§542.10 What are the minimum internal control standards for keno? 

(a) Computer applications. For any computer applications utilized, alternate 

documentation and/or procedures that provide at least the level of control described by 

the standards in this section, as approved by the Tribal gaming regulatory authority in 

writing, will be acceptable. Alternative computer applications that cannot comply 

with this part shall require variance concurrence in accordance with §542.18.

Justification: Revision is to clarify that computer applications that cannot comply with 

the MICS they are intended to replace must be submitted in accordance with the variance 

regulation 542.18. The phrase “in writing” is added for consistency with other sections in 

this Part.

(b) Game play standards. (1) The computerized customer ticket shall include the gaming 

operation name, city, state or tribe, date, game number, ticket sequence number, station 

number or writer identification number, and conditioning (including multi-race if 

applicable). 

Justification: Revision is requiring that the identity of the issuer be more clearly defined 

and to establish an alternative to the station number requirement. 

(2) The information on the ticket shall be recorded on a restricted transaction log or 

computer storage media concurrently with the generation of the ticket. 

(3) Keno personnel shall be precluded from having access to the restricted transaction log 

or computer storage media. 

(4) When it is necessary to void a ticket, the void information shall be inputted in the 

computer and the computer shall document the appropriate information pertaining 

to the voided wager (e.g., void slip is issued or equivalent documentation is 

generated).

When it is necessary to void a ticket, the following shall apply:

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(i) For computer voids, the void information shall be input in the computer and the 

computer shall document, at a minimum, the ticket number, date/time of the void 

and the name or other identifier of the employee completing the void;

(ii) A void slip or equivalent documentation shall be generated;

(iii) For manual voids, the void designation, date, and time shall be written/stamped 

on the original ticket. A supervisor and the writer of the ticket must sign at the time 

of the voiding.

Justification: Revision is intended to more clearly define the controls governing the 

voiding of a keno ticket. 

(5) Controls shall exist to prevent the writing and voiding of tickets after a game has been 

closed and after the number selection process for that game has begun. 

(6) The controls in effect for tickets prepared in outstations (if applicable) shall be 

identical to those in effect for the primary keno game. 

(c) Rabbit ear or wheel system. (1) The following standards shall apply if a rabbit ear or 

wheel system is utilized: 

(i) A dedicated camera shall be utilized to monitor the following both prior to, and 

subsequent to, the calling of a game:

(A) Empty rabbit ears or wheel;

(B) Date and time;

(C) Game number; and

(D) Full rabbit ears or wheel.

(ii) The film of the rabbit ears or wheel shall provide a legible identification of the 

numbers on the balls drawn.

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Justification: Revision is moving surveillance standards to the surveillance sections 

542.23 Tier A, 542.33 Tier B and 542.33 Tier C. 

(i) (iii) Keno personnel shall immediately input the selected numbers in the computer 

and the computer shall document the date, the game number, the time the game was 

closed, and the numbers drawn. 

(ii) (iv) The Tribal gaming regulatory authority, or the gaming operation as approved 

by the Tribal gaming regulatory authority, shall establish and the gaming operation 

shall comply with procedures that prevent unauthorized access to keno balls in play by 

one individual. 

Justification: Revision is intended to delete the requirement that the TGRA approve or 

that the required controls be submitted to the regulator for approval, since the authority to 

review and approve already exists at Section 542.3. Furthermore, the standard is being 

revised to require two individuals to be present when keno balls in play are being 

accessed. 

(iii) (v) Back-up keno ball inventories shall be secured in a manner to prevent 

unauthorized access by one individual. 

Justification: Revision is intended to establish requirement that the accessing of keno 

balls in secured storage requires two individuals to be present. 

Comment (December): Recommend using either “by one individual” or “by a 

single individual” in both (iii) and (iv) 

Response: Agree. Revised to “by a single individual” 

Comment (December): I do not understand why the keno balls, which are 

considered to be sensitive items, are not so sensitive as to require TGRA 

approval of the method by which they are secured. 

