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Message from the Chairman

I am pleased to present the National 

Indian Gaming Commission’s 2022-2026 

Strategic Plan. The Plan sets out the 

Agency’s goals and measures by which it 

will assess its success. The Agency 

prepared the Strategic Plan pursuant to 

the Government Performance and Results 

Act of 1993, and in consultation with 

tribal governments. This Strategic Plan 

supersedes the Fiscal Years 2018-2022 

plan.

The Agency will continue to strengthen 

its role in the regulatory community. This 

requires the Agency to focus on its 

unique responsibilities in the industry’s 

regulatory framework as articulated by its 

statutory mission. Enhancing Agency 

expertise by fostering relationships with 

other regulatory bodies and tribal partners 

will help ensure the Agency’s future 

resilience; as will an Agency focus on diplomatic, and accountable decision

making. Such decision-making encourages forward-looking planning processes 

and provides the public with greater insight into the Agency’s work. It also 

upholds the Agency’s intergovernmental obligations which honors tribes’ 

governmental authority and supports tribal economies.

This Plan was informed by significant trends. A hallmark of the Indian gaming 

industry has been its ability to innovate and grow. An influx of new 

technologies and gaming formats in recent years presents opportunities for 

potential industry growth. This growth would continue to benefit from the 

Agency’s engagement with industry and other federal agencies when 

engagement provides certainty and promotes a shared commitment to a wellregulated industry. In addition, the insights from the global pandemic will 

remain relevant. These insights build on the regulatory community’s role in 

NIGC Chairman 

E. Sequoyah Simermeyer
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managing risk when meeting the obligations to protect public health and safety 

and ensure the continuity of sound regulatory operations at all levels. The 

Agency’s insights also include efficient and cost-effective approaches in order 

to maintain the NIGC’s operations. Sustainable Agency operations help to grow 

tribes’ self-sufficiency, regulatory capacity, and tribal economies; and require a 

commitment to good governance practices, a well-trained federal workforce, 

and appropriate Agency presence.

The NIGC’s strategic plan is an important tool to support the Agency’s success 

in carrying out its statutory responsibilities and it serves as a tool for 

transparency as the Agency sets forth priorities and initiatives. The Strategic 

Plan for Fiscal Years 2022-2026 emphasizes four areas for the Agency’s work. 

The Plan focuses on support for industry integrity; efforts around Agency 

accountability; the regulatory community’s commitment to preparedness; and 

innovation in the Agency’s outreach and collaboration. Please feel free to share 

your comments at www.NIGC.gov.
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Contents

Introduction.............................................................................................................................. 4

Organizational Structure........................................................................................... 5

Mission.......................................................................................................................... 5

Vision............................................................................................................................ 5

Strategic Plan Development ................................................................................................ 5

Consultation Efforts .............................................................................................................. 6

Strategic Plan Framework .................................................................................................... 6

External Risk Factors ............................................................................................................. 7

Performance Tracking and Reporting ................................................................................ 8

Strategic Goal 1: Industry Integrity – Protecting the valuable tool of Indian gaming 

that in many communities creates jobs, is the lifeblood for tribal programs, and 

creates opportunities for tribes to explore and strengthen relationships with 

neighboring jurisdictions ..................................................................................................... 8

Strategic Goal 2: Preparedness – Promoting tribes’ capacity to plan for risks to tribal 

gaming assets including man-made disaster threats, pandemics, natural disaster 

threats, the need to modernize and enhance regulatory and gaming operation 

workforces, or public health and safety emergencies ................................................ 11

Strategic Goal 3: Outreach – Cultivating opportunities for outreach to ensure 

well-informed Indian gaming policy development through diverse relationships, 

accessible resources, and government-to-government consultation .......................... 14

Strategic Goal 4: Agency Accountability – Meeting the tribes’ and public’s expectation 

for administrative processes that uphold good governance practices and support 

efficient and effective decision making to protect tribal assets ................................. 16
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Introduction

The National Indian Gaming Commission (“NIGC” or “Commission” or “Agency”) was created by 

Congress through the Indian Gaming Regulatory Act of 1988 (P.L. 100-497). The Indian Gaming 

Regulatory Act (IGRA) established the NIGC as an independent federal agency within the 

Department of the Interior (DOI). IGRA was enacted with the express purpose to support and 

promote tribal economic development, self-sufficiency and strong tribal governments through 

the operation of gaming on Indian lands. 25. U.S.C. § 2702.

