Alcohol Strategy - the way forward. A report from Alcohol Concern

Transcription

1 Alcohol Strategy - the way forward A report from Alcohol Concern Prepared by Srabani Sen, Chief Executive March st Floor, 8 Shelton Street, London WC2H 9JR, Tel: Fax: , contact@alcoholconcern.org.uk Page 1

2 Alcohol Strategy - the way forward As the Government reviews its Alcohol Harm Reduction Strategy and considers its next steps, this paper summarises Alcohol Concern s vision of how society can achieve a relationship with alcohol. It sets out: The principles which should underlie the new strategy It s key aims and objectives Alcohol Concern s recommended solutions Alcohol Concern is conducting a review of the evidence regarding the impact of the Alcohol Harm Reduction Strategy England This is contained in a separate document, but its findings inform the proposals set out within this paper. Underlying principles Government leadership If genuine progress is to be made, Government will need to demonstrate clear leadership to drive forward change. This is not to say that government has to deliver all of the change. However government must set out clear expectations of what that change should look like, by whom it should be delivered and by when it should be achieved. It will also require ambition on the part of Government. The levels of harm caused by alcohol are escalating beyond reason and in many cases increasing cost to individuals and to public services. These harms and the costs associated with them are avoidable. However tinkering around the extreme edges of alcohol harm is simply not an efficient or cost-effective way of tackling the problem. An integrated and systematic approach which recognises the complexity of alcohol issues and how embedded alcohol excess is within the psyche of British society is essential. Government rightly talks of the need for culture change and for society to re-evaluate its relationship with alcohol. Culture change takes effort and commitment from government and other key stakeholders on a large scale. The climate of public opinion has never been more receptive to government initiatives to tackle alcohol-related harm. Public concerns about alcohol harms have gone well beyond fear of alcohol fuelled violence and binge drinking. The media and the public are waking up to the damage alcohol can do to their health and also to the well being of their children. Never has there been a greater opportunity for government to leave a lasting legacy on this crucial issue. Page 2

3 Long term commitment The problems surrounding alcohol misuse and the harm it causes are complex, and in many contexts, embedded within certain parts of society. Any plan to tackle this area will need to have a realistic timeframe for delivery, but equally, sustained commitment and leadership from Government and stakeholders. Holistic view One of the difficulties of harm reduction approaches to date, whether they relate to the Government s Strategy or local initiatives, is that they tend to focus on particular problems at particular times. The trouble is that alcohol as an issue is not as simple as that. e.g. although there may be a particular problem with binge drinking, this is interconnected with a whole series of other issues such as societal attitude to drunkenness, easy accessibility of cheap alcohol, increase in disposable incomes for young people etc. Therefore one dimensional approaches are never going to be sufficient. Furthermore, for local action to be consistent, specific levers are required to ensure some communities do not suffer more than others. This requires government to ensure these levers are put in place, monitored and evaluated, allowing local people to hold those in authority to account. We would urge the Government to recognise the complexities and interconnectedness of the issues. Without this understanding, the next stage of the Alcohol Strategy is unlikely to succeed to any great extent. Industry outlook Understandably the drinks industry has tended to take a protectionist view whenever it has engaged en masse in debates about reducing alcohol harm. What is needed is a new approach, whereby the drinks industry acknowledges its contribution to alcohol harm as a starting point for debate. Some sections of what is a very fragmented industry, will privately acknowledge that they need a change of approach. Perhaps government could consider working with these sectors in the first instance to move the agenda forward. Whilst the production and sale of alcohol is perfectly legitimate activity, government needs to ask itself how much harm it is willing for British society to bear before it regulates against the worst practices of the industry. Page 3

4 Redress the balance of the debate Government and industry often preface debates about alcohol harm by citing the fact that it is possible to drink safely, and that alcohol can have protective benefits for health. While both of these statements are true, in Alcohol Concern s view their prominence in the debate are out of kilter with the reality of how dangerous a substance alcohol can be when mishandled. Whereas it is possible to drink safely, the main data we have about alcohol consumption is based on self reporting. Even assuming that people are able to be accurate about how much they drink, and that the consumption data we have is correct, millions of people in this country are hurting or putting at risk themselves and those around them. This cannot be acceptable. Indeed the level of consumption may well be an underestimate. ONS data makes it clear that most people do not know how to measure their alcohol intake in units. Therefore we simply do not know how many people are drinking too much, and the figures are likely to me much higher than we thought. The figures for harm are also likely to be a significant underestimate. The degree to which alcohol is a factor in, for example, heart disease, cancers and strokes is not routinely evaluated. As to the protective benefits of alcohol, these equate to the consumption of very small quantities of alcohol, relate to only one condition - heart disease - and are only relevant for small groups of people. The damaging impact of alcohol, even when consumed at relatively low levels, FAR outweigh the benefits of alcohol consumption in terms of its impact on society. Therefore in framing the debate about the next stages of the Strategy, government really needs to acknowledge that too many people are drinking too much, and that this is causing unacceptable levels of damage to individuals, families and society. If this is acknowledged up front as the starting point, we can then begin an honest debate about how to solve the problems. Clarity Alcohol Concern looks to Government, through the development of the new Strategy to be clear about: What it wishes to achieve Who the key stakeholders are and what the Government s role will be in delivering change The timescales within which achievements are to be made What resources need to be devoted to achieving change and where they will come from How the impact of the new strategy will be monitored and evaluated, when and by whom How progress will be reported, and when Page 4