Response: The Committee has agreed that including the “TGRA approval” 

requirement sporadically throughout the document tends to encourage the 

erroneous conclusion that TGRA approval cannot be required absent such 

wording. 

Proposed revision as a result of December comments:

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(ii) (iv) The Tribal gaming regulatory authority, or the gaming operation as approved 

by the Tribal gaming regulatory authority, shall establish and the gaming operation 

shall comply with procedures that prevent unauthorized access to keno balls in play by a 

single individual. 

(iii) (v) Back-up keno ball inventories shall be secured in a manner to prevent 

unauthorized access by a single individual. 

(vi) The Tribal gaming regulatory authority, or the gaming operation as approved 

by the Tribal gaming regulatory authority, shall establish and the gaming operation 

shall comply with procedures for inspecting new keno balls put into play as well as 

for those in use.

(v) Keno balls shall be inventoried and inspected prior to being placed into play to 

ensure that all numbers are accounted for and no defects are noted that would 

potentially interfere or influence the random selection process. The inspection shall 

be performed by two individuals and be documented, as follows:

(A) Date and time;

(B) Inspection results;

(C) Investigation of any exceptions noted; and

(D) Signatures of the two individuals completing the inspection.

Justification: Revision is intended to remove the requirement that the TGRA create or 

approve the controls created in response to this standard and to more precisely stipulate 

the minimum inspection procedures that must be followed. 

(2) [Reserved] 

(d) Random number generator. (1) The following standards shall apply if a random 

number generator is utilized: 

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(i) The random number generator shall be linked to the computer system and shall 

directly relay the numbers selected into the computer without manual input. 

(ii) Keno personnel shall be precluded from access to the random number 

generator.

Justification: Revision is deleting a control that is already addressed in the IT section. 

(ii) The computer system shall create a record that includes the following:

(A) Date;

(B) Game number;

(C) Time the game was closed; and

(D) Numbers drawn.

Justification: Revision is defining the minimum data that must be captured by the 

computer system. 

(2) [Reserved] 

Comment (December): Recommend including language restricting access to 

the random number generator to authorized personnel. 

Comment (December): Recommend cross-referencing restriction to 542.16 (a) 

IT standards. 

Response: Agree. Revised accordingly. 

Proposed revision as a result of December comments:

(2) [Reserved] Access to the random number generator shall be restricted to 

authorized personnel. Refer 542.16 (a). 

(e) Winning tickets. Winning tickets shall be verified and paid as follows: 

(1) The sequence number of tickets presented for payment shall be inputted into the 

computer, and the payment amount generated by the computer shall be given to the 

customer. 

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(2) The Tribal gaming regulatory authority, or the gaming operation as approved by 

the Tribal gaming regulatory authority, shall establish and the gaming operation 

shall comply with procedures that preclude payment on tickets previously presented for 

payment, unclaimed winning tickets (sleepers) after a specified period of time, voided 

tickets, and tickets that have not been issued yet. 

Justification: Revision is deleting the requirement that the TGRA create or approve 

controls to comply with this standard. Such authority is already recognized at Section 

542.3. 

Comment (December): Recommend reinstating requirement for TGRA 

approval with the following wording “The gaming operation with the approval 

of the TGRA.” 

Comment (December): A lengthy discussion took place regarding hypothetical 

situations in which “tickets that have not been issued yet” might exist, all of 

which were rejected. It was recommended that the wording be deleted. 

Response: Agree. Revised accordingly. 

Proposed revision as a result of December comments:

(2) The gaming operation with the approval of the TGRA Tribal gaming regulatory

authority, or the gaming operation as approved by the Tribal gaming regulatory 

authority, shall establish and the gaming operation shall comply with procedures that 

preclude payment on tickets previously presented for payment, unclaimed winning tickets 

(sleepers) after a specified period of time, and voided tickets. and tickets that have not 

been issued yet. 