IGRA provides a legal framework structured to safeguard tribes as the primary beneficiaries of 

their gaming operations, shield Indian gaming from corrupting influences, and ensure that the 

games offered are fair and honest. IGRA created the NIGC to protect tribal gaming as a means of 

generating revenue for tribal governance and tribal communities. 

NIGC seeks compliance with IGRA, NIGC regulations and tribal gaming ordinances. To do so, the 

Agency regulates and monitors tribal gaming activity, inspects gaming premises, conducts 

background investigations, analyzes audits of Class II and certain aspects of Class III gaming 

operations, and investigates violations of IGRA. The NIGC further provides technical assistance, 

including extensive training, to tribal leaders as well as tribal gaming commissions and operators. 

When technical assistance and training do not achieve compliance with IGRA, NIGC regulations 

and the tribal gaming ordinance, the NIGC will undertake enforcement action. 

The NIGC fulfills its responsibilities under IGRA by: 

 regulating and monitoring certain aspects of Indian gaming; 

 coordinating its regulatory responsibilities with tribal regulatory agencies through the 

review and approval of tribal gaming ordinances and management agreements;

 reviewing the backgrounds of individuals and entities to ensure the suitability of those 

seeking to manage Indian gaming; 

 overseeing and reviewing the conduct and regulation of Indian gaming operations;

 providing relevant technical assistance and training;

 referring criminal matters to appropriate tribal, Federal and state entities; and 

 undertaking enforcement actions for violations of IGRA, NIGC regulations, and tribal 

gaming ordinances, including imposing appropriate sanctions for such violations, which 

may include civil penalties and orders for temporary closure. 

As the NIGC fulfills these responsibilities, the Agency closely reviews any indications of corrupting 

influences that may jeopardize the integrity of tribal gaming.

The NIGC provides Federal oversight to over 520 tribally owned, operated, or licensed

gaming establishments operating in 29 states.
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Organizational Structure

The Commission is composed of three full-time members, including a Chair and two Associate 

Commissioners. The Chair is appointed by the President and confirmed by the Senate. The two 

Associate Commissioners are appointed by the Secretary of the Interior. The Commission selects 

a Vice Chair by a majority vote. At least two members of the Commission must be members of a 

federally recognized Indian Tribe and no more than two may be of the same political party.

Led by the Chair, the NIGC is composed of the Office of the Chief of Staff and the Office of General 

Counsel with approximately 100 full-time employees at the Commission’s headquarters in 

Washington, D.C., and at eight regional offices. The Office of the Chief of Staff oversees four 

operational divisions including the Division of Public Affairs, Division of Finance, Division of 

Technology and the Division of Compliance to accomplish NIGC’s mission and support the 

Commission’s vision.

Mission

The NIGC’s mission is to (1) promote tribal economic development, self-sufficiency, and strong 

tribal governments; (2) maintain the integrity of the Indian gaming industry; and (3) ensure that 

Tribes are the primary beneficiaries of their gaming activities. To fulfill its mission and achieve 

compliance, the NIGC works within the framework created by the IGRA by providing sound 

guidance, removing unnecessary roadblocks, and sensibly regulating gaming activities conducted 

by sovereign Indian tribes on Indian lands without stymieing the economic development and 

entrepreneurial spirit of tribes.

Vision

The Commission’s vision is to utilize all of its regulatory tools, including training, technical 

assistance, public education, and enforcement, to empower and partner with tribal governments 

to ensure regulatory compliance and gaming integrity that respects the capabilities and 

responsibilities of each sovereign tribe.

Strategic Plan Development

Every four years, the NIGC updates its strategic plan to reflect the Agency’s current priorities and 

initiatives and how it will accomplish them. The strategic plan presents the NIGC’s long-term 

goals and strategies for achieving effective federal regulation of Indian gaming in coordination 

with regulatory partners.

To develop the strategic plan, the NIGC established a strategic planning team to provide a 

comprehensive review of the Agency, its mission, and current initiatives in order to draft a plan 

outline for Commission and NIGC management review. This team included staff from each 

principal department and each operational division to contribute to the development of the 
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strategic plan. Meetings were held to formulate the objectives and strategies based on goals 

established from the NIGC’s current mission, priorities, and emphasis areas. 