5 Key aims and objectives Goal 1 Overall aim: Reduce alcohol consumption Specific objectives: - Reduce per capita consumption to 1970s levels - Reduce to nil consumption of alcohol by children aged 15 or under Goal 2 Overall aim: Alcohol will be a public health issue with the same status as tobacco and obesity Specific objectives: - All drinkers will understand how to drink safely and know the risks of not doing so - All social, healthcare and criminal justice professionals will know how to recognise when their client is drinking above safe levels and will have standardised interventions available to support them Goal 3 Overall aim: Individual and societal Harm levels will decrease (health, relationships, violence etc) Specific objectives: - Government will define acceptable levels of societal Harm - Alcohol related domestic violence will fall by 50% over 10 years - violent crime will fall by 50 % over 5 years - mortality will be reduced by 50% over 10 years. - Child admission to hospital for alcohol related conditions will fall to nil Goal 4 Overall aim: Alcohol will be integrated as an issue within the health, social care and criminal justice systems Specific objective: - However a problem drinker enters or encounters the health, criminal justice or social care system, they will be picked up and supported to reduce their drinking - No less than one in 5 problem drinkers will be able to access treatment when required Goal 5 Overall aim: There will be national and local leadership for alcohol Specific objective: -There will be national leadership on alcohol to ensure that the new alcohol strategy is delivered - There will be mandatory targets to assess and reduce alcohol harm locally. Local leadership structures will ensure that local delivery plans are sustained Page 5

6 Solutions A mixture of agencies would be responsible for delivering these proposals including government, public service providers, voluntary organisations and the drinks industry. Solutions relating to goal 1 of reducing alcohol consumption Consumption levels Tax on alcohol will relate to alcohol strength. The stronger the product, the higher the tax No alcohol will be sold at a loss, either by a producer or a retailer Alcohol will only be available in alcohol sections of supermarkets and retail outlets, e.g. no end of aisle promotions There will be no more than x outlets for the sale of alcohol within y square miles Children s drinking It will be illegal to provide children aged 15 or under with alcohol There will be no alcohol advertising before the watershed or around cinema advertising linked to films under an 18 rating There will be no alcohol company sponsorship of sports events or music festivals Solutions relating to goal 2 of making alcohol a high status public health issue All key healthcare professionals will be trained to recognise and provide brief interventions for people with alcohol problems, and will know how and when to refer people on to specialist services Alcohol will be built into the Quality and Outcomes Framework for GPs Every hospital ward and A&E department will have access to an alcohol health liaison worker The alcohol industry will be independently regulated, with proactive monitoring of compliance with relevant codes There will be mandatory point of sale information about how to drink safely and the dangers of not doing so Government will work with others to conduct a sustained awareness raising campaign to educate the public about safe drinking and the dangers of drinking to excess There will be an increase in research funding for alcohol Page 6

7 Solutions relating to goal 3 of reducing levels of harm All alcohol dependent drinkers will be able to access treatment services in their area There will be a comprehensive infrastructure of youth treatment services Resources spend on alcohol harm reduction will be the equivalent of 10% of alcohol tax revenue The permissible blood alcohol level relating to drink driving will be reduced from 80mg to 50mg/100ml of blood. It will be mandatory for the alcohol industry to spend 10% or more of its promotional budget on promoting harm reduction initiatives which are independently provided and evaluated The government will commit to an evidence based review of Licensing Laws in 2008 and will introduce a fifth local authority objective to include protecting public health Arrest referral schemes will be introduced within every borough command unit Every prison will have a dedicated team to support prisoners with alcohol problems to reduce reoffending Existing laws will be fully enforced and monitored, e.g. laws relating to the sale of alcohol to people who are drunk Solutions relating to goal 4 of integrating alcohol issues within the health, social care and criminal justice systems Government will set out clear expectations and timescales relating to national, regional and local alcohol harm reduction Key services, e.g. the police, social services, A&E etc, will monitor all alcohol related incidents Every local area agreement will assess alcohol harm and set targets for reduction, making specific reference to alcohol treatment provision Screening and brief interventions (SBI) will take place in all Tier One services, with ongoing training provided for all tier one professionals There will be a national monitoring system for brief interventions and treatment provision, including evaluation of the number of people helped, the quality of services and the outcomes achieved. Local commissioners will be obliged to assess the degree to which local treatment systems conform to Models of Care for Alcohol Misuse guidelines and to report to Regional Directors of Public Health Alcohol treatment services will be resourced to improve aftercare and self-help provision Properly planned and resourced services must be put in place for those affected by problem drinkers, e.g. partners and children. Adult treatment services will be trained and resourced to work more effectively with carers and families Page 7