(3) All payouts shall be supported by the customer (computer-generated) copy of the 

winning ticket (payout amount is indicated on the customer ticket or a payment slip is 

issued). 

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(4) A manual report or other documentation shall be produced and maintained 

documenting any payments made on tickets that are not authorized by the computer. 

Supervisory authorization, which shall be documented, is required prior to 

payment.

Justification: Revision is establishing the requirement that payment on tickets that were 

not computer authorized require supervisory approval. 

(5) Winning tickets over a specified dollar amount (not to exceed $10,000 for Tier C

locations with more than $5 million annual keno write and $3,000 for all other Tier A 

and B locations) shall also require the following: 

(i) Approval of management personnel independent of the keno department, evidenced by 

their signature; 

(ii) Review of the video recording and/or digital record of the rabbit ears or wheel to 

verify the legitimacy of the draw and the accuracy of the draw ticket (for rabbit ear or 

wheel systems only); 

(iii) Comparison of the winning customer copy to the computer reports; 

(iv) Regrading of the customer copy using the payout schedule and draw information; 

and 

(v) Documentation and maintenance of the procedures in this paragraph. 

Justification: Revision is intended to grant greater latitude to smaller gaming operations 

regarding the approval of large keno payouts. 

(6) When the keno game is operated by one person, all winning tickets in excess of an 

amount to be determined by management (not to exceed $1,500) shall be reviewed and 

authorized by a keno supervisor, who did not write the ticket, or a person independent 

of the keno department. 

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Justification: Revision is intended to grant greater latitude to management in 

determining minimum payout requirements for a game operated by only one person. 

(f) Check out standards at the end of each keno shift. (1) If the computer system 

indicates the amount of net cash that should be in each writer station, the keno 

supervisor must have access to the information.

Justification: Revision is intended to recognize that, if the keno department’s computer 

system reconciles the writer cash drawer, the keno supervisor should have access to the 

information in conjunction with receiving the cash turn-in from the writers. 

(2) For each writer station, a cash summary report (count sheet) shall be prepared that 

includes: 

(i) Computation of net cash proceeds for the shift and the cash turned in, inclusive of any 

variances between the cash turn-in and the amount of net cash the computer system 

indicated; 

(ii) The procedures required by (i) are also applicable to transfers of banks 

occurring between writers at a writer station during a shift; and 

Justification: Revision is intended to establish the requirement that variances between 

the actual cash turn-in and the computer report must be documented. Revision is also 

recognizing that writer banks may be transferred from one person to another during a 

shift; however, the accounting for the bank must occur in conjunction with the transfer of 

the accountability. 

(ii) (iii) Signatures of two employees who have verified the net cash proceeds for the shift 

and the cash turned in. Unverified transfers of cash and/or cash equivalents are 

prohibited. (Revised August 12, 2005) 

(g) Promotional payouts or awards. (1) If a gaming operation offers promotional payouts 

or awards, the payout form/documentation shall include the following information: 

(i) Date and time; 

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(ii) Dollar amount of payout or description of personal property (e.g., jacket, toaster, car, 

etc.), including fair market value; 

(iii) Type of promotion; and 

(iv) Signature of at least one employee authorizing and completing the transaction, unless 

above (e)(5)(i) is applicable. 

Justification: Revision is intended to recognize that if the promotional payout exceeds 

the minimum threshold established by the referenced standard additional payout 

documentation and authorization requirements will be applicable. 

(2) [Reserved] 

(h) Standards for statistical reports. (1) Records shall be maintained that include win and 

write by individual writer for each day. 

(2) Records shall be maintained that include win, write, and win-to-write hold percentage 

for: 

(i) Each shift; 

(ii) Each day; 

(iii) Month-to-date; and 

(iv) Year-to-date or fiscal year-to-date as applicable. 