The strategic plan was prepared pursuant to the requirements of the GPRA Modernization Act of 

2010. This plan updates and supersedes the strategic plan covering fiscal years 2018 – 2022.

Consultation Efforts

The NIGC incorporated the more specific consultation requirements set forth in the GPRA 

Modernization Act of 2010. The NIGC recognizes the requirements set forth in Executive Order 

13175 for Consultation, and although it does not apply to the NIGC, the NIGC does have a 

Consultation Policy that requires meaningful and timely input by Tribal officials for regulatory 

policy changes. Due to the consultation requirements set forth in the GPRA Modernization Act of 

2010 and the NIGC Consultation Policy, the NIGC engaged the public by posting the draft strategic 

plan for comment to the NIGC website (https://www.nigc.gov/commission/strategic-plan) and 

sent e-mail notices to tribal government leaders of the availability of the draft plan. The NIGC 

also conducted consultation with tribal partners and submitted the plan for input to the Office 

of Management and Budget. All comments received were considered when finalizing the 

strategic plan.

Strategic Plan Framework

The NIGC Strategic Plan FY 2022 – 2026 includes four strategic goals:

 Goal 1: Industry Integrity – Protecting the valuable tool of Indian gaming that in many 

communities creates jobs, is the lifeblood for tribal programs, and creates opportunities for tribes 

to explore and strengthen relationships with neighboring jurisdictions by ensuring the industry’s 

integrity.

 Goal 2: Preparedness – Promoting tribes’ capacity to plan for risks to tribal gaming assets 

including man-made disaster threats, pandemics, natural disaster threats, the need to modernize 

and enhance regulatory and gaming operation workforces, or public health and safety 

emergencies.

 Goal 3: Outreach – Cultivating opportunities for outreach to ensure well-informed Indian 

gaming policy development through collaborative and diverse relationships, accessible resources, 

and government-to-government consultation.

 Goal 4: Agency Accountability – Meeting the tribes’ and public’s expectation for 

administrative processes that uphold good governance practices and support efficient and 

effective decision making to protect tribal assets.

These four strategic goals focus primarily on the emphasis areas of the NIGC and articulate the 

Commission’s priorities. The associated objectives are mission- and management-focused in 
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achieving these goals. The strategies that identify actions that will be taken for accomplishing 

the goals are presented within each objective. There are set performance measures to track the 

progress in achieving each objective. The external risk factors highlight possible challenges the 

NIGC may encounter in achieving each strategic goal.

External Risk Factors

The following are key external factors that the Commission has identified which could 

significantly and adversely affect the ability of the Commission to achieve its strategic goals:

 An important element of the Commission’s vision is that Indian tribes are the primary 

beneficiaries of gaming revenues. These revenues have played a vital role in the economic 

development of Indian tribes. A sharp downturn in the local or national economy could 

adversely affect the gaming public’s amount of disposable income, thereby reducing Indian 

gaming patronage and resulting in a decrease in Indian gaming revenues.

 The Commission is comprised of a Chair and two Commissioners. To take certain regulatory 

actions, the Commission can act only if there is a quorum of two Commissioners. The sudden 

and unexpected departure of one or two Commissioners would paralyze the Commission 

until such time that new Commissioners are appointed.

 The Commission is a very small agency, with approximately 100 full-time employees. 

Extensive litigation against the Commission would result in a shift of limited agency resources, 

normally used to perform its normal regulatory oversight functions (e.g., reviews of 

management contracts and tribal gaming ordinances, drafting of Indian land opinions, etc.) 

to instead perform litigation defense work.

 As a result of the decision in Colorado River Indian Tribes v. National Indian Gaming 

Commission, 466 F.3d 134 (D.C. Cir. 2006), the Commission lacks the authority to prescribe 

minimum internal control standards for most class III gaming activities, and the Commission 

is prevented from auditing high-risk class III gaming facilities. Other future court or legislative 

decisions may further influence the scope of the Commission’s regulatory authority. 

 Commission personnel often have to drive long distances to remote locations of the country 

in order to perform site visits of tribal gaming facilities. Prolonged, severe weather conditions 

in certain parts of the country may prevent Commission personnel from conducting site visits, 

consultations, and other mission-oriented travel.

 The Commission maintains partnerships with other Federal agencies. In those circumstances 

when the Commission has to rely on these other agencies for factual information or 

documentation, the Commission may be inhibited in its ability to make timely 

determinations. Similarly, when the Commission is requested by other Federal investigatory 

agencies to postpone enforcement actions while they conduct their own criminal and/or civil 

investigations, the Commission’s regulatory activities may be delayed.

