Submissions

To: Ministry of Health
Date: October 2024

Purpose

This submission’s primary purpose is to advocate for the recognition of disabled people as an identified population group at high risk of experiencing gambling harm. DPA aims to ensure the strategy is responsive to the unique challenges faced by disabled individuals, particularly given their disproportionately low incomes and other socio-economic factors that increase vulnerability to problem gambling. DPA also provides recommendations on service tailoring, workforce development, and targeted research.

Summary of DPA submission

DPA highlights that this issue is pertinent for the disability community, as disabled people are disproportionately low-income earners and live in poverty, with 54% of beneficiaries having a disability or health condition. Disabled people in paid employment also earn considerably less than non-disabled people. These factors contribute to an increased risk that some disabled people will gamble disproportionately high amounts of their income. Research indicates that disabled and D/deaf people are more likely to be problem gamblers, with those having learning/intellectual disabilities, cognitive impairments, and acquired brain injuries at higher risk due to issues with budgeting, spending, and impulse control.
 
Despite this, DPA notes there has been minimal recognition of the need for disabled people to be seen as an identified group experiencing inequitable outcomes and gambling harm within the current and draft strategies. DPA agrees with the proposed strategic goal for New Zealanders' quality of life not to be affected by gambling harm, and with the strategic outcomes focusing on a full spectrum of services, social/cultural norms, leadership, and systemic focus on at-risk groups. DPA supports the proposed systemic priorities of increasing access to support, growing the workforce, strengthening prevention, and improving effectiveness. DPA is pleased with the proposed 16% funding increase for frontline services and the use of the Problem Gambling Levy as a revenue stream.
 
Key Recommendation:

DPA recommends that the Ministry of Health add disabled people as an identified population group who disproportionately experience gambling harm.
 
Supporting Statement 1:

Disabled people are disproportionately low-income earners and live in poverty, contributing to an increased risk that some will gamble disproportionately high amounts of their income.
 
Supporting Statement 2:

Australian and American studies indicate that people with learning/intellectual disabilities, cognitive impairments, and acquired brain injuries are at higher risk of becoming problem gamblers due to factors such as problems with budgeting, spending, and impaired impulse control.