(3) A manager independent of the keno department shall review keno statistical data on at 

least a monthly basis and investigate any large or unusual statistical variances. 

(4) At a minimum, investigations shall be performed for statistical percentage 

fluctuations from the base level for a month in excess of +/-3%. The base level shall 

be defined as the gaming operation's win percentage for the previous business year 

or the previous twelve (12) months.

Justification: Revision is deleting standard considered not to be relevant to the game of 

keno. 

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(4) Such investigations shall be completed no later than 30 days after generation of 

the month-end report, documented, maintained for inspection, and provided to the 

Tribal gaming regulatory authority upon request. 

Justification: Revision is establishing the requirement that investigation of unusual 

fluctuations must occur within a specified time period. 

(i) System security standards. 

(1) All keys (including duplicates) to sensitive computer hardware in the keno area 

shall be maintained by a department independent of the keno function.

(2) Personnel independent of the keno department shall be required to accompany 

such keys to the keno area and shall observe changes or repairs each time the 

sensitive areas are accessed.

Justification: Revision is deleting standards better suited to the IT section of the MICS. 

(i) Documentation standards. (1) Adequate documentation of all pertinent keno 

information shall be generated by the computer system. 

(2) This documentation shall be restricted to authorized personnel. 

(3) The documentation shall include, at a minimum: 

(i) Ticket information (as described in paragraph (b)(1) of this section); 

(ii) Payout information (date, time, ticket number, amount, etc.); 

(iii) Game information (number, ball draw, time, etc.); 

(iv) Daily recap information by shift, if less than 24 hours, and day, including: 

(A) Write; 

(B) Payouts; and 

(C) Gross revenue (win); 

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(v) System exception information, including: 

(A) Voids; 

(B) Late pays; and 

(C) Appropriate system parameter information (e.g., changes in pay tables, ball draws, 

payouts over a predetermined amount, etc.); and

(vi) Personnel access listing, including:

(A) Employee name or employee identification number; and

(B) Listing of functions employee can perform or equivalent means of identifying 

same.

Justification: Revision is intended to more clearly define the reporting period and to 

strike standards better suited to the IT section. 

Comment (December): Because the word “daily” modifies the word “recap”, 

including the words “and day” is redundant. Recommend striking “and day”. 

Comment (December): A shift, by definition, cannot exceed 24 hours. If a 

shift equals twenty-four hours, then it constitutes a day. Therefore, the phrase 

“if less than 24 hours” is unnecessary. Recommend striking the phrase. 

Response: Agree. Modified accordingly. 

Proposed revision as a result of December comments:

(i) Documentation standards. (1) Adequate documentation of all pertinent keno 

information shall be generated by the computer system. 

(2) This documentation shall be restricted to authorized personnel. 

(3) The documentation shall include, at a minimum: 

(i) Ticket information (as described in paragraph (b)(1) of this section); 

(ii) Payout information (date, time, ticket number, amount, etc.); 

(iii) Game information (number, ball draw, time, etc.); 

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(iv) Daily recap information by shift including: 

(A) Write; 

(B) Payouts; and 

(C) Gross revenue (win); 

(v) System exception information, including: 

(A) Voids; 

(B) Late pays; and 

(C) Appropriate system parameter information (e.g., changes in pay tables, ball draws, 

payouts over a predetermined amount, etc.); and

(vi) Personnel access listing, including:

(A) Employee name or employee identification number; and

(B) Listing of functions employee can perform or equivalent means of identifying 

same.

(j) Contests/Tournaments (1) All contest/tournament entry fees and prize payouts 

shall be summarized on a cash accountability document on a daily basis.

(2) When contest/tournament entry fees and payouts are transacted, the 

transactions shall be recorded on a document which contains; 

(i) Customer’s name;

(ii) Date of entry/payout;

(iii) Dollar amount of entry fee/payout (both alpha and numeric, or unalterable 

numeric) and /or nature and dollar value of any non-cash payout;

(iv) Signature of individual completing transaction attesting to the receipt or 

disbursement of the entry fee/payout with the customer; and

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(v) Name of contest/tournament.