8 Solutions relating to goal 5 of providing national and local leadership on alcohol issues Government will develop a clear action plan for tackling alcohol, with specific timescales and setting out how the plan will be evaluated Government will appoint a national alcohol champion, supported by a central unit, reporting into Number 10. Every relevant public service (e.g. hospitals, borough command units) will have a named individual responsible for leading and reporting on alcohol harm reduction for their service Drug Action Teams and Crime and Disorder Reduction Partnerships will have statutory responsibilities to oversee local alcohol strategies and LAA targets to reduce alcohol harms Page 8

9 5 Alcohol as a determining factor in people s ability to access financial services Buying a policy Insurance 5.1 Within the highly competitive insurance market, most applications for insurance are granted on the basis of the application form, unless the answers on the form give rise for concern. Also, within for example the health insurance products, one factor, e.g. alcohol consumption, would not be looked at in isolation from other factors in determining whether to deny an application, whether to increase the price or whether to introduce exclusions to the policy. 5.2 Also, the volume of insurance sales is enormous. As one person put it if we were to ask for GP certificates from everyone who gave grounds for further inquiry, the NHS would grind to a halt. Therefore it is more a matter of judgement made by individual insurance company employees about whether to grant an insurance application or not. 5.3 An examination of the standard form 1 that GPs are sometimes asked to fill in for health insurance products, reveals some interesting points: Patients have to give consent for a GP to fill in the form. Therefore if someone has an alcohol problem, are they likely to give consent? And to what extent is failure to consent to a GP certificate grounds for insurance companies to refuse applications? Patients do not have to be interviewed by the GP; information already on the GP system is used to fill in the form. There are clearly implications here as we know that many GPs do not pick up on alcohol problems. A specific question is asked about conditions related to drug or alcohol misuse Questions are asked about conditions which might be affected by alcohol consumption, e,g, cardiovascular disease, mental health problems, suicidal tendencies, high blood pressure 5.4 There is a real opportunity here to educate the insurance company further about the impact of alcohol on the risk. This would need to be looked at further. 5.5 Regarding the pricing of premiums charged for extra risks identified through the application process, decisions are made at a company level. These pricing decisions are based as much on the need to be competitive as they are on the actual risks identified. 5.6 In relation to health insurance products questions are asked about alcohol consumption. However insurers seem more interested in whether actual harm has been caused to health and whether there is evidence of alcohol related illnesses 1 Standard GP report form and covering letter, Association of British Insurers Page 9

10 when deciding whether to issue a policy. These conditions may lead to exclusions to what is covered by the policy. (No exclusions are included in most life insurance policies.) 5.7 In relation to critical illness cover for example there is a specific exclusion related to illnesses caused by drug or alcohol misuse. Below is the wording recommended for companies to use in the ABI s Best Practice guidance on critical illness cover 2 : We will not pay a critical illness claim if it is caused directly or indirectly from any of the following: Inappropriate use of alcohol or drugs, including but not limited to the following: Consuming too much alcohol Taking an overdose of drugs whether lawfully prescribed or otherwise Taking controlled drugs as defined by the Misuse of Drugs Act 1971 otherwise than in accordance with a lawful prescription 5.8 Similar wording is used in relation to other health insurance products, including income protection insurance No questions are asked about alcohol consumption on motor insurance applications. Questions are asked however about any driving convictions, and this will of course pick up drink driving convictions 5.10 Insurers also ask questions about any medical conditions notifiable to the DVLA. Therefore there may be cost implications to people wanting to buy motor insurance. (See reference to DVLA above) Loans and credit 5.11 No questions are asked on alcohol consumption or alcohol related issues on mortgage applications. The BSA were clear that they believe this would be unfairly intrusive, their point being where would you stop if you started asking about one area of a person s life. All that building societies are interested in when deciding to offer a mortgage are the risks which they perceive are linked to potential default, e.g. a person s employment history. They were not interested in considering that alcohol may have been the reason someone has had a patchy employment history. The BSA also pointed out that people can lie on their forms in order to get a mortgage, particularly in the current climate within the housing market As stated above, what is examined is people s payment and credit history. Each lender will tend to have their own policies in terms of their response to a person s payment behaviour. So whereas an alcohol problem may have led to 2 Statement of Best Practice for Critical Illness Cover, Association of British Insurers, Statement of Best Practice for Income Protection Insurance, Association of British Insurance, 2005 Page 10

