NIGC DRAFT STRATEGIC PLAN

2018-2022

 

NIGC

1849 C Street NW Mail Stop 1621 Washington, DC 20240
NIGC Strategic Plan FY 2018-2022 

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Contents

Introduction.............................................................................................................................. 1

Organizational Structure........................................................................................... 2

Mission.......................................................................................................................... 2

Vision............................................................................................................................ 2

Strategic Plan Development................................................................................................ 2

Consultation Efforts.............................................................................................................. 4

Strategic Plan Framework..................................................................................................... 4

External Risk Factors.............................................................................................................. 5

Performance Tracking and Reporting............................................................................... 5

Strategic Goal 1: Gamesmanship – Protect against anything that amounts to

gamesmanship on the backs of tribes through meaningful

communication, training, and technical assistance and utilizing NIGC’s enforcement

authorities, when necessary....... .......................................................................... 6

Strategic Goal 2: Strong Workforce – Maintain a strong workforce both within

the Agency as well as with NIGC’s tribal regulatory partners.......................... 9

Strategic Goal 3: Technology – Leverage reliable and emerging industry

technology trends to support tribal economic development, selfsufficiency and the integrity of Indian gaming.................................................... 12

Strategic Goal 4: Rural Outreach – Develop and execute a plan for small

rural gaming tribes that reviews training, technical assistance and

regulations................................................................................................................ 15

Strategic Goal 5: Operational Excellence – Deliver appropriate resources,

solutions, and services in an efficient and effective manner to benefit 

stakeholders............................................................................................................. 17

Appendix A: Organizational Chart.................................................................................. 19

Appendix B: Operating Divisions & Their Functions................................................... 20

Appendix C: NIGC Offices................................................................................................. 21
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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 regulatory agency within 

the Department of the Interior. 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 created the NIGC to protect tribal gaming as a means of generating revenue for tribal 

governance and tribal communities. IGRA further provides a legal framework structured to 

safeguard tribes as the primary beneficiaries of their gaming operations, support the integrity 

of the Indian gaming industry, and assure that gaming is conducted fairly and honestly by both 

the operators and players.

The NIGC seeks compliance with IGRA, NIGC regulations and tribal gaming ordinances with 499

gaming establishments owned, operated or licensed by 245 federally recognized tribes located

within 29 states. 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 also 

coordinates its regulatory responsibilities with tribal regulatory agencies through the review 

and approval of tribal gaming ordinances and management agreements. 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, which may 

include imposing appropriate sanctions for such violations, such as civil penalties and orders for 

temporary closure as well as referring criminal matters to appropriate tribal, Federal and state 

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

corrupting influences, such as gamesmanship by non-tribal governmental entities.

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 after public notice and 

comment. 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 staff is composed of the Office of the Chief of Staff and the Office of 

General Counsel with approximately 130 full-time employees at the Commission’s 
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headquarters in Washington, D.C., seven regional offices, and two satellite 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.

Appendix A includes the organizational chart for the NIGC. Appendix B shows the operating 

divisions and their functions within the NIGC. Appendix C provides a listing of the NIGC offices.

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 longterm 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 

strategic plan. Meetings were held to formulate the objectives and strategies based on goals 

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

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 2014 – 2018.
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Consultation Efforts

The NIGC followed the consultation requirements set forth in the GPRA Modernization Act of 

2010, Executive Order 13175 “Consultation and Coordination with Indian Tribal Governments,” 

the National Indian Gaming Commission Policy on Consultation with Indian Tribes, and 

guidance from the Office of Management and Budget in the development of this strategic plan. 

The NIGC recognizes the importance of tribal consultation in formulating policy and maintaining 

the government-to-government relationship with tribal nations. To engage with tribal leaders, 

the NIGC sent written notice of the availability of the draft strategic plan and held a webinar to 

present and hear comments on it, followed by a comment period of more than a month. The 

NIGC also engaged the public by posting the draft strategic plan for comment to the NIGC 

website (https://www.nigc.gov/commission/strategic-plan). The NIGC also notified the 

President and Congress of the availability of the strategic plan. The NIGC further requested

input from the Office of Management and Budget. All comments have been taken into 

consideration in the strategic plan.