(3) The contest/tournament entry fees and payouts shall be summarized and posted 

to the accounting records on at least a monthly basis.

(4) Current contest/tournament rules shall be included on all entry 

forms/brochures and prominently displayed or available for customer review at the 

gaming operation. The rules shall include at a minimum:

(i) All conditions customers must satisfy to qualify for entry, and advancement 

through, the contest/tournament;

(ii) Specific information pertaining to any single contest/tournament, inclusive of the 

following: 

(A) Dollar amount of money placed into the prize pool;

(B) The distribution of funds based on specific outcomes; and

(C) If applicable, the name of the organization or individual (charity conducting the 

game in conjunction with the gaming operation).

(iii) The distribution of funds based on specific outcomes.

(5) Results of current contests/tournaments shall be recorded and available for 

participants to review, including the name of the event, date(s) of event, total 

number of entries, dollar amount of entry fees, total prize pool, and the dollar 

amount paid for each winning category. The gaming operation shall establish a 

reasonable period to retain the information, which shall be subject to Tribal gaming 

regulatory authority concurrence. If the contest/tournament is free (customer does 

not pay to enter), the number of entries, dollar amount of the entry fees and total 

prize pool is not required.

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Justification: Revision is establishing controls relevant to contests and tournaments 

involving the keno department. 

(k) Promotional giveaways and drawings. (1) The conditions for participating in 

promotional events, including drawings and giveaway programs, shall be 

prominently displayed or available for customer review at the gaming operation.

(2) Prizes from promotional drawings and giveaway programs that are equal to or 

greater than $600 shall be documented as follows:

(i) Date and time;

(ii) Dollar amount or description of personal property (e.g., jacket, toaster, car, etc.), 

including fair market value;

(iii) Type of promotion; and

(iv) Signature of at least the following number of employees verifying, authorizing, 

and completing the transaction with the patron:

(A) Two employee signatures for all prizes of $100 or more, unless below (B) is 

applicable; 

(B) If a computerized system validates and prints the dollar amount of the prize on 

a computer generated form, two employee signatures are required for prizes of $600 

or more; and

(C) Non-keno employees may perform the payout transaction as long as the 

required signatures are those of the employees completing the payout transaction 

with the customer.

(v) Customer name if necessary to make the payout and the amount is equal to or 

more than $600.

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(3) Prizes from promotional drawings and giveaway programs that are less than 

$100 require documentation to be created to support the bank accountability, which 

could be a line item on a cage or keno accountability document (e.g. “43 $10 keno 

cash giveaway coupons = $430). 

Justification: Revision is establishing the requirement that the rules governing 

promotional drawings and giveaway programs be available to the public. Furthermore, 

revision is establishing the standards relevant to the authorization and documentation of 

such payouts. The proposed revision considers the risk associated with computer-assisted 

transactions being mitigated and therefore, the minimum internal controls are less 

stringent. 

(l) Computerized player tracking systems requirements. (1) The addition of points 

to player tracking accounts other than through an automated process related to 

actual play must be sufficiently documented, including substantiation of reasons for 

increases and authorization by supervisory personnel of the player tracking, 

promotions, or keno department. Random verification by account/auditing 

personnel on at least a quarterly basis is required;

(2) Employees who redeem points for customers shall not have access to inactive or 

closed accounts without supervisory authorization. Documentation of such access 

and approval must be prepared and maintained;

(3) Customer identification shall be required when redeeming points without a 

player tracking card;

(4) Changes to the player tracking system parameters, such as point structures and 

employee access, shall be performed made by supervisory personnel independent of 

the keno department. Alternatively, changes to player tracking system parameters 

may be performed by keno supervisory personnel if sufficient documentation is 

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generated and the propriety of changes is randomly verified by personnel 

independent of the keno department on a quarterly basis.

