Avoiding and Evading Exclusion Orders

The British Columbia report we lately have been drawing upon (71-page pdf here) indicates that most people who chose to self-exclude from BC casinos nevertheless continued to gamble, and on a somewhat regular (though not daily) basis, during their exclusion. Most of those who gambled during their exclusion did so at casinos, too, although some stuck to lottery games or keno. Many casino visits were made outside of BC, so these trips avoided but did not evade exclusion orders. Most self-exclusion clients did not evade their commitment. Nonetheless, most casino gambling that did take place during exclusion apparently occurred in BC casinos, in violation of exclusion agreements.

The self-exclusion clients generally -- and correctly -- believed that they could sneak back into BC casinos, even if most did not try. Further, those who were caught trying to gamble at a BC casino were escorted out, but generally no further sanction was applied; for the most part, even wins were paid out to excluded gamblers. Attempts to evade exclusion orders were highly skewed, with about ten percent of excluded gamblers persistently (at least weekly) trying to enter BC casinos, and much time of casino security personnel was devoted to trying to track these persistent violators. The BC report, not surprisingly, calls for improved detection and more sanctions for breaking an exclusion order. The additional sanctions should be of the helping, not the punishing variety, in keeping with the "behavioral triage" approach.

Effectiveness of Self-Exclusion in British Columbia

The report (71-page pdf here) noted in the previous post utilized focus groups consisting of providers of self-exclusion, as well as telephone interviews of self-excluded clients. About one-third of the participants completely abstained from gambling during their exclusion (which lasted, at their discretion, either six months, or one, two, or three years). The methodology does not provide, it seems, a clean comparison between the extent of gambling problems pre- and post-exclusion, but the data that are provided suggest that those who continued to gamble, by and large, gambled less frequently, and still found that the self-exclusion program was helpful. (After the exclusion period was over, very few clients remained abstinent from gambling; again, however, the extent of their gambling seemed to be lower than before the exclusion.) The clients were asked if they were satisfied with the self-exclusion program, and more than 80% reported satisfaction; an even higher percentage indicated that they would recommend the program to others.

Less-than-Voluntary Exclusion

The Self-Exclusion blog has made a point of detailing exclusion orders, particularly in Singapore, that are not fully voluntary. A recent report (71-page pdf here) on self exclusion from casinos in British Columbia notes (page 14) that people who administer the program do not see all participants as being uncoerced: "...not all clients signed up completely voluntarily as some were pressured by family or friends, while others signed up because they needed to show someone else (e.g. the bank, a judge) that they were doing something to address their gambling problem." The coerced excluders also were viewed as being the most likely to try to violate their exclusion order.

The April, 2011 report with this information was prepared for the British Columbia Lottery Corporation by the BC Centre for Social Responsibility. The report provides both a fine review of previous work on gambling self-exclusion and a new longitudinal analysis on the British Columbia program; I hope to draw on this source for some more posts soon.

Committing to Getting Out of Bed

While gambling self-exclusion programs are aimed at preventing an undesired behavior, some commitments are aimed at motivating a desired behavior. (There's a bit of arbitrariness here, of course, as committing to doing something is like committing to not doing any of the alternatives.) My suspicion is that it might be easier to honor a commitment not to do one well-specified thing -- don't go to a casino -- than it is to commit to doing something -- say, working more -- because there are many alternatives to working. There's only one way to violate the no gambling pledge, but many ways not to work. But the alternative to getting out of bed is pretty much just staying in bed, so a positive commitment to getting out of bed might work pretty well. Indeed, I keep my alarm clock away from my bed to provide a small commitment to achieving verticality in the morning.

That scheme might not be enough, however. Do not despair, as technology has progressed to the point where you can raise the stakes of not getting up. The SnūzNLūz alarm clock allows you to precommit to making a donation to a cause you loathe -- an anti-charity -- every time you hit the snooze button on the alarm clock. SnūzNLūz users will either be prompt at getting out of bed, or the revenues of various presidential libraries will soar.

Foreign Workers in Singapore Flock to Self-Exclude

The Self-Exclusion blog speculated that foreign workers in Singapore might feel a bit of pressure from their employers to self-exclude from the Singapore casinos, and this is one prediction that seems to have been borne out: "many Singaporer companies are refusing to renew their foreign employees work permits unless they agree to give the casinos a wide berth."

The excluded list is not public, so how do employers know that their employees have self-excluded? The employer-assisted procedure involves an application form that is filled out in part by the employer, and in part by the employee, and signed by both parties. The completed form is submitted by the employer, however. Employers, therefore, can monitor whether their employees fill out and sign their portion of the form.

