ground facts in a specific community. The NIGC is available to provide resources and input as these
considerations become relevant in different communities and in preparation to mitigate any risk.

In order to assist in monitoring environmental and public health and safety requirements under the Indian
Gaming Regulatory Act, we encourage tribes to self-report any presumptive positive cases of COVID-19
that involve your gaming facilities to the NIGC. For additional guidance, information or technical
assistance, please contact your NIGC Regional Office (www.nige.gov/compliance/regional-office) or
Director of Compliance, Dustin Thomas, at dustin.thomas@nige.gov or (202) 531-6407.

Sincerely, )
ud

fustin Thomas
Director of Compliance



Address key prevention strategies in your emergency operations and preparedness plan:

« Provide COVID-19 prevention supplies at your facilities. Plan to have extra supplies on hand for
employees and patrons, including sinks with soap, hand sanitizers, increased cleaning and
sanitizing efforts, etc.

« Plan for employee absences. Develop flexible attendance and sick-leave policies. Employees
should stay home when they are sick, or they may need to stay home to care for a sick household
member or care for their children in the event of school dismissals. Identify critical job functions
and positions and plan for alternative coverage by cross-training staff (similar to planning for
holiday staffing).

¢ Ifan employee is confirmed to have COVID-19, employers should inform fellow employees of
their possible exposure to COVID-19 in the workplace but maintain confidentiality as required by
the Americans with Disabilities Act.

Stay informed using trusted sources — CDC is updating its website daily with the latest information and
advice for the public. (https://www.cdc.gov/coronavirus/2019-ncov/index.html) The CDC does NOT
currently recommend the use of facemasks or other respiratory protection for the general public.
However, everyday preventive actions to help prevent the spread of viruses are advised, including:

«Wash hands often with soap and water for at least 20 seconds. If soap and water are not available,
use an alcohol-based hand sanitizer.

« Avoid touching eyes, nose, and mouth with unwashed hands.

« Stay home when sick and avoid close contact with people who are sick.

« Cover cough or sneeze with a tissue, then throw the tissue in the trash.

« Clean and disinfect frequently touched objects and surfaces.

« Get the flu vaccine, if you have not already received it this season.

« If you are experiencing symptoms such as cough, fever, shortness of breath, follow up with your
healthcare provider and be sure to mention any recent travel.

References/For more information:

+ _THS: https://www.ihs.gov/
+ HHS-CDC Information: https://www.cde.gov/coronavirus/2019-nCoV/summary.html

« OSHA Information: https://www.osha.gov/SLTC/novel_coronavirus/index.htm]

« World Health Organization Information: https://www.who.int/emergencies/diseases/novel-
coronavirus-2019

Tribal regulatory authorities and casino management should evaluate tribal internal controls and policies
and procedures for updates needed to account for preventive health practices that are being encouraged to
protect casino staff and patrons. In the event of a presumptive positive case of COVID-19 that involves
your gaming facility, the NIGC encourages swift action to contain and mitigate the spread of the virus.
Appropriate measures should be taken to protect the health and safety of staff and the public.

The NIGC is very open to understanding how the NIGC can support your efforts to communicate
externally to the public about the oversight measures in place to protect facilities, staff and patrons. We
know that the scope of internal deliberations among the tribe and its operators will vary given the on the


NEW MAILING ADDRESS: NIGC/DEPARTMENT OF THE INTERIOR 1

March 12, 2020

Dear Tribal Leader

This letter is to provide you with an update on the measures the National Indian Gaming
Commission (NIGC) is taking with regard to the Coronavirus (COVID-19). I also want to
reiterate the strength of the regulatory framework in place to protect the Indian gaming industry
from new and emerging threats.

To the extent there is a threat to public health and safety at an Indian gaming facility, the
oversight envisioned by the Indian Gaming Regulatory Act safeguards an operation’s staff,
patrons and facilities. As the Indian gaming industry’s federal regulatory body, the NIGC shares
a common interest with tribal regulators in preserving the Indian gaming industry’s integrity.
That common interests will continue to guide the NIGC’s collaboration with tribes as we monitor
public health and safety threats.

There are numerous requirements to an Indian gaming facility’s operation. One requirement is
the tribal government’s attestation that tribal gaming ordinances and related laws that apply toa
gaming facility’s environment, public health, and safety standards are effective and in place.
Regular site visits by the NIGC ensure that these measures are in effect and followed by the
licensed operators. This NIGC presence and additional oversight measures give the NIGC
confidence that tribal gaming regulatory authorities (TGRAs) are an on-the-ground presence at
every Indian gaming operation and that TGRAs have the capacity and tools to help ensure
compliance.