(5) Rules and policies for player tracking accounts including the awarding, 

redeeming and expiration of points shall be prominently displayed or available for 

customer review at the gaming operation.

Justification: Revision is establishing controls relevant to computerized player tracking 

systems of the keno department. 

542.10 (m) Keno audit standards has been moved to proposed Revenue Audit 542.50 (c) 

(m) Keno audit standards. (1) The keno audit function shall be independent of the 

keno department.

(2) At least annually, keno audit shall foot (add up) the write on the restricted copy 

of the keno transaction report for a minimum of one shift and compare the total to 

the total as documented by the computer.

(3) For at least one shift every other month, keno audit shall perform the following:

(i) Foot the customer copy of the payouts and trace the total to the payout report; 

and

(ii) Regrade at least 1% of the winning tickets using the payout schedule and draw 

ticket.

(4) Keno audit shall perform the following:

(i) For a minimum of five games per week, compare the video recording and/or 

digital record of the rabbit ears or wheel to the computer transaction summary. 

For rabbit ear systems that directly interface with the keno computer system, 

compare the recording of the rabbit ears to the keno transaction report for a 

minimum of ten games per month. When manual ball draw results changes are 

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made to the direct interface, all changes shall be audited and compared to the rabbit 

ear recordings;

Comment (December): Recommend adding “or wheel” following “rabbit 

ears” where it does not currently appear.

Comment (December): Recommend adding “manual overrides” to clarify 

“changes” and rewording the rest of the second sentence to clarify 

meaning. 

Response: Agree. Revised accordingly.

Proposed revision as a result of December comments:

(i) For a minimum of five games per week, compare the video recording and/or 

digital record of the rabbit ears or wheel to the computer transaction summary. 

For rabbit ear or wheel systems that directly interface with the keno computer 

system, compare the recording of the rabbit ears or wheel to the keno transaction 

report for a minimum of ten games per month. When manual changes (manual 

overrides) are made to the direct interface ball draw results, all changes shall be 

audited and compared to the rabbit ear or wheel recordings;

(ii) Compare net cash proceeds to the audited win/loss by shift and investigate any 

large cash overages or shortages (i.e., in excess of $25.00);

(iii) Review and regrade all winning tickets greater than or equal to $1,500, 

including all forms that document that proper authorizations and verifications were 

obtained and performed. Trace customer copies to the computer payout report;

Comment (December): Recommend replacing “trace” with “compare”.

Response: Agree. Revised accordingly.

Proposed revision as a result of December comment:

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(iii) Review and regrade all winning tickets greater than or equal to $1,500, 

including all forms that document that proper authorizations and verifications were 

obtained and performed. Compare customer copies to the computer payout report;

(iv) Review the documentation for payout adjustments made outside the computer 

and investigate large and frequent payments;

(v) Review personnel access listing for inappropriate functions an employee can 

perform;

(v) Review system exception information on a daily basis for propriety of 

transactions and unusual occurrences including changes to the personnel access 

listing, but not limited to, void authorizations, late pays, and parameter alterations;

(vi) If a random number generator is used, then at least weekly review the 

numerical frequency distribution for potential patterns, including missing numbers, 

during the previous four-week period; and

Comment (December): Review of numerical frequency distribution on a 

weekly basis is excessive. Recommend changing to monthly and deleting 

“during the previous four week period”.

Response: Agree. Revised accordingly

Proposed revision as a result of December comment:

(vi) If a random number generator is used, then at least weekly monthly review the 

numerical frequency distribution for potential patterns, including missing numbers

and

(vii) If a rabbit ear system is used and the keno computer system generates a drawn 

number frequency report, then at least weekly the numerical frequency distribution 

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shall be reviewed for potential patterns, including missing numbers, during the 

previous four-week period;

Comment (December): Recommend adding “or wheel” following 

“rabbit ears”.