Singapore's National Council on Problem Gambling goes to great lengths to stress that these employer-facilitated exclusions must be voluntary on the part of the employee. But just how voluntary are they if an employee who won't agree to self-exclude will not get to keep his or her job? Here's the claimed purpose of the program:

The Consolidated Foreigner Form is to facilitate/assist employers to help their foreign workers apply for self-exclusion from the casinos. This is because many foreign workers, especially Work Permit holders, may not be proficient in English or our other official languages. They may not be aware that they can opt to exclude themselves from the casinos or understand how to apply for exclusion orders. Therefore, we are providing this option for employers to facilitate/assist their foreign workers to apply for self-exclusion.

The amazing popularity of the program with foreign workers suggests that in practice, the employer-facilitated process is more about employer coercion than about empowering foreign employees to satisfy their latent desires to self-exclude.

The same article linked above gives the overall exclusion numbers in Singapore, circa July, 2011:

In total, around 18,000 self exclusion orders are now in place at Singapore’s casinos, of which 70% are from foreigners. In addition to the 12,660 foreign workers excluded from the casinos, the number of locals excluding themselves from visiting Singapore’s casinos has also risen from 3,500 to 5,389.

Involuntarily Unwelcome, but not Excluded

Singapore and parts of Australia allow family members to initiate an inquiry that could result in a family member being excluded from casinos. The overriding of individual autonomy makes such programs more objectionable, to my mind, than voluntary self-exclusion programs. In “Handling Corporate Social Responsibility: A Third Way,” (Gaming Law Review and Economics 14(5): 355-361, 2010), William N. Thompson offers a compromise that North American casinos might want to consider. Family members can initiate an inquiry that could result, not in a gambler being excluded, but in a gambler being made to feel unwelcome or worse. (These consequences would be implemented for gamblers whose betting was creating significant harms for him- or her-self or for others.) Such unwelcome folks would be removed from all marketing campaigns, denied credit from the casino, and not allowed to collect large jackpots. (These three sanctions are standard elements of self-exclusion, too.) But the unwelcome would be allowed into casinos. Thompson suggests that toleration of their (unwelcome) presence could be at the discretion of the casinos: "They could be asked to leave casino premises at any time by casino authorities without any legal recourse." If casinos are generally intolerant of the unwelcome visitors, then the compromise begins to look a lot like an involuntary, third-party exclusion.

Facial Recognition, and Extending Exclusions

In April we noted that Ontario was in the midst of installing cameras tied to facial recognition software to help enforce casino exclusions. Apparently the system is now up and running in 19 of Ontario's 27 casinos, with complete coverage slated by the end of the year. One big hurdle that the proponents of the technology claim to have overcome is safeguarding the information identifying gamblers from intrusions by hackers.

The last line of the linked article indicates one potential penalty that can be applied to a self-excluded gambler who attempts to breach the agreement by sneaking into a casino. The regulatory agency can unilaterally extend the length of the exclusion of such miscreants, turning a voluntary self-exclusion into a third-party, mandated exclusion. I would hope that this move would be complemented with a positive step, an offer of treatment for gambling addiction. People who violate exclusion agreements, particularly ones with non-trivial penalties attached for non-compliance, are indicating that they have relatively serious control problems, perhaps even within the subset of gamblers who exclude -- so there is something to be said for directing treatment resources at these people. Angela Hawken, who promotes the analgous approach for drug users within the criminal justice system, calls such treatment targeting "behavioral triage."

"Re-Legalizing Drugs"

On April 17, 2011, I gave a talk (yes, "Re-Legalizing Drugs") as part of the TEDxUChicago festivities. The whole 17-minute ordeal is viewable here; the exclusion material starts around the 9:20 mark, and addresses both mandatory exclusions and voluntary self-exclusions from drugs.

[A similar link to the TEDxUChicago talk was posted on Vice Squad.]

British Columbia Casino ID Checks

In Canada's British Columbia, the drinking age and the minimum age to patronize a casino are both nineteen. A television investigative news team sent two 18 year-olds to four casinos, and at three of the four locations, the youths managed to walk right in, gamble a little, collect their winnings, and get a drink. Turns out the alcohol violation is the more serious offense, and the investigation has spurred a policy change: electronic ID readers will be employed at entrances and on the casino floor. Eventually the readers might be tied to self-exclusion lists, easing the enforcement of exclusion orders.