Strategic Plan Framework

The NIGC Strategic Plan FY 2018 – 2022 includes five strategic goals:

• Goal 1: Gamesmanship – Protect against anything that amounts to gamesmanship on 

the backs of tribes through meaningful communication, training, and technical 

assistance and utilizing the NIGC’s enforcement authorities when necessary

• Goal 2: Strong Workforce – Maintain a strong workforce both within the Agency as well 

as with NIGC’s tribal regulatory partners

• Goal 3: Technology – Leverage reliable and emerging industry technology trends to 

support tribal economic development, self-sufficiency and the integrity of Indian gaming

• Goal 4: Rural Outreach – Develop and execute a plan for small rural gaming tribes that 

reviews training, technical assistance and regulations

• Goal 5: Operational Excellence – Deliver appropriate resources, solutions, and services 

in an efficient and effective manner to benefit stakeholders

These five strategic goals focus primarily on the core initiatives of the NIGC and articulate the 

Commission’s priorities. The associated objectives are mission- and management-focused in 

achieving these goals. Within each objective, there are strategies that identify actions that will 

be taken for accomplishing the goals. 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 its strategic goals.
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External Risk Factors

The following are key external factors that could significantly and adversely affect the ability of 

the Commission to achieve its strategic goals:

• IGRA requires that Indian tribes are the primary beneficiaries of gaming revenues and this 

requirement is an important element of the Commission’s vision. Gaming revenues have 

played a vital role in the economic development of Indian tribes and those revenues are 

dependent on the broader economy. 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. The Commission has 

quorum with two members, and certain regulatory actions require a quorum. The sudden 

and unexpected departure of two Commissioners would paralyze the Commission until such 

time that new Commissioners could be appointed.

• The Commission is a very small agency, with approximately 130 full-time employees. 

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

resources, normally dedicated to regulatory oversight functions (e.g., reviews of 

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

to litigation needs.

• The decision in Colorado River Indian Tribes v. National Indian Gaming Commission, 466 

F.3d 134 (D.C. Cir. 2006), limited the Commission’s authority to prescribe minimum internal 

control standards for class III gaming activities, and prevents the Commission 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, documentation, or to perform investigations, the Commission may be inhibited 

in its ability to make timely determinations due to funding and/or capacity challenges of 

these agencies or tribal partners. 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 did 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 full benefit of the IGRA scheme through Class III gaming and rely exclusively on Class II 

gaming. This places a greater Class II compliance oversight burden on the Commission.
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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.

Gamesmanship

Strategic Goal 1: Gamesmanship – Protect against anything that amounts to 

gamesmanship on the backs of tribes through meaningful 

communication, training, and technical assistance, and utilizing

the NIGC’s enforcement authorities when necessary

The NIGC has identified “gamesmanship” as a tactic by non-tribal governmental interests to 

manipulate business, professional, and employment relationships associated with Indian 

gaming operations to further their own interests at the expense of the tribal gaming operation 

and the tribal government. Gamesmanship often results in a third-party and the tribal 

government violating IGRA, NIGC regulations, or the tribal gaming ordinance.

Gamesmanship violations arise directly out of IGRA and often involve management of a tribal

gaming operation without an approved management contract, misuse of gaming revenue, or a 

violation of the sole proprietary interest requirement. Gamesmanship is even more egregious 

when the parties engaging in gamesmanship have exercised undue influence over the tribal

government decision-making process, as can be the case when the gamesmanship is facilitated 

by trusted tribal advisors. 

The NIGC is taking a targeted approach based on IGRA’s statutory authorities to ensure that 

tribal governments are truly the primary beneficiaries of their gaming operations by reducing 

gamesmanship in the Indian gaming industry and helping tribal governments develop ways to 

detect and prevent gamesmanship before it occurs. The NIGC is committed to providing tribal 

governments, tribal regulators and operators with assistance. This is achieved by the following: 

(1) enhancing awareness of gamesmanship and improve tribal governments’ and tribal 

regulators’ ability to detect the occurrence of gamesmanship; and (2) preventing and/or 

eliminating ongoing gamesmanship by offering training and technical assistance and/or utilizing 

the NIGC’s enforcement authorities to ensure that the gaming fulfills the legislative purposes of 

IGRA.
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Objective 1.1: Enhance awareness of gamesmanship and improve tribal government,

regulator, and operator capacity to detect the occurrence of gamesmanship. 