Comment (December): Review of numerical frequency distribution 

on a weekly basis is excessive. Recommend changing to monthly.

Comment (December): Recommend changing “generates” to “is 

capable of generating”.

 

 Response: Agree. Revised accordingly

Proposed revision as a result of December comments:

(vii) If a rabbit ear or wheel system is used and the keno computer system is capable 

of generating a drawn number frequency report, then at least monthly the 

numerical frequency distribution shall be reviewed for potential patterns, including 

missing numbers;

(viii) Accounting/audit personnel shall review all not-in-computer voids for void 

designation and proper supervisory approval; and

(ix) Investigate and document results of all noted improper transactions or unusual 

occurrences.

(5) When the keno game is operated by one person:

(i) The customer copies of all winning tickets in excess of $100 $500 and at least 5% 

10 winning tickets less than or equal to $500 of all other winning tickets shall be 

regraded and traced to the computer payout report;

(ii) The video recording and/or digital record of rabbit ears or wheel shall be 

randomly compared to the computer game information report for at least 10% 10 of 

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the games during the shift. This procedure does not apply to rabbit ear systems that 

are directly interfaced to the keno computer system unless a ball draw results 

change is made manually; and

Comment (December): Recommend adding “or wheel” following “rabbit 

ears”.

 

Response: Agree. Revised accordingly

Proposed revision as a result of December comment:

(ii) The video recording and/or digital record of rabbit ears or wheel shall be 

randomly compared to the computer game information report for at least 10% 10 of 

the games during the shift. This procedure does not apply to rabbit ear or wheel 

systems that are directly interfaced to the keno computer system unless a ball draw 

results change is made manually; and

(iii) Keno audit personnel shall review winning tickets for proper authorization 

pursuant to paragraph (e) (6) of this section.

(6) In the event any person performs the writer and deskman functions on the same 

shift, the procedures described in paragraphs (j)(m)(5)(i) and (ii) of this section 

(using the sample sizes indicated) shall be performed on tickets written by that 

person.

Comment (December): “Deskman” is an out-dated term. Such a position 

no longer is relevant to current-day keno. Recommend deleting (6).

Response: Agree. Modified accordingly (subsequent sub-sections 

renumbered accordingly.)

Proposed revision as a result of December comment:

(6) In the event any person performs the writer and deskman functions on the same 

shift, the procedures described in paragraphs (j)(m)(5)(i) and (ii) of this section 

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(using the sample sizes indicated) shall be performed on tickets written by that 

person.

(6) (7) Documentation (e.g., a log, checklist, etc.) that evidences the performance of 

all keno audit procedures shall be maintained.

(7) (8) A manager independent of the keno department shall review keno audit 

exceptions, and perform and document investigations into unresolved exceptions. 

These investigations shall be documented, maintained for inspection, and provided 

to the Tribal gaming regulatory authority upon request.

(8) (9) When a multi-game ticket is part of the sample in paragraphs (j) (m) (3) (ii), 

(j) (m) (5) (i) and (j) (m) (6) of this section, the procedures may be performed for ten 

(10) games or ten percent (10%) of the games won, whichever is greater.

Comment (December): 542.10 (m) (6) has been recommended for deletion. 

Therefore, reference to (m) (6) should be deleted as well.

Response: Agree. Revised accordingly.

Proposed revision as a result of December comment:

(8) (9) When a multi-game ticket is part of the sample in paragraphs (j) (m) (3) (ii) 

and (j) (m) (5) (i) and (j) (m) (6) of this section, the procedures may be performed 

for ten (10) games or ten percent (10%) of the games won, whichever is greater.

(l) Access. Access to the computer system shall be adequately restricted (i.e., 

passwords are changed at least quarterly, access to computer hardware is physically 

restricted, etc.).