Mandated Exclusion from Alcohol

An underused tool for drug regulation is to revoke (for some period of time) a person's right to consume a drug, if that person has previously been violent or otherwise seriously misbehaved under the influence of the drug. Drunk drivers often lose their right to drive, but not their right to drink. In the case of repeat DWI offenders, South Dakota has a program that is effective at removing the privilege to consume alcohol. One can imagine that people might sign up for voluntary alcohol exclusion or limitation (as they do for gambling), if the implementation (including enforcement) of the exclusion were not too onerous. I think that many people would welcome a cheap, transparent, easy-functioning ignition interlock device in their car, too -- most people (when non-intoxicated) are not anxious to drive when they are unsafe or liable for arrest, though they might drive drunk anyway in the absence of an enforceable pre-commitment. (OK, "pre-commitment" is sort of a redundancy, but it is a popular one!)

An important 1933 book on alcohol policy, by Fosdick and Scott, includes (page 49) some information about exclusion. They are outlining how they think legal licensed alcohol sellers should be regulated following the (then imminent) demise of Prohibition. (Fosdick and Scott prefer state monopoly stores to licensed sellers for distilled alcohol, but they nevertheless provide detailed suggestions for how a licensing system might best be implemented.) "Rules are also necessary forbidding sale to minors, habitual alcoholics, paupers, mental defectives and to anyone who is drunk." The quoted sentence concludes with a footnote, which among other things indicates that Rhode Island has a law in which "an order of interdiction is prescribed for persons receiving town aid and for those whose relatives have filed complaint." That is, the Rhode Island alcohol law exhibited features that are replicated in current gambling regulations in Singapore.

My interest in mandated as well as voluntary exclusion derives in large measure by my belief that the (future) regulatory system for currently-prohibited drugs should, in many instances, include these elements.

Mandatory Gambling Limits in Australia?

Electronic gaming machines in Australia are slated to be retrofitted with card readers or other devices that will be able to keep track of a player's wagers. The idea is to enforce limits to gambling -- and it will be mandatory for gamblers to pre-specify those limits, at least if the central government gets its way. The proposal is meeting significant opposition, with pubs, clubs, and hotels that host gaming machines involved in the backlash. One of the animating developments behind the "mandatory pre-commitment" movement is the 2010 Productivity Commission report on gambling that (once again) showed the extent to which profits drawn from electronic gaming machines come from problem gamblers. From Chapter 5 (pdf here) of the report:

"Based on available survey data, there are between 80 000 and 160 000 Australian adults suffering significant problems from their gambling (0.5 to 1.0 per cent of adults), with a further 230 000 to 350 000 experiencing moderate risks that may make them vulnerable to problem gambling (1.4 to 2.1 per cent of adults).

Although there are substantial difficulties in calculating gambling expenditure, it is estimated that problem gamblers account for 22 to 60 per cent of total gaming machine spending (average of 41). The likely range for moderate risk and problem gamblers together is 42 to 75 per cent."

Enforcing Self-exclusion Through Facial Recognition

Ontario will soon be enforcing self-exclusion at its casinos via face recognition software, it seems. I am all for serious enforcement of self-exclusion programs, but I have to overcome some Big Brother-style fears when it comes to face recognition software. Apparently there are ways of keeping the information private? [PDF version, 23 pages, here.] I am late to this story, of course: here's a newspaper article from January that provides details. Humans will still make the final call on whether to approach a patron whom the computer has identified as on the exclusion list.

Reinstatement

A comment on this blog from last June informed us of the process for ending a self-exclusion in Pennsylvania. The idea is that once your chosen term for exclusion is over, you still might have to jump through some hoops to be reinstated. I think that there is something to be said for the need to take a positive step to be reinstated, as long as that step is not too onerous. (One of the problems with making reinstatement difficult is that wavering people might decide to forgo self-exclusion entirely; I think that also is a problem for exclusion schemes that offer only lifetime or long-term bans.)

The National Center for Responsible Gaming publication on Self-exclusion (54-page pdf here) contains an appendix summarizing self-exclusion programs in US states and selected other jurisdictions. Drawing on this source, some of the reinstatement schemes that involve barriers, and those barriers, follow:

Illinois: requires an affidavit from a mental health professional indicating that controlled gambling is feasible; Louisiana has a similar provision;

Kansas: excluders must take courses on healthy lifestyles and undertake a problem gambling assessment;

Pennsylvania: two personal visits, at least five days apart, are required for reinstatement; classes might be mandated, too;

Delaware (racetrack casinos): an in-person request for reinstatement is mandated;

Florida (racetrack casinos): A written request, and evidence of treatment, is required from the excluded individual; further, the casino manager must indicate in writing why the ban should be lifted;

Maine, New Mexico, and West Virginia (racetrack casinos): a petition is necessary for reinstatement; some New York racinos also require a petition for reinstatement;

SKYCITY Adelaide in Australia: excluders seeking reinstatement must undergo counseling, and agree to limits on both gambling spending and casino visits;

Ontario and Nova Scotia, in Canada: petitions are required for early reinstatement, and an investigation is then triggered;

Singapore: self- or family-excluded individuals must apply in person for reinstatement;

South Africa: an application, plus evidence of treatment, are required for reinstatement;

United Kingdom: an application for reinstatement is required, with a one-day cooling off period before the ban can be lifted.