11 someone losing their job and therefore being unable to keep up with mortgage payments, the non-payment will be looked at, not the reason why. Making an insurance claim 5.13 In relation to life, critical illness and income protection insurance, there are lists of conditions which would impact on whether or not a company would pay out. Alcohol induced illness is one of them. Page 11

12 6 Issues and opportunities for DH to consider moving forward Areas of further research Due to time constraints, we were unable to look at the banking industry s response to alcohol issues. This may be worthy of further exploration. The role of the Financial Ombudsman Service, together with any data regarding to what extent alcohol figures in the disputes they deal with would be worthy of further exploration. Areas of opportunity (either for DH or others) It would be worth exploring with the FSA whether there should or could be a requirement to collect data on alcohol related insurance claims and loan defaults There is a real opportunity to explore with the insurance industry a better way of assessing alcohol related risks. There seemed to be a genuine willingness from those we spoke to within the insurance industry to continue the dialogue begun through this research. DH could explore partnership working with the DVLA to ensure that robust processes are in place to identify problem drinkers applying for driving licences. It also be the case that information about sensible drinking could be included with licenses which are issued. We did not look into the age profile of driving licence applications, but we would suspect that a large volume of new licence requests are from year olds, who are already one of the government s targets in relation to binge drinking. Financial services providers often have corporate social responsibility programmes, and one example of how these programmes have supported alcohol is listed in this report. This kind of support for tackling alcohol problems could be further explored, and indeed stimulated. It would be worth pursuing APACS on alcohol issues, to build on the work that credit card companies are already doing around mental health issues Page 12

13 Appendix 1 List of documents reviewed Association of British Insurers, Standard GP report form and covering letter Association of British Insurers, Statement of Best Practice for Critical Illness Cover, 2006 Association of British Insurers, Statement of Best Practice for Income Protection Insurance, 2005 Association of British Insurers, UK Insurance Key Facts, 2005 Association of British Insurers and the British Medical Association, Medical Information and insurance: joint guidelines from the British Medical Association and the Association of British Insurers, 2002 Citizen s Advice, Deeper in debt, 2006 DVLA, For medical practitioners: at a glance guide to the current medical standards of fitness to drive, 2006 Financial Services Authority, The future regulation of insurance, 2002 Page 13

14 Appendix 2 List of people spoken to Name Job Title Organisation Nick Hurman Corporate Affairs Aegon UK plc Consultant Derek Fawey Policy Advisor (Motor) Association of British Insurers Richard Walsh Head of Health Association of British Insurers Sandra Quinn Director of Communications Association for Payment Clearance Services (APACS) Rachel Snow Head of External Affairs Building Societies Association Teresa Purchard Head of Policy Citizens Advice Tony Jupp Chief Underwriter (Life Insurance) Norwich Union Page 14

15 Appendix 3 Key questions for the DH insurance and financial services project Overall question 1. To what extent does alcohol figure in the business decisions of the financial and insurance services sector? Scale of the problem 2. Does the insurance industry keep records of alcohol related claims? If so what is the scale of alcohol related claims 3. To what extent is the insurance industry aware of the level of alcohol consumption in the UK and its impact on accidents, health and crime? 4. What evidence is there of alcohol related defaulting on loans/ mortgages? Is this area monitored. 5. Is the mortgage/ loan industry aware of alcohol s impact on working days lost etc? Response of the industry 6. Are questions asked about alcohol consumption of potential customers in relation to loans, mortgages and insurance policies (car insurance, health insurance, life insurance, mortgage protection insurance are there other types of insurance affected by alcohol??) 7. Is alcohol a factor in calculating insurance premiums/ Is alcohol a factor in companies deciding likely claims that will be made to them? 8. Is there evidence of people being refused policies/ loans/ mortgages because of their alcohol consumption? 9. Is there FSA/ ABI guidance on alcohol issues? 10. Is there any legislation/ guidelines for what to do if someone has lied on their application e.g. and develops liver disease 11. If the insurance/ financial services industry were to introduce alcohol into its decision making, what mechanisms exist: i. For influencing practice ii. For enforcing new ways or working Page 15