Abstract
T
Approximately a decade later, few operators, policymakers, or regulators have adopted this infrastructure recommendation. In practice, operators and policymakers have relied on research data that reports tentative, inconsistent, or inconclusive findings, expressed opinions, or reflects methodological flaws. 3 In addition, stakeholders often use studies that lack external validity because these employ analogue samples (e.g., first-year university studies, media-recruited volunteers), occur within laboratory settings, and use simulated gambling experimental tasks that do not involve the use of participants' money (e.g., simulated gambling tasks for credit points or minimal amounts of money provided by the researcher).
Consequently, the purpose of this article is to clarify and build upon the fundamental scientific principles, concepts, and values of the Reno model by providing guidelines to the values and practices associated with evaluating responsible gambling (RG) programs. More specifically, the present article has two primary aims:
1. Highlight the importance of critically assessing the empirical evidence on which operators, policymakers, and regulators propose and implement RG programs; and 2. Highlight and increase awareness and understanding of the requirement to monitor and empirically evaluate RG programs with the aim of continually improving effectiveness.
Despite the volume of published research focusing on responsible gambling initiatives, recent comprehensive literature reviews have concluded that the majority of programs 4 do not have strong evidence-based data supporting their effectiveness. 5 One implication of such a conclusion is that, in the absence of empirical evidence, gambling operators, public policymakers, and regulators have responded to public pressures to implement responsible gambling programs. To do so, they remained reliant on the available scientific data, the validity of which often rested on face-validity, opinion, and/or partial or inconclusive research findings. The adage, “something has to be done, this is something, therefore this has to be done,” is perhaps most appropriately applied to this situation. However, as convincingly argued a few decades ago by Howard J. Shaffer, “… when something seems so obvious that it goes without question, it is probably not that obvious!” 6 is still an actuality in the field of responsible gambling. Common sense and conventional wisdom is often incorrect. There is an urgent need for guidelines that can facilitate the active participation of gambling operators, policymakers, and regulators in contributing to the development of evidence-based responsible gambling programs that are optimally effective in achieving their intended objectives.
There are multiple cost-benefit arguments supporting the need to inform operators, policymakers, and regulators about the importance of evaluating the strength of research data when framing policy and implementing responsible gambling programs. The fundamental consideration is that the primary aim of responsible gambling programs is to encourage individuals to restrict expenditures to personally affordable limits, and consequently, reduce gambling-related harms. When stakeholders rely on opinions, methodologically inadequate research findings, and non-empirical sources to formulate policies, the result is often well-meaning but misguided initiatives that compromise the intended success of such programs. Gambling operators, policymakers, and regulators need to consider the following issues when developing responsible gambling programs:
• The per gambler costs associated with responsible gambling strategies need to be taken into account. For example, a costly intervention that only assists a small number of individuals (i.e., low impact) does not represent a satisfactory allocation of resources. In this regard, we cannot justify mandatory pre-commitment and technical adjustments to player information displays because these costly strategies evidence minimal effectiveness. More importantly, these strategies hold potential to create iatrogenic effects that can counterproductively increase gambling expenditure. • There is a need to constantly re-evaluate and improve responsible gambling programs as a result of ongoing outcome data monitoring. This is necessary to avoid the potential pitfalls of assuming that current programs are effective, resulting in the stagnation of improvement and, even worse, inadvertently encouraging harms. • There is a need for industry and governments to remain accountable for, and to demonstrate to the public, the cost-benefit outcomes achieved by the allocation of resources intended to support responsible gambling policies. For example, the Reno model encourages operators and public policymakers to allocate health service funds guided by accurate and valid empirical data. Given that less than a fifth of those meeting diagnostic criteria seek treatment at any one point in time,
7
using prevalence data to determine treatment services funding will result in overestimates of costs and an inequitable distribution of funds.
Operators, policymakers, and regulators face the difficult task of interpreting the plethora of conflicting and inconclusive research data when they attempt to formulate sound policies based on scientific evidence. Industry and governments are ideally suited to develop and enhance responsible gambling programs, given the large data sets at their disposal.
Clarifying Responsible Gambling Objectives: Considering Multiple Perspectives
Stakeholders have defined “responsible gambling” in various ways according to the perspective(s) of differing agencies and individuals. To achieve a common foundation, we encourage all stakeholders to retain the pivotal definition underpinning all responsible gambling policies and strategies: that is, initiatives that are designed to limit gambling expenditures to personally affordable levels. Achieving this objective invariably will result in the prevention and/or reduction of gambling-related harms in the community. To implement a framework that will limit harms, gambling operators and policymakers need to work collaboratively to ensure a safe gambling environment. Nonetheless, gambling requires some level of regulation because it has the potential to adversely influence the health and welfare of a proportion of the community.