 The lack of a “Seminole fix.” The United States Supreme Court in Seminole Tribe of Florida v. 

Florida, 517 U.S. 44 (1996) concluded that Congress could not waive States’ immunity from 

suit by Indian tribes for failing to negotiate compacts in good faith, thus shifting the balance 

of power in tribal-state compact negotiations. As a result, some tribes have not achieved the 
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full benefit of the IGRA scheme. This places a greater Class II compliance oversight burden on 

the Commission.

 Events, such as the COVID pandemic and unforeseen events, that impact the Commission’s 

ability to collect fees that may limit the ability to provide appropriate resources to carry out 

statutory requirements. The COVID pandemic closed many Tribal gaming operations, which 

had a direct impact on gross gaming revenues that are used to calculate fees collected by the 

NIGC. It is expected that this is only a temporary setback as Tribal gaming operations have 

created protocols and policies in place to re-open from the COVID pandemic. The NIGC during 

this time took measures to handle the COVID pandemic including its availability to carry out 

its statutory requirements, such as an increase in online training events and online 

conferences/meetings with Tribal officials.

Performance Tracking and Reporting

The NIGC is committed to monitoring and improving its services provided under each strategic 

goal. This is accomplished through the evaluation of the performance of these services in 

achieving its objectives. Progress in achieving the performance measures is presented annually 

in the NIGC’s Budget Justifications, which includes a section for the Annual Performance Report.

Industry Integrity

Strategic Goal 1: Industry Integrity – protect the valuable tool of Indian gaming 

that, in many communities, creates jobs, is the lifeblood for 

tribal programs, and creates opportunities for tribes to explore 

and strengthen relationships with neighboring jurisdictions by 

ensuring the industry’s integrity.

Objective 1.1: Enhance awareness of actions that lead to IGRA Violations issues for all 

stakeholders in Indian gaming.

The purpose of IGRA is to shield gaming by an Indian tribe from organized crime and other 

corrupting influences, to ensure that the Indian tribe is the primary beneficiary of the gaming 

operation, and to assure that gaming is conducted fairly and honestly by both the operator and 

players. When tribes comply with IGRA, these purposes are met and the integrity of the industry 

is maintained. The NIGC aims to work, from outreach and education to investigation and 

enforcement, with tribal governments and regulatory partners to ensure compliance and 

maintain industry integrity. This requires strong partnerships within the Indian gaming industry 

to ensure that the NIGC continues to monitor the industry effectively. The NIGC will implement 

three strategies described below to achieve this objective.
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Strategies:

 Ensure stakeholders receive coordinated and consistent information on what constitutes 

a violation of IGRA.

 Build partnerships within the Indian gaming industry through a team approach to identify 

common actions that lead to IGRA Violations.

 Meet with tribal leadership, regulators, and operators to encourage technical assistance 

(“TA”) requests and use of the OGC Declination Process.

Performance measures:

 Number of outreach efforts in which NIGC Leadership and Staff discuss elements of IGRA 

violation with Tribal partners (yearly total hours: TA interactions, Region Site Visit (“RSV”)

and Site-Specific Training (“SST”) training as outreach efforts)

 Number of collaborations between NIGC Leadership and Staff with Industry experts and 

organizations (yearly total invitations to participate on panels, region meetings with 

industry experts, and meeting with industry stakeholders)

 Number of national, regional and individual meetings and training events to engage tribal 

leaders and regulatory community.

 Number of events and meetings with respect to awareness actions that lead to IGRA 

violations. 

Objective 1.2: Improve stakeholders’ ability to detect the occurrence of IGRA violations.

Ensuring compliance with gaming laws and regulations is essential to maintaining the integrity in 

the Indian gaming industry. The NIGC will implement five strategies described below to achieve 

this objective.

Strategies:

 Create new and/or update existing training courses to improve stakeholders’ ability to 

identify and prevent IGRA violations.

 Create new and improve existing tools and technology used to identify common actions 

that lead to IGRA Violations.

 Maintain and staff the OGC Declination Process utilized by tribes in draft agreements and 

contracts.

 Develop and maintain a collection and analysis of data related to IGRA Violations to 

provide decision-makers with current and relevant risk and trend information.

 Increase education and outreach opportunities related to addressing and preventing IGRA 

violations.

 Identify and utilize all resources available from NIGC to detect and prevent IGRA 

Violations.

