling offices in small towns and a residential care service. None of these are likely to help enough problem gamblers to justify their cost. The $3.5m proposed to be allocated to developing these services would be much better spent funding facial recognition software licensing, support fees and hardware for high-risk, high-turnover venues.

  • We strongly recommend the 30/70 weighting for levy payments. This option provides the greatest weight to expenditure, which is a robust, objective measure based on accurate data from all forms of gambling, unlike presentations which are highly subjective and represent only a small sub-section of gamblers.

  • The 30/70 weighting provides the most appropriate apportionment, which reflects the 5.7% increase in expenditure that has occurred on Lotto products and the 7.1% decrease in expenditure on pub gaming machines since 2009/10.

  • There are two major barriers to moving class 4 venues out of lower socioeconomic areas: council gambling venue policies and the Department of Internal Affairs' refusal to apply the principles of the Waikiwi Tavern decision to other potential relocations.

  • We have concerns about Sapere's Gambling Harm Reduction Needs Assessment that has informed the proposed strategy, particularly the suggestion to move away from using the internationally adopted and proven Problem Gambling Severity Index (PGSI) to the Short Gambling Harm Screen (SGHS) or the Disability-Adjusted Life Year measure.

> Read our full submission (PDF, 1.2 MB)