Justification: Revision is intended to recognize the benefit of keno computerized 

systems that interface with the gaming operation’s accounting programs, to strike 

certain standards that are already addressed in the IT section and to update selected 

auditing requirements. 

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(m) (n) Equipment standards.(1) There shall be effective maintenance planned to 

service keno equipment, including computer program updates, hardware servicing, 

and keno ball selection equipment (e.g., service contract with lessor).

(2) Keno equipment maintenance (excluding keno balls) shall be independent of the 

operation of the keno game.

(3) Keno maintenance personnel shall report irregularities to management 

personnel independent of the keno department.

(4) (1) If the gaming operation utilizes a barcode or microchip reader in connection with 

the play of keno, the reader shall be tested at least annually by personnel independent of 

the keno department to determine that it is correctly reading the barcode or microchip. 

(2) [Reserved]

Justification: Revision is intended to recognize that the maintenance of the keno 

equipment may be performed by keno personnel or outsourced by the department. 

Therefore, certain standards that would conflict with such an option are being deleted. 

(n) Document retention.

(1) All documents (including computer storage media) discussed in this section shall 

be retained for five (5) years, except for the following, which shall be retained for at 

least seven (7) days:

(i) Video recordings and/or digital records of rabbit ears or wheel;

(ii) All copies of winning keno tickets of less than $1,500.00.

(2) [Reserved]

Justification: Revision is deleting requirements that are effectively addressed either in 

the Surveillance Section or the Accounting Section of the MICS. 

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(n) (o) Multi-race tickets. (1) Procedures shall be established to notify keno personnel 

immediately of large multi-race winners to ensure compliance with standards in 

paragraph (e)(5) of this section. 

(2) Procedures shall be established to ensure that keno personnel are aware of multi-race 

tickets still in process at the end of a shift. 

(3) All games encompassed by a multi-race keno ticket must be completed within 14 

days of the wager being placed. 

Justification: Revision is intended to establish a limit on the future time period that a 

multi-race ticket can be accepted. 

(p) Payout procedures for mail-in winning keno tickets. (1) Management shall adopt 

and implement procedures for the acceptance and redemption of mail-in winning 

keno tickets and the procedures shall be approved by the tribal gaming regulatory 

authority. 

(2) At a minimum, the mail-in winning keno ticket procedures must include the 

following:

(i) Original winning keno tickets received shall be routed to accounting/audit 

personnel or other personnel independent of the keno department;

(ii) Accounting/audit personnel or other personnel independent of the keno 

department shall record winning keno tickets received on a log as a mail pay. The 

log must include, at a minimum, the date received, customer’s name and ticket 

number;

(iii) The winning keno tickets shall be entered into the computer system by keno 

personnel or accounting/audit personnel for validation and cancellation.

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(iv) Accounting/audit personnel shall compare the “paid” winning keno tickets to 

the mail pay log and the system report for “paid” winning keno tickets. Any 

discrepancies shall be documented by keno and accounting management;

(v) Accounting/audit personnel, independent of the employee(s) who processed the 

mail pay winning ticket, shall review the customer’s correspondence submitted, the 

winning ticket, the mail pay log and the system report for “paid” winning tickets for 

any discrepancies. Any discrepancies noted shall be documented and resolved prior 

to remitting payment to the customer.

Justification: Revision is intended to recognize that gaming operations may wish to 

allow for mail-in winning keno tickets. The revision is establishing the requirement that 

management’s decision and adoption of related controls must be approved by the tribal 

gaming regulatory authority. Furthermore, the revision is establishing minimum 

standards that the controls must address. 

(p) Manual keno. For gaming operations that conduct manual keno games, 

alternate procedures that provide at least the level of control described by the 

standards in this section shall be developed and implemented.

Justification: Revision is striking the latitude of adopting alternative procedures for a 

manual game of keno. Current revisions include controls that would be applicable to a 

manual game. 

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