Performance measures:

 Number of new training courses created specific to IGRA violations. 

 Number of existing training courses updated specific to IGRA violations. 
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 Number of training courses presented specific to IGRA violations. 

 Number of attendees for each type of training course offered and for each course. 

 Type and number of actions taken by NIGC for IGRA violations identified.

 Number of collaborative efforts by staff to update training courses.

Objective 1.3: Prevent, identify, disrupt and/or eliminate ongoing IGRA violations by utilizing 

the NIGC’s enforcement authority and pre-enforcement actions to ensure that the gaming fulfills 

the legislative purposes of IGRA.

In identifying compliance weaknesses through analysis of data and providing outreach to those 

tribal governments, tribal regulators and operators, it is essential, when practical, that a plan of 

action be developed to address these weaknesses before an enforcement action is initiated. By 

working with tribal governments, tribal regulators and operators, a compliance-based approach 

can be achieved as tribal regulators are able to provide alternative options and remedies. Site 

visits and the analysis of the tribal gaming operations audited financial statements, management 

letter(s), and if applicable, agreed-upon procedures (AUP) report provide opportunities to 

address compliance issues. A thorough review and reporting process ensures quality reports that 

explain what were found and why corrective actions, if any, are required. Although these 

processes are in place, there may be circumstances where an enforcement action is necessary 

and appropriate in some situations. The NIGC will implement eight strategies described below 

to achieve this objective.

Strategies:

 Maintain effective, efficient, consistent, and risk-informed oversight of licensing for key 

employee and primary management officials of tribal gaming enterprises.

 Conduct effective and efficient inspections, audits, as well as follow-up reviews, 

investigations, and enforcement as needed, to ensure that tribal gaming is conducted in 

compliance with NIGC and tribal regulatory requirements.

 Proactively solicit and efficiently review unexecuted gaming related contracts and 

agreements to identify, prevent and address potential IGRA and NIGC regulation 

violations. 

 Analyze audited financial statements and AUP reports submitted for potential violations 

or conditions that create a risk of an IGRA violation.

 Develop and maintain strong working relationships with tribal regulators.

 Implement and enforce Indian gaming laws consistently and investigate and take actions 

to address potential violations of Indian gaming laws.

 Conduct analysis to determine high risk areas and develop, and deliver training to educate 

and prevent recurring findings. 

Performance Measures:

 Number of fingerprint based criminal history reports requested and disseminated to tribal 

regulators to help determine a gaming licensee’s eligibility. 
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 Number of key employee/primary management official licensing submissions received, 

reviewed and processed, to include total number of objections issued. 

 Number of site visits conducted annually, the number of potential IGRA violations 

identified, and the method used to remedy the findings.

 Number of Internal Control Assessments (ICA), Internal Audit Reviews (IAR), GAAP 

Reviews (GAR) and NIGC Fee Reviews (NFR) conducted annually to identify risk and 

potential IGRA violations, to include the annual remediation rate of any issues identified. 

 Number of Investigative Audit (IVAs) completed annually, to include issues identified 

and results.

 Number of audited and reviewed financial statements analyzed annually, to include a 

number of potential IGRA violations and manner in which they were resolved.

 Number of potential violations or conditions that create a high risk of non-compliance 

with federal regulations.

 Number of outreach efforts with Tribal Leaders and Tribal Gaming Regulatory Authority 

(TGRA) to develop and maintain a strong working relationship with tribal leaders and 

regulators. (add outreach to TA spreadsheet and report totals at year-end)

 Number of technical assistance inquiries submitted by stakeholders seeking clarification 

or acknowledgment related to the stakeholders’ understanding or implementation of 

IGRA requirements. 

 Number of contracts and agreements submitted, reviewed, resolved, or referred 

through the OGC Declination Process. 

 Number of Letters of Concern issued and resolved, to include manner of resolution. 

 Number of IGRA violations reported by external parties and the manner of resolution. 

 Number of risk-based training annually to educate and prevent recurring findings. 

Preparedness

Strategic Goal 2: Preparedness – Promoting tribes’ capacity to plan for risks to 

tribal gaming assets including man-made disaster threats, 

pandemics, natural disaster threats, the need to modernize and 

enhance regulatory and gaming operation workforces, or public 

health and safety emergencies.