We must recognize that there are inherent limitations and difficulties confronting those invested with the task of promoting responsible gambling practices. For example, the online environment represents a technology that exposes individuals to both regulated and unregulated sites. Although policymakers can introduce regulatory requirements and restrictions for legally sanctioned sites, they have no authority or jurisdiction to impose responsible gambling strategies on illicit sites. In addition, legal sites in one jurisdiction can offer services across international borders without necessarily meeting regulatory requirements in other jurisdictions. This circumstance highlights the need for collaboration and information sharing between legitimate operators and policymakers in order to foster adequate consumer protection, as well as to prevent transmigration to illicit offshore sites, thereby increasing the risks of negative impacts.
Finally, there are important challenges to achieving a balance across competing interests that exist among stakeholders: consumer protection (e.g., reducing harms: responsibility of all stakeholders); maintaining tax revenue (e.g., governments); compliance with regulatory requirements (e.g., regulators; integrity of gambling activities); and commercial interests of industry (e.g., profit motive: industry). It must be recognized that at times, these competing demands may be in conflict; for example, reducing gambling consumption but maintaining profits and taxation revenue streams. This means that consideration must be given to determining and collaboratively negotiating the hierarchical importance of policies in an open and transparent manner between respective parties.
In essence, gambling operators, policymakers, and regulators share a common goal: reducing gambling-related problems within the community. To achieve this goal, all stakeholders must work to reduce the incidence of problem gambling (i.e., the number of new cases emerging within a defined timeframe), and ultimately, its point-prevalence (i.e., the number of identified cases during a given time period).
There are a number responsible gambling initiatives directed towards reducing the incidence of gambling disorders and gambling-related harms. These efforts often focus on educational campaigns and provide resources to inform individuals about the nature and risks associated with gambling. Illustrative examples include, but are not limited to, those that target members of the general population or specific groups considered at higher risk (e.g., children and gambling industry employees). These are measures that seek to prevent individuals from developing problems in the first instance, or to intervene to abort the progression to increasing levels of severity (i.e., primary and secondary prevention).
Some tertiary and secondary prevention initiatives targeting responsible gambling aim to reduce the prevalence of gambling-related harms, targeting individuals already experiencing gambling-related problems. Among them, we find initiatives such as self-exclusion, helpline numbers, treatment provider referrals, and warning signs to identify problem gambling and gamblers. Some initiatives target both a reduction in incidence and prevalence rates; for example, some programs use pre-commitment as a tool to limit expenditure among both recreational and problem gamblers.
A Basic Guide for Examining the Quality of Evidence
In this section, we provide a basic guide to six key elements that operators, policymakers, and regulators need to critically evaluate before adopting any proposed activities for their responsible gambling programs. We offer a systematic approach to assist stakeholders when they attempt to determine the quality and robustness of evidence upon which responsible gambling programs are founded.
The following list contains the six primary dimensions for evaluating evidence. Each needs consideration when making decisions about whether to integrate a specific initiative within an overall responsible gambling program. For each evidentiary dimension, we will outline the main features that stakeholders should critically assess when evaluating a proposed initiative:
1. Goals and objectives: Stakeholders must clearly operationalize the goals and objectives of an initiative. That is, we must describe and specify the intended outcomes in sufficient detail that we objectively can observe, measure, and quantify them. 2. Measurement: Stakeholders need to include a measure of outcome in any initiative. Such measures should be relevant, specific, and have the capacity to adequately assess whether the intended outcomes have been met totally, or at least to some degree. For example, with self-exclusion, stakeholders should measure success by using multiple indicators (e.g., number of enrollments, detected breaches, and reduction in overall gambling activities and severity). However, these measures would not be relevant in some jurisdictions—for example, Macao and Las Vegas, where the majority of patrons are infrequent tourists/visitors. In such gambling destinations, breaches and detection rates might not provide pertinent or relevant measures of effectiveness. Accordingly, different measures for determining the effectiveness of an initiative should be used for transient tourists/visitors to gambling destinations, where problems are dealt with in other locations, as compared to local residents, where the measurement of breaches and reduction in gambling involvement are dealt within their community. 3. Research design: To evaluate an initiative's potential effectiveness, program planners need to include two or more points of comparison. This is a sine qua non requirement. Any initiative, therefore, must use measurements applied to at least two points in time either within one subpopulation (e.g., prior to and post the introduction of an initiative), or a comparison between two or more subpopulations (e.g., control and comparison samples). Any study proposing or using only one point of measurement fails to provide any useful evidence with which we can determine an initiative's effectiveness. 4. Sample adequacy: Stakeholders need to consider assessing the size and nature of the sample. The primary factors include a) an adequate number of enrolled participants; b) a sample representative of the population from which the sample is drawn so that we can generalize the findings to the community from which the sample was drawn; c) a response rate of at least 70%; and d) a low dropout or high retention rate for prospective studies. 5. Sample characteristics: Participants that represent the initiative's primary target population should comprise the sample. To evaluate this, basic information describing demographics (e.g., gender, age, gambling history and status, socio-demographic variables) should be identified. For example, in a school-based educational campaign, a sample comprised of predominantly very young females who participate in non-commercial forms of gambling might not provide any meaningful information about subsequent adolescent commercial gambling behaviors and outcomes. 6. Study integrity: Integrity means that a study is or has been administered and implemented in accordance with the stated protocol. Stakeholders should not assume that a study will be or has been conducted as initially planned; multiple factors often emerge during research that influence some deviation/modification from the original protocol. Therefore, it is important that studies embed regular fidelity checks to monitor study procedures to guarantee that the procedure is being applied as planned. For example, during a staff training initiative, there should be evidence that all modules of the manual have been delivered as intended. If changes in module delivery or content modification occur during the training, it is likely that the investigators' interpretation of results will be compromised and the conclusions reached flawed.
