Gaming consultant Regulus Partners published a critique of the OHID’s work, examining a series of methodological errors within the original published paper.
Many of the problem’s identified by the paper’s author Dan Waugh related to the speculative nature of the estimates, the failure to consider any benefits from engaging in gambling activity and the motives to publishing the report at all.
“The most important question to be asked about this report, however, is why it – or the 2021 report by the OHID’s predecessor, Public Health England (PHE) – were undertaken in the first place,” Waugh said.
Waugh characterised the purpose of the OHID report’s publication as being to promote “advocacy and action”, not provide methodologically sound research into the effects of gambling-related harms.
According to Waugh, while the report estimates that the annual economic burden of harmful gambling in England is either £1bn or £1.8bn, the bases for calculation of each cost component is “highly speculative” as well as being undermined by factual errors, mathematical mistakes, opaque calculations and questionable methods.
Waugh also emphasised that the costs identified cannot be put with “any degree of confidence” to either gambling or harmful gambling, and that the majority of costs, are not costs to the state but “intangible costs to ‘society’.”
“In short, the OHID and PHE reports provide an array of unreliable estimates of costs of unknown origin, to – in most cases – unknown entities,” said Waugh. “The policy relevance of such calculations ought therefore be of limited value; something that has been recognised by the Gambling Commission.”
Waugh stipulated that the Gambling Commission has suggested in its previous remarks that PHE has published costs estimates of questionable accuracy “in in order to support a predetermined agenda”.
The OHID report came under particular fire for its failure to disclose previous mistakes by PHE relayed to “erroneous calculations” of suicide mortality. Waugh argued that both the OHID and PHE went to some lengths to prevent examination of PHE’s claims as they were “methodologically and mathematically inaccurate”.
“It is in the interests of sound public policy that Government research is subjected to scrutiny, particularly where it has a bearing on the health, wellbeing and freedom of citizens,” said Waugh.
“Both the OHID and PHE reports have been cited uncritically by the Department for Culture, Media and Sport in policy debates; and referred to by one government minister as “an important input” to the forthcoming white paper on gambling market reform.
“The Gambling Commission meanwhile, has adopted a policy of not commenting on research produced by government departments, even when its own internal analysis has revealed the research to be misleading.”