Objective 2.1: Provide current and up to date training and resources to improve stakeholder’s 

awareness and understanding of preparedness for risks to tribal gaming assets, the laws and 

regulations designed to foster this preparedness by ensuring tribes have the most current 

information, and how to tribes’ can locate preparedness resources. 
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The NIGC works to educate tribal governments, tribal regulators, and operators on Indian gaming 

law and regulations so stakeholders can make well-informed decisions. The NIGC will implement 

six strategies described below to achieve this objective.

Strategies:

 Conduct training events to provide for a consistent policy approach.

 Maintain a library of training material for agency staff to use to provide consistency in 

presentations.

 Continue to support the development and delivery of training courses essential to 

maintaining a highly effective workforce.

 Strengthen the impact and effectiveness of training by fostering best practices, facilitating 

partnerships, and identifying gaps in training.

 Foster and develop relationships with other Federal Partners, Tribal Regulatory Partners 

and Non-Governmental Organizations, in the delivery of trainings where the

aforementioned groups provide subject matter expertise. 

 Analyze trainings provided through the use of both formal and informal methods to 

measure the effectiveness of trainings provided

Performance Measure: 

 Number of training events conducted, number and type of specific training course 

conducted, attendance by event and course. 

 Number of training courses developed, revised, and, to include information on staff and 

external partners responsible for development and delivery.

 Number, type and duration of professional development course completed by agency 

staff. 

 Number, type, and occasions of use of training courses available through NIGC resources 

for download or viewing. 

 

Objective 2.2: Keep informed about developments in gaming, including best practices and 

emerging trends, utilize the knowledge to raise awareness of these developments.

The NIGC is committed to making the best use of our resources and assisting our stakeholders in 

providing information on industry trends and best practices. We will conduct research, data 

collection, perform analysis, and disseminate information to promote awareness of 

developments in the gaming industry. We will encourage greater sharing of best practices. The 

NIGC will implement three strategies described below to achieve this objective.

Strategies:

 Research industry trends and best practices.

 Identify or develop agency staff subject matter experts.

 Disseminate information to tribes, tribal regulators and operators.
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Performance Measures:

 Number of professional development training opportunities NIGC subject matter experts

participated in to enhance specialized skills to maintain subject matter expertise.

 Number of NIGC internal information sharing meetings. 

 Number of external meetings or engagement disseminating preparedness resources.

 Number of events, meetings or other engagement by NIGC and industry experts to discuss 

developments in gaming, best practices and emerging trends. 

Objective 2.3: Support and ensure tribe’s construction and maintenance of the gaming facility, 

and the operation of that gaming is conducted in a manner which adequately protects the 

environment and the public health and safety. 

The NIGC is committed to Environment, Public Health, and Safety (EPHS) efforts of tribes. The 

NIGC will verify on an ongoing basis that gaming facilities are constructed and operated in a 

manner the adequately protects the environment, public health and safety in accordance with 

IGRA, NIGC regulations and approved tribal gaming ordinances and ensure tribal monitoring and 

licensing protocols are adequate to support the issuance of new or renewed licenses. The NIGC 

will implement three strategies described below to achieve this objective.

Strategies: 

 Ensure tribes comply with facility license submissions and attestations. 

 Provide technical assistance to tribes for the development or improvement of tribal 

protocols related to public health and safety. 

 Act swiftly to educate and support tribes and pursue enforcement actions when 

necessary, when the environment or public health and safety are at risk due to conditions 

developing or ongoing at a tribally licensed gaming facility. 

Performance Measures: 

 Number of facility license submissions made that were on time and complete. 

 The number of EPHS resources developed and deployed. 

 Number of training and technical assistance provided. 

 Number of actions taken by NIGC to address potential EPHS concerns or violations. 

Objective 2.4: Support tribe’s preparedness to identify, protect, detect, respond and recover

from Cybersecurity threats and attacks. 

The NIGC works to educate gaming tribes with the knowledge, tools, and capabilities that may 

be needed to maintain or improve their cybersecurity posture. The NIGC continues to develop a 

variety of tools that provide targeted and meaningful technical assistance and information 

sharing to gaming tribes. The NIGC will implement two strategies described below to achieve this 

objective.

Strategies: 
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 Provide onsite or site specific technical assistance to identify and mitigate cybersecurity 

weaknesses or potential threats. 

 Establish and maintain a cybersecurity task force or working group responsible for making 

recommendations to the Commission regarding cybersecurity and for the development 

of cyber security response protocol. 