The NIGC aims to work with tribal governments and regulatory partners at all stages when 

gamesmanship could occur, from development of a new gaming facility through contracts and 

other agreements, to ongoing daily activities on the gaming floor. This requires strong 

partnerships within the Indian gaming industry to ensure that the NIGC continues to monitor 

the industry effectively. Ensuring compliance with gaming laws and regulations is essential to 

maintaining the integrity in the Indian gaming industry. The NIGC will implement eight 

strategies described below to achieve this objective.

 

Strategies:

• Create and update hands-on and on-demand training courses to improve tribal 

governments’, regulators’, and gaming service providers’ ability to identify and 

prevent gamesmanship violations;

• Ensure tribal governments, regulators, and operators receive coordinated and 

consistent information;

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

identify common avenues and methods of gamesmanship;

• Meet with tribal leadership, regulators, and operators to encourage training and 

technical assistance requests;

• Utilize the declination process within the Agency’s Office of General Counsel to 

review unexecuted contracts and agreements that may contain offending provisions;

• Create and improve tools and technology used to identify and prevent 

gamesmanship;

• Develop and maintain a collection and analysis of data related to gamesmanship to 

provide decision makers current and relevant information; and

• Identify and utilize all resources available to the Agency to detect and prevent 

gamesmanship and enforce when necessary, including making referrals to agencies 

with criminal and other civil jurisdiction.

Performance Measures

• Number of engagements where NIGC leadership and staff discuss the elements of 

gamesmanship and the resources available to our regulatory partners.

• Number of gamesmanship training courses offered each year.

• Number of attendees at gamesmanship training events each year.

• Percentage of attendees that identify through anonymous polling that they may have 

gamesmanship issues at their facilities.

• Percentage of attendees who passed knowledge review questions during training 

events.

• Type and number of formal actions taken to protect against gamesmanship on the 

backs of tribes.
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Objective 1.2: Prevent and eliminate ongoing gamesmanship by utilizing the NIGC’s 

enforcement authority to ensure that 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 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 was 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. The NIGC will implement six strategies described below to achieve this 

objective.

Strategies:

• Conduct site visits at gaming facilities, tribal gaming regulatory authorities, and 

other tribal entities to detect conditions of risk and incidences of ongoing or prior 

gamesmanship violations;

• Review submitted unexecuted contracts and agreements for potential 

gamesmanship;

• Analyze audited financial statements and AUP reports submitted for potential 

gamesmanship violations or conditions that create a risk for gamesmanship;

• Develop trusted contacts within the industry that have access to information about 

gamesmanship occurring or about to occur;

• Develop and maintain strong working relationships with tribal regulators to address 

gamesmanship bilaterally when appropriate; and

• Implement and enforce Indian gaming laws consistently and investigate and take 

actions to address potential violations of Indian gaming laws.

Performance Measures

• Number of engagements conducted by NIGC leadership and staff for which the purpose 

is to discuss a gamesmanship violation(s) or potential violation(s).

• Number of site visits performed each year that include awareness efforts, technical 

assistance for detection/prevention, or investigative steps performed by NIGC staff.

• Number of potential gamesmanship issues identified as a result of review of audited 

financial statements and AUP reports submitted by tribal gaming operations.

• Number of unexecuted contracts and agreements reviewed by the NIGC Office of 

General Counsel for potential gamesmanship.

• Number of unexecuted contracts reviewed by the NIGC Office of General Counsel that 

contained elements of gamesmanship.

• Number of unexecuted contracts amended by tribal governments based on the NIGC 
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Office of General Counsel’s findings and technical assistance.

• Number of confirmed gamesmanship violations identified by the NIGC Compliance 

Division.

• Number of gamesmanship violations remedied by the tribal government based on the 

NIGC Compliance Division’s findings.

• Number of gamesmanship violations resulting in enforcement actions, including 

settlement agreements.