The NIGC team is made up of talented subject matter experts with a diversity of expertise and a
strong commitment to protect the integrity of the Indian gaming industry. The NIGC team will
continue to communicate the importance of the NIGC team supporting TGRAs’ role in helping
to inform lawmakers about planning for and responding to circumstances that would threaten a
well managed and safe Indian gaming operation. This outreach effort is part of an agency-wide
focus in our daily work around preparedness.

Earlier this week I presented on the topic of preparedness to the National Tribal Gaming
Commissioners/Regulators in San Diego, CA. In my presentation I emphasized the important
role TGRAs can and should play as tribal leadership mitigates risk associated with COVID-19.
TGRAs are well positioned to encourage and facilitate coordination with local jurisdictions.
TGRAs are able to assess regulatory requirements’ capacity to protect the well-being of an
Indian gaming operation’s staff, patrons and facilities. And, TGRAs’ risk assessment knowledge
should be an important consideration as a tribal community develops an appropriate
communication plan for their local area.

REGIONAL OFFICES Portland,

WWW.NIGC.GOV


In order to assist TGRAs in their efforts the NIGC remains a collaborative resource. Through our
outreach by the NIGC regional offices, the NIGC will give special attention to challenges that
may arise in a given operation and the impact those challenges may have toa TGRA’s over all
regulatory capacity. In addition, the NIGC will continue to promote best practices at the local
and national levels to help address issues that may arise. A copy of the most recent
communication by the NIGC Director of Compliance to all TGRA leadership is attached to this
letter and illustrates the guidance we will continue to provide as appropriate.

Additionally, the NIGC continues to take steps that will ensure we remain accountable to good
governance practices as a federal agency. It is a priority at the agency to institute and anticipate
policies and practices necessary to maintain the NIGC’s ability to continue operations.
Maintaining operational capacity ensures the NIGC will meet our responsibilities as a regulatory
body in service to the American people.

As developments occur I will continue to update you. Thank you for the leadership you provide
and our shared commitment to protect tribal assets and promote tribal self-sufficiency.

Sincerely,

(! :

E. AA
Chairman

Attachment


Coronavirus (COVID-19) Guidance for Tribal Gaming Facilities

March 12, 2020

Dear Tribal Regulators:

This interim guidance, as provided by the Centers for Disease Control and Prevention (CDC), is intended
to assist you and your tribal gaming communities in taking appropriate measures to combat the
Coronavirus (COVID-19).

COVID-19 is an emerging respiratory disease and there is more to learn about its transmission, clinical
course, and populations at increased risk of disease and complications. Everyone can do their part to help
plan, prepare, and respond to this emerging public health threat.

As the COVID-19 outbreak evolves, CDC strongly encourages organizers and staff of large gatherings to
prepare for the possibility of outbreaks in their communities. Assessing your emergency preparedness and
continuity plans can help protect your employees and communities.

CDC has developed recommended actions for preventing the spread of COVID-19 at mass gatherings and
large community events.

Review emergency operation and preparedness plans for your facilities:

+ Stay informed about the local COVID-19 situation. Get up-to-date information about local
COVID-19 activity from public health officials.

« Discuss your emergency operations plans and determine how they may impact aspects of your
events, such as personnel, security, services and activities, functions, and resources. Work with
your emergency operations coordinator or planning team to prepare for the key prevention
strategies outlined in this guidance. Develop a contingency plan that addresses various scenarios
described below which you may encounter during a COVID-19 outbreak.

¢ Establish relationships with key community partners and stakeholders. When forming key
relationships, include relevant partners such as the local public health departments, community
leaders, vendors, suppliers, hospitals, hotels, airlines, transportation companies, and law
enforcement. Collaborate and coordinate with them on broader planning efforts. Clearly identify
each partner’s role, responsibilities, and decision-making authority. Contact your local public
health department for a copy of their outbreak response and mitigation plan for your community.
Participate in community-wide emergency preparedness activities.

NATIONAL INDIAN GAMING COMMISSION 1849 C Street NW, Mail Stop #1621 Washington, DC 20240 Tel: 202.632.7003 Fax: 202.632.7066
REGIONAL OFFICES Portland, OR; Sacramento, CA; Phoenix, AZ; St. Paul, MN; Tulsa, OK; Oklahoma City, OK; Rapid City, SD
WWW.NIGC.GOV