Performance Measures: 

 Number of Information Technology Vulnerability Assessments (ITVA) requested, 

completed, to include the number of vulnerabilities identified. 

 Number of tribal-related cybersecurity attacks reported, responded to and their 

outcomes. 

 Number and type of Tech Alerts and Bulletins issued by the agency.

 Number of trainings and resources provided. 

 Number and type of recommendations to the Commission by the cybersecurity task force. 

 Number of and type of actions taken to modernize NIGC regulations. 

Outreach

Strategic Goal 3: Outreach – Cultivating opportunities for outreach to ensure 

well-informed Indian gaming policy development through 

collaborative and diverse relationships, accessible resources, 

and government-to-government consultation

Objective 3.1: Enhance relationships and increase engagement with gaming tribes.

The NIGC works to reach out to gaming tribes with the knowledge, tools, and capabilities that 

may be needed to make better informed decisions. The NIGC is developing a variety of tools that 

provide targeted and meaningful technical assistance and information sharing to gaming tribes. 

The NIGC will implement three strategies described below to achieve this objective.

Strategies:

 Increase engagement between the agency and gaming tribes.

 Expand access to training and technical assistance for gaming tribes.

 Increase targeted outreach activities and digital training materials in order to engage 

gaming tribes.

Performance Measures:
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 Percent change (increase or decreases) in attendance of NIGC training events and 

courses, with a comparison to the previous year. 

 Number of virtual training events conducted, topics and attendance. 

 Number of in-person training events conducted, topics and attendance. 

 Number of site-specific training events conducted, topic and attendance.

 Number of digital/on-line training materials available, topic and downloads or 

attendance. 

 Number and manner of invitations issued to stakeholders per event compared to 

attendance. 

 Number of documented outreach methods, areas of improvement identified and new 

outreach methods developed. 

Objective 3.2: Review agency training, technical assistance and regulations to foster improved 

outreach.

The NIGC conducts outreach activities through various channels, such as issuing bulletins 

targeted to the Indian gaming industry; providing training events throughout the Agency’s 

regional office coverage; delivering speeches and presentations on Indian gaming and updates; 

and participating in meetings and discussions with tribal governments, tribal regulators, and 

operators. The NIGC has taken steps to upgrade and enhance its website to better meet the 

needs of our stakeholders and to allow more access to the NIGC’s tools and resources. In order 

to provide better outreach and to provide timely and useful information, the NIGC will expand 

its outreach efforts. The NIGC will implement three strategies described below to achieve this 

objective.

Strategies:

 Conduct a study of the agency’s regulations.

 Support demonstration or pilot projects for improving outreach to gaming tribes.

 Strengthen stakeholder outreach.

Performance measures:

 Number of agency regulations identified for amendment and number amended following 

tribal consultation. 

 Number of new training courses created. 

 Number of existing training courses updated. 

 Number of training courses presented. 

 Number of attendees for each type of training course offered and for each course. 

 Number of Technical Assistance events outside of scheduled training to include tribe, 

topic, staff, time, and outcome. 

 Number of NIGC staff involved in presenting training and resource material. 

Agency Accountability
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Strategic Goal 4: Agency Accountability – Meeting the tribes’ and public’s 

expectation for administrative processes that uphold good 

governance practices and support efficient and effective 

decision making to protect tribal assets.

Objective 4.1: Monitor employee work to provide superior service and to promote continuous 

improvements to routine processes and services.

NIGC employees must strive to provide superior service by delivering information to our 

stakeholders in an efficient manner. Our employees are committed to providing high-quality 

accurate decisions. To enhance these processes, we must hold employees accountable and 

provide timely and effective feedback. We must provide opportunities for employees to learn, 

develop, and grow, so that talents are supported and utilized. The NIGC will implement six

strategies described below to achieve this objective.

Strategies:

 Provide feedback to employees during work processes.

 Provide support by supervisors and managers to manage employee workload.

 Simplify processes and procedures for operational improvement by removing duplicative 

tasks or unnecessary steps.

 Use evidence-based decision-making.

 Initiate an annual review of agency policies and procedures for updates as necessary.

 Develop a training/mentoring program for new and current employees to enhance 

employee skills and efficiency.

 Gather workforce data, such as that provided under the Federal Employee Viewpoint 

Survey (FEVS) to plan for change by analyzing the data.

 Engage the workforce in regular listening sessions to obtain data on implementation and 

feedback on continuous improvements to decision-making processes.