Motivating Workouts

Self-exclusion noted a gym where non-attendance at scheduled workouts results in fines. The fine system is presumably motivated by the gym's capacity constraints: popular classes are over-subscribed, so reservations are required. The fines dissuade people from making, but then not honoring, their reservations. The system is similar to cancellation fees for hotels or airlines or upscale restaurants.

Via the Freakonomics blog, we learn of a Boston-area gym-pricing option that features higher fees for missed workouts. The variant of the fee schedule that involves enhanced payments for missing a daily workout has much in common with the fines imposed by the Chicago gym. Nevertheless, the motivations behind the two plans seem to be quite different: one is about managing a capacity constraint, and the other is about bolstering workout incentives. (And as the Boston plan is one that is self-selected among other fee arrangements, perhaps there is a systematic difference in the "types" of exercisers in the two locales.) Does the motivation behind the pricing scheme matter, or will the two similar plans produce similar results in terms of exercise behavior?

Foreigners Can Self-Exclude in Singapore

In the lead-up to the opening of two resort casinos, Singapore established a self-exclusion program. At first, self-exclusion was made available only to Singapore citizens and permanent residents. In recent months, however, the self-exclusion option has been extended to foreigners living in Singapore who hold temporary work permits. To get out the word, the institution that manages the self-exclusion program sent out 95,000 letters to employers, letting them know that their foreign workers now have access to casino self-exclusion.The employers themselves will not be able to initiate the casino exclusion of their employees. (Other types of involuntary exclusions are allowed in Singapore, including bans initiated at the behest of family members of a gambler.) Employers can facilitate a voluntary self-exclusion, however -- and it might be hard for a foreign worker to reject the proffered aid.

Missouri's Introduction of Self-Exclusion

In the United States, the first government-sponsored self-exclusion program was instituted by the state of Missouri in 1996. One of the people involved with the creation of the Missouri program has written a brief essay describing the initiation of self-exclusion; the essay, "The Emergence of Self-Exclusion Programs," appears on pages 3 to 6 of a 2010 publication (54-page pdf here) from the National Center for Responsible Gaming. (The entire volume, brought to my attention by the Pennsylvania press release linked in the previous post, is devoted to self-exclusion; more commentary on the volume, I suspect, will e-materialize on this blog in the future.) Missouri's voluntary self-exclusion program emanated from publicity concerning its involuntary program. Like many jurisdictions, Missouri bars some individuals (often those with gambling-related offenses in their background) from entering casinos. When a list of such excluded individuals made the news in 1995, a person suffering with his inability to control his gambling asked if he similarly could be banned. From such humble beginnings has grown a program that now includes more than 15,000 people who have volunteered for a lifetime ban on patronizing Missouri's casinos.

2,000 Applicants for Pennsylvania Self-Exclusion

Legal casinos came to Pennsylvania in late 2006, accompanied by a system of self-exclusion that applies to all gambling locales in the state. Within six months, more than 50 people had signed up for exclusion. Since that time, self-exclusion has been something of a growth industry in Pennsylvania: in January, 2011, the state announced that 2,000 erstwhile gamblers had made use of its self-exclusion service -- and more than one-quarter of these had chosen a lifetime ban over the one-year and five-year options, though the one-year ban was the majority choice. The one-year and five-year exclusions do not simply expire; rather, the excluded gambler has to request that the self-imposed ban be lifted after the exclusion period has elapsed.

Does Casino Self-Exclusion Work? (V)

European casinos generally require that patrons provide identification upon entering, and this measure aids enforcement of exclusion orders. (The news is filled with a continuing series of reports of excluded gamblers in other jurisdictions managing to evade, at least for a time, their exclusion orders.) A new article by Tobias Hayer and Gerhard Meyer uses a series of questionnaires to learn about the effectiveness of casino self-exclusion programs in Germany, Austria, and Switzerland. The results comport well with the findings from prior studies undertaken at other locales: gamblers who choose to self-exclude typically experience significant declines in gambling-related problems, and they tend to view the self-exclusion quite positively. These general findings are complemented by a slew of interesting details, including the importance of other gamblers, family members, and friends in informing people about the existence of self-exclusion programs. Only a relatively small number of gamblers learn of self-exclusion through information displays inside the casinos, suggesting that there is room for improved publicity measures. Casino staff, in these European locations, are nearly twice as likely as passive information displays to be a source of knowledge of the self-exclusion option.