Who Should Conduct Evaluation and Monitoring?
Gambling operators, policymakers, and regulators can evaluate the evidence base supporting an initiative; in addition, they should proactively monitor and assess outcomes to a certain degree. However, we recognize that there are circumstances that require stakeholders to engage external experts to conduct evaluative studies. In the following discussion, we will suggest respective roles and boundaries for operators, policymakers, regulators, and external experts, and criteria for guiding fruitful collaboration among all.
The role and function of policymakers is to set the regulatory requirements that aim to reduce the incidence and prevalence of gambling-related harms. The decision to introduce specific responsible gambling initiatives should rest on strong evidence supporting their effectiveness. Policymakers, therefore, should maintain reliance on valid and reliable data becoming available. Given that policymakers also are often the agency funding research, we encourage them to provide long-term prospective funding for studies that have the capacity to provide more meaningful data, compared to ad hoc or funding-fragmented research proposals.
Regulators ensure operator compliance with regulatory requirements. This entails constant auditing as to whether an operator is complying with requirements, and monitoring the integrity of how an initiative is delivered and outcomes recorded. For example, an initiative cannot be evaluated properly when an operator complies with the legislated requirement to offer self-exclusion but fails to actively promote its availability, maintain records, and/or implement procedures for detection of breaches.
When offering products that hold potential to contribute to the development of harms, operators have a strong obligation to establish an atmosphere of corporate social responsibility and to evaluate initiatives that have been implemented. It is insufficient to establish a code of conduct for responsible gambling if aspects of that code are not exposed to quality assurance and evaluation. Operators should ensure that evaluation of their responsible gambling program is well integrated in their core business. Absent these commitments, it is not possible to maintain responsible gambling programs and a responsible gambling industry. Stakeholders have the capacity to evaluate the effectiveness of responsible gambling initiatives across their various activities (e.g., marketing, product development, and customer profiles).
There are a number of fundamental steps necessary to collecting data; operators have the capacity to manage these activities and provide the organizational support necessary to engage in these activities. At the outset, the issue is not necessarily the question of introducing an initiative, but rather, what are the specific goals to be achieved: what are the valid outcome measures that can be administered that will inform an initiative's effectiveness? That is to say, an initiative should have face-validity (“looks like it can limit gambling-related harms”), manage corporate social appearance (“enhance image of doing something”), and actually meet the intended program goals and objectives (i.e., effectiveness and impact). To demonstrate the effectiveness of an initiative, operators and regulators should establish collaborative relationships that guarantee that an initiative is being offered and monitored as intended. Both groups should act to provide empirical evidence of the integrity and fidelity of that initiative.
Operators currently compile substantial data about player characteristics, expenditures, and patterns of gambling activity. Such data provides a rich set of information that can assist with identifying effective initiatives that apply to both gambling products and individuals. Operators and regulators must balance the commercial sensitivity of data against the importance of analyzing the data and disseminating the findings. This delicate balance encourages operators to collaborate with researchers and others by sharing de-identified data, or allowing access to player profiles and, with player consent, linking player profiles to objective data.
Although operators do conduct internal assessments of player characteristics and behavior for commercial purposes, and to some extent for responsible gambling initiatives, there are some evaluative procedures that require special expertise, resources, and independence. External experts have the capacity to advise on and develop research designs and methodologies that would allow outcomes to be accurately and validly assessed. As we mentioned before, robust research methodologies are the sine qua non condition to provide information about the successful outcome of any initiative.