Performance Measures:

 Number of quarterly or mid-year reviews conducted by established deadlines compared 

to previous year. 

 Number of instances where workload was adjusted to better accommodate the needs of 

staff. 

 Number and type of duplicative efforts identified and removed. 

 Number of policies/procedures/protocol identified for annual review, the number 

reviewed, number amended, number of new policies created, and the number approved.

 Number of new employees who completed new hire training and the average evaluation 

rating given to the program by the attendee. 

 Number of employees who completed professional development and required training.
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 Number employee engagement opportunities provided. 

 Number positive changes made to improve FEVS responses. 

Objective 4.2: Increase transparency and accountability in financial management for the 

Agency.

The NIGC continues to effectively and efficiently manage its financial resources through the use 

of a secondary accounting system in addition to the outsourced accounting function. Currently, 

the secondary accounting system supplements the main system but has limited functionality. 

Both systems are necessary to provide an accurate budget and financial reports. Improving 

effectiveness and efficiency of financial and project management are essential to delivering 

mission critical activities and services on time and within budget. Providing timely budget and 

financial reports to senior leadership ensures better decision-making. The NIGC will implement 

four strategies described below to achieve this objective.

Strategies:

 Effectively allocate and prioritize resources by improving the budget formulation process

and document this process.

 Ensure efficient and effective management of financial resources through a balanced 

budget.

 Continue to improve the reliability of the secondary accounting system.

 Continue to provide a budget to all managers and compare budgeted to actual.

Performance Measures:

 Number of program budgets reviewed to track the ratio of budgeted to actual expense to 

determine if budgets are effectively allocated.

 Number of engagements where NIGC shares information about the Agency’s financial 

resources with tribes and obtain tribal input on this information where it could improve 

efficiencies;

 Number of annual communications to inform tribes of Agency financial resources (Gross 

Gaming Revenue and Agency Budget).

 Number of annual budgets submitted by deadlines.

 Number of budget procedures identified and updated for improved uniformity.

Objective 4.3: Strengthen information and communication systems to support timely decision 

making and the dissemination of information to all agency staff.

Improving and expanding on internal communications allows a platform for agency employees 

to collaborate and share information across the agency, between regional and satellite offices 

and headquarters. The NIGC will implement four strategies described below to achieve this 

objective.

Strategies:
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 Ensure consistency in services by improving communication with agency staff.

 Continue to strengthen collaborations between internal operations to ensure tribes have 

adequate guidance and technical assistance.

 Develop and maintain the tools and technology required to effectively, efficiently, and 

securely disseminate data and information internally.

 Improve employee intranet to provide timely information to agency staff.

Performance Measures:

 Number of routine, weekly and/or monthly internal collaboration meetings. 

 Number of intranet improvement meetings attended and provide comments for 

improvement.

 Number of Intranet updates completed weekly and reminder emails sent to all staff 

reinforcing availability of information in a timely manner. 

 Percentage of staff with access to communication platforms (e.g. email, intranet, 

Microsoft Teams, etc.

 Number of connection issues are identified, and attempt at correction is made within 24 

hours.

Objective 4.4: Strengthen agency provided technology and infrastructure services to improve 

overall operational efficiencies throughout the agency.

The NIGC is committed to using modern tools to improve efficiencies throughout the agency by 

leveraging new technologies and improving agency IT operations and delivery of IT infrastructure

services. The NIGC continuously works to identify and replace legacy systems and applications. 

Applications and systems no longer providing efficient mission-enabling services or approaching 

end of life become a liability for the agency resulting in a decrease in employee productivity and 

agency output. The need for secure, high performing and reliable internal technology 

infrastructure services is critical in enabling the agency to support its mission. The NIGC will 

implement four strategies described below to achieve this objective.

Strategies:

 Focus on leveraging and adopting technologies to increase process automation.

 Expand the use of agency information technology to improve service and increase 

efficiency.

 Continuously monitor and remediate IT security and operational vulnerabilities 

 Assess agency applications for value and use.

Performance Measures:

 Percentage of staff that successfully completed required IT security trainings.

 Annually Inquire with Tribal partners for input and recommendations for efficiency or 

new technologies. Number of technology processes or applications identified for 

improvement or suggested implementation.
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 Annually, assess repeat tasks involving new technologies implemented and ensure 

policies reflect current duties and operations.

 Number of unscheduled system outages reported annually.