The Wisconsin Division of Gaming (WDOG) appreciates the opportunity to provide comment on the 

NIGC Class III MICS Guidance document. The WDOG is providing comments for the following sections:

NIGC MICS CHANGE WDOG COMMENT

542.13 (g)(6) – “EPROMS, or other equivalent 

game software media, returned to gaming 

devices shall be labeled with the program 

number. Supporting documentation shall include 

the date, program number, information identical 

to that shown on the manufacturer's label, and 

initials of the person replacing the EPROM, or 

other equivalent game software media.”

The WDOG believes that the current standard 

regarding software labeling should remain in 

place. The current standard ensures that 

software ID label will be on the media in case of 

removal, and easily identifying media in an 

electronic gaming machine may prevent 

unnecessary media testing for the sake of media 

identification.

542.13 (h)(18) – “three percent (3%) 

recommended”.

The WDOG believes that a minimum threshold 

should be in place for investigation of machine 

performance. The 3% threshold helps identify 

patterns of loss and malfunction which may go 

unnoticed as the investigation threshold rises.

542.13 (j)(1) “(1) The following standards apply if 

a player tracking system is utilized: 

(i) The player tracking system shall be secured so 

as to prevent unauthorized access (e.g., changing 

passwords at least quarterly and physical access 

to computer hardware, etc.). 

(ii) The addition of points to members' accounts 

other than through actual gaming machine play 

shall be sufficiently documented (including 

substantiation of reasons for increases) and shall 

be authorized by a department independent of 

the player tracking and gaming machines. 

Alternatively, addition of points to members' 

accounts may be authorized by gaming machine 

supervisory employees if sufficient 

documentation is generated and it is randomly 

verified by employees who are independent of 

the gaming machine department on a quarterly 

basis. 

(iii) Booth employees who redeem points for 

members shall be allowed to receive lost players 

club cards, provided that they are immediately 

deposited into a secured container for retrieval 

by independent personnel.”

The WDOG believes that physical and IT security 

standards in player tracking systems are critical in 

protecting against fraud. The WDOG 

recommends retention of the standards for 

tracking of agent work on an employee account 

within a gaming machine or player tracking 

department. Player’s club cards are valuable 

assets belonging to patrons, and the security of 

lost cards should be included in the standards.
WISCONSIN DIVISION OF GAMING – NIGC MICS GUIDANCE RESPONSE

JULY 26, 2017 Page 2 of 4

NIGC MICS CHANGE WDOG COMMENT

542.13 (5)/(7) – “Follow-up shall be performed 

for any one machine having an unresolved 

variance between actual coin drop and coin-todrop meter reading in excess of three percent 

(3%) and over $25.00. The follow-up performed 

and results of the investigation shall be 

documented, maintained for inspection, and 

provided to the Tribal gaming regulatory 

authority upon request.”

The WDOG believes that a minimum threshold 

should remain in place for investigation of 

machine drop variances of Tribal assets. While 

investigations of a higher threshold may lead to 

fewer investigations, the 3% threshold helps 

identify patterns of loss and malfunction which 

may go unnoticed as the investigation threshold 

rises.

542.14 (b) – “(1) If personal checks, cashier's 

checks, payroll checks, or counter checks are 

cashed at the cage, 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 appropriate controls for purposes of security 

and integrity. 

(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 for the acceptance of personal 

checks, collecting and recording checks returned 

to the gaming operation after deposit, re-deposit, 

and write-off authorization.”

The WDOG believes that controls should remain

in place for financial instrument acceptance, 

along with assurance casino credit is not possibly 

given where prohibited by State/Tribal Compact.

542.17 (a) – “including limits based on 

relationships between the authorizer and 

recipient”.

The WDOG believes that controls should remain

in place regarding the relationship between the 

authorizer of a comp and the recipient. A lack of 

controls in this area increases the risk of assets 

being given to patrons without justification, and 

increases the potential for fraud.

542.17 (c) – “The internal audit or accounting 

departments shall review the reports required in 

paragraph (b) of this section at least monthly. 

These reports shall be made available to the 

Tribe, Tribal gaming regulatory authority, audit 

committee, other entity designated by the Tribe, 

and the Commission upon request.”

The WDOG believes that this standard should 

remain in place regarding the reporting for player 

tracking systems. This reporting may help 

identify areas of risk, concern, or fraud.
WISCONSIN DIVISION OF GAMING – NIGC MICS GUIDANCE RESPONSE

JULY 26, 2017 Page 3 of 4

NIGC MICS CHANGE WDOG COMMENT

Drop & Count: The WDOG recommends retention of the 

standards for drop and count non-currency 

paperwork (credit fill slip, inventory form, etc.)

These documents are critical to maintaining the 

ability to conduct and audit of gaming revenue.

Internal Audit: The WDOG recommends retention of the 

requirement that Tier C operations maintain a 

separate internal audit department. The WDOG 

has observed that the utilization of outside 

auditors who are not at a property on a full-time 

basis negatively affects the quality of the audits 

and increases the risk of control violations 

occurring without being identified. While the

WDOG agrees that the additional expense of an 

internal audit department may not be justified 

for Tier A and B operations, the higher level of 

assets and therefore higher level of risk inherent 

in a Tier C operation merits the additional 

expense of an internal department. 

Surveillance: The WDOG recommends retention of the 

standards for providing adjustable camera 

coverage of table games (i.e., PTZ). The WDOG 

believes that lack of a dedicated camera 

requirement increases the risk of unrecorded 

activity at the table.

The WDOG believes that the table games 

coverage requirement of activities is too broad 

and vague, leaving out specific coverage 

requirements for games which have unique 

mechanics such as craps and roulette. Some 

games have areas to bet which may need more 

intense focus to determine bets, pays, 

patron/dealer activities, etc. The lack of 

standards for individual games may lead to 

inadequate coverage.

The WDOG recommends that surveillance 

requirements for Cage and vault continue to 

include coverage of the credit/fill window. A 

potentially high level of casino assets are at risk in 

cage and vault transactions, and the WDOG 

believes that reliance solely on paperwork as 

protection for these transactions is insufficient. 
WISCONSIN DIVISION OF GAMING – NIGC MICS GUIDANCE RESPONSE

JULY 26, 2017 Page 4 of 4

NIGC MICS CHANGE WDOG COMMENT

Surveillance (cont.): The WDOG recommends retention of the 

standards for count equipment surveillance 

coverage and recording clarity. Confirmation by 

surveillance of written and actual totals from the 

count machines mitigates the risk of errors and

fraud.

The WDOG recommends retention of the 

standards for recording of suspected 

crimes/suspicious activity by the surveillance

department. A lack of standards in this area 

increases the risk of incidents occurring

undetected.