When operators need to collaborate with external researchers, they can face some challenges when seeking independent evaluators and determining their expertise. The basic essential qualities that operators need to consider when establishing collaborative evaluation ventures is threefold: 1) the competence of the researcher, as evidenced by peer-reviewed publications; 2) credibility as an unbiased and objective researcher—that is, holding neither pro- nor anti-gambling attitudes and ideological stances; and 3) the ability to respect and maintain the confidentiality of commercially sensitive data. In addition to the need for institutional review board approval when research involves human participants, operators also need to be cognizant of the environment within which researchers operate. Universities require researchers to submit funding contracts to their legal branch to ensure that the conditions of the research agreement are consistent with university dictates. These agreements refer to data ownership and intellectual property, as well as the capacity to report and publish findings in the public domain, typically through peer-reviewed journals, reports, and conference proceedings. These conditions need to be negotiated in advance of any project.
Conclusions
Rigorous empirical evaluation of responsible gambling initiatives is a central tenant of the Reno model; this cornerstone principle places stakeholders in a position where they can defend their efforts at consumer protection on the basis of scientific evidence. Operators and responsible gambling program stakeholders alike must assure the safety of their interventions and that these programs are accomplishing clearly stated objectives. The advantage of operators acting proactively to evaluate responsible gambling initiatives is that it reinforces their commitment to corporate social responsibility; proactive evaluation also limits constantly being defensive and reactive to the findings of other researchers. In the absence of proactive evaluation, other researchers can publish negative results, causing stakeholders to be on the defensive/reactive to findings. In addition, rigorous evaluation programs deflect unfounded or misguided criticisms based on opinion or moral grounds instead of evidence. Thus, the ultimate goal of responsible gambling evaluation is to benefit gamblers through the application of best practices and standards of care. Responsible gambling evaluation establishes and affirms an atmosphere of corporate social responsibility that assures a safe environment, sustaining gambling as a recreational activity while preventing the potential adverse consequences that can be associated with gambling and attempts to limit gambling.
Footnotes
Acknowledgments
The authors jointly accept responsibility for the content of this article. None of these supporters or any of the authors has personal interests in bwin.party, La Loterie Romande, ClubNSW, or the National Lottery that would suggest a conflict of interest.
During the preparation of this article, Howard Shaffer received reimbursement from Laval University for travel expenses, but no honorarium. In addition, the Division on Addiction at the Cambridge Health Alliance has received funding support from a variety of sources, including the following: bwin.party Interactive Entertainment, AG; the Foundation for Advancing Alcohol Responsibility (FAAR); National Institutes of Health (i.e., NIDA, NIAAA, NIMH); Substance Abuse and Mental Health Services Administration (SAMHSA); the National Center for Responsible Gambling (NCRG); Massachusetts Council on Compulsive Gambling; the Massachusetts Gaming Commission; and the University of Nevada, Las Vegas. Dr. Shaffer has received funding for consultation from Las Vegas Sands Corp., Davies Ward Phillips & Vineberg, LLP, and the DUNES of Easthampton.
During the preparation of this article, Robert Ladouceur received funding support for the International Group on Responsible Gambling from La Loterie Romande (Switzerland), ClubNSW (Australia), Camelot (United Kingdom), La Française des Jeux (France), Loto-Québec (Québec, Canada), and the National Lottery (Belgium). In addition, the Ontario Problem Gambling Research Center and Fonds Québécois Recherche sur la Société et Culture (Quebec) provided funding to Dr. Ladouceur for this project.
During the preparation of this article, Alex Blaszczynski obtained reimbursement from the project funders for expenses; he did not receive any honorarium for this work. Dr. Blaszczynski has had financial professional dealings with the gambling industry and various state and federal governments both directly and indirectly over the last three years, including research funding, personal fees for professional consultancy, honoraria for grant reviews and theses examination, royalties for published books, and research funding and expenses covered to attend and present at conference and government meetings from the following gambling industry operators, including: La Loterie Romande (Switzerland), Svenska Spel (Sweden), Club NSW (Australia), Camelot (United Kingdom), La Française des Jeux (France), Loto-Québec (Québec, Canada), Casino Austria, National Lottery (Belgium), Sportsbet, British Columbia Lottery Corporation, and Aristocrat Leisure Industries. He also has had financial dealings with organizations that are funded directly or indirectly from the gambling industry or by levies on the gambling industry, including the Victorian Responsible Gambling Foundation, Ontario Problem Gambling Research Centre, the Responsible Gambling Trust, Manitoba Gambling Research Program, Ministerial Expert Advisory Group (federal government), and has received honoraria and expense reimbursement from government-funded problem gambling counseling services for conducting training programs and workshops. Government-funded agencies include the NSW Office of Liquor, Gaming, and Racing, Australian Institute of Family Studies, Gambling Research Australia, Australian Department Social Services, and non-industry or government agencies, including the National Association for Gambling Studies, National Council on Problem Gambling, and Le Comité d'organisation Congrès International sur les troubles addictifs.
During the preparation of this article, Paige Shaffer obtained reimbursement from the Laval University; she did not receive any honorarium for this work.