The ID controls in European casinos, and the accompanying increase in the enforceability of an exclusion order, might make self-exclusion more popular as a preventative measure in Europe than elsewhere. About one-quarter of the participants in the study would not be classified as problem or pathological gamblers, by the usual metrics, at the time they chose to exclude.

Hayer and Meyer also indicate that my longstanding belief that formal casino self-exclusion programs originated in Canada in 1989 is terribly misguided. They report that self-exclusion programs existed decades earlier in both Germany and Austria. I will have to do some revising!


Previous (misguided?) posts in this series:

Does Casino Self-Exclusion Work? (IV)

Does Casino Self-Exclusion Work? (III)

Does Casino Self-Exclusion Work? (II)

Does Casino Self-Exclusion Work? (I)

eCOGRA's Safe and Fair Seal Requires Exclusion Options

Internet gambling seems to combine two area of human activity that display more than their share of less-than-trustworthy behavior. Someone interested in placing a bet online could be scared off over the uncertainty surrounding the integrity of the transaction offered by an internet betting shop or casino.

The internet gambling industry recognized their credibility problem at an early stage. One response that they adopted is a form of self-regulation. This response involves a sort of Good Housekeeping seal of approval, and one non-profit, independent (of the online betting shops) organization that awards the e-gambling seals is eCOGRA. To qualify for the right to display a "Safe and Fair" seal, internet gambling providers must meet a host of requirements concerning player protection, fair gaming, and responsible conduct. The detailed guidelines can be found here (49-page pdf). More than 100 e-casinos, internet poker rooms, and e-betting shops, including many of the best-known ones, currently are authorized to display the Safe and Fair seal.

Among the requirements for a Safe and Fair seal is the provision and effective communication of self-exclusion measures. A 24-hour cooling-off option must be available to players, and a six-month or longer exclusion also must be on offer. Third parties can request that a gambler be excluded -- as in Singapore's land-based casinos -- but those requests need not be honored. The guidelines also require, if I understand things correctly, that the gambling sites allow players to establish deposit limits, and to decrease those limits. Requests to increase a deposit limit that previously had been decreased cannot be honored for at least 24 hours. So both self-exclusion and self-limiting features are built into Safe and Fair e-gambling sites. Nevertheless, it does not appear to be the case that a single exclusion request will apply to multiple websites. (A system mentioned earlier had the feature of allowing a single exclusion to be implemented at multiple sites.) An e-gambler hoping to cut off access to his or her vice of choice might have a hard time maintaining enough stamina to self-exclude from dozens of e-casinos, of course.

Choosing to be Fined for Failure to Quit Smoking

Casino-style self-exclusion presents a physical barrier to further betting, and also lowers the reward to gambling, through the threat of confiscation of winnings (and embarrassment at being caught in violation of the exclusion order). Now-standard(?) commitment contracts implement the reward diminution element, but not the physical unavailability, when it comes to refraining from the undesired behavior.

A recent article by Gine', Karlan, and Zinman (working paper version here) examined a field trial in the Philippines of commitment contracts aimed at smoking cessation. Smokers were offered a chance to conveniently make weekly deposits to an illiquid bank account. (The idea was that they would deposit about the amount they would otherwise spend on cigarettes.) After six months, the depositors who took up this option would be tested to see if they had quit smoking. If they had quit, they would have access to their funds; if not, they would lose the money. The vast majority of smokers who were offered the savings account option refused to take part. Most of those who did take up the commitment contract failed to quit smoking. Nevertheless, quit rates were higher for those offered the savings account option than for those in the control group, and the difference persisted six months later.

Evaluating Improved Self-Exclusion

The heart of self-exclusion programs is the negative commitment, the ban on gambling at the excluded locales. But someone who volunteers for self-exclusion also is in a position to be informed about treatment options, and access to those options can be eased. (Currently, only a small percentage of problem gamblers, and of self-excluders, receive any formal treatment.) A Montreal casino introduced a reinforced self-exclusion program in 2005, one that included an initial evaluation, monthly phone contacts, and a mandatory meeting before the revocation of the exclusion agreement. The new variant was evaluated by Tremblay, Boutin, and Ladouceur in 2008. Given the option of either a standard self-exclusion program or the "improved" version, a majority of excluders chose the improved version. Their gambling problems decreased significantly, and generally they were quite favorably disposed towards the improved self-exclusion regime.