• Average time for NIGC to complete investigative and enforcement process from the 

date of opening an investigation to resolution (investigation closure, settlement 

agreement, or other enforcement action) of gamesmanship violations.

• Number of referrals to other agencies and a list of agencies to which referrals were 

made.

Strong Workforce

Strategic Goal 2: Strong Workforce – Maintain a strong workforce both within 

the Agency as well as with NIGC’s tribal regulatory partners

Maintaining a strong workforce is twofold within the NIGC. First, the Agency is statutorily 

required by IGRA to support the self-sufficiency and self-determination of tribes, and 

supporting the tribal gaming workforce is an important goal to achieve tribal self-sufficiency. 

Second, the Agency must also support its own staff and employees that serve the tribal gaming 

industry. 

The 2006 IGRA amendments direct the NIGC to provide technical assistance to tribal 

governments engaged in Indian gaming. The tribal gaming workforce has a significant part to 

play in supporting tribal self-sufficiency and protecting tribal gaming revenues. In order to 

support the workforce of NIGC’s tribal partners and carry out IGRA’s purposes, the NIGC 

provides training and technical assistance.

Further, the NIGC values its employees and is taking every opportunity to make the NIGC the 

best place to work in the federal government. The NIGC will continue to invest in its employees 

through improved performance management and training opportunities. Efforts are also 

focused on improving internal processes and promoting diversity and inclusion within the 

workforce. Employee accountability will be addressed through employee performance plans 

and annual action plans resulting from the Federal Employee Viewpoint Survey.
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The NIGC is committed to craft trainings that are carefully targeted to meet the evolving needs 

of the Agency, as well as regulatory partners, and address high priority matters critical to 

safeguarding the Indian Gaming industry. The NIGC will utilize technology offering on-line and 

on-demand training to allow for live video-conferencing training events that will reach 

employees and tribes across Indian country. In addition, the Agency will invest in the Agency’s 

employee training, work-life programs, and performance management to recruit, hire and 

retain the most qualified and motivated employees to ensure a talented and diverse workforce.

Objective 2.1: Provide training to tribal regulatory partners to promote tribal economic 

development, tribal self-sufficiency, and strong tribal governments.

The NIGC works to educate tribal governments, tribal regulators, and operators on Indian 

gaming law and regulations so they may make well-informed decisions. The NIGC will 

implement four strategies described below to achieve this objective.

Strategies:

• Conduct training events that provide a consistent approach from a variety of 

methods that supports the purposes of IGRA;

• 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 

maintain a highly effective workforce; and

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

facilitating partnerships, and identifying gaps in training.

Performance Measures

• Number of training events held annually.

• Number of individuals attending training events annually.

• Percentage of training evaluations with a “strongly agree” or “agree” rating on meeting 

expectations overall for instructor, course content, and materials.

• Percentage of attendees who passed knowledge review questions during training 

events.

Objective 2.2: Utilize technology and a variety of hands-on learning and virtual learning 

modalities to support efficient and effective training and technical assistance to regulatory 

partners.

To strengthen the tribal gaming workforce, it is important to provide varied methods of training 

that can meet the abilities of diverse learners. The NIGC will implement the five strategies 

described below to achieve this objective.

Strategies:
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• Offer ongoing in-person and virtual access to training and development resources to 

support continual learning;

• Develop a Learning Management System;

• Link the Learning Management System to the Agency’s website for ease of access 

and user ability;

• Increase knowledge reviews on training courses offered; and

• Optimize the training experience through the use of various communication tools to 

support the improvement of training.

Performance Measures

• Number of online presentations available.

• Number of enrollments in online presentations annually.

• Number and types of trainings made available annually.

Objective 2.3: Ensure the Agency creates reasonable goals for employee engagement.

The NIGC will foster an environment where employees have more opportunities to provide 

input into decisions and feel included and engaged. We will continue to motivate and support 

our employees. The NIGC will implement the three strategies described below to achieve this 

objective.

Strategies:

• Evaluate employee feedback based on the Federal Employee Viewpoint Survey 

(FEVS) results, utilize Office of Personnel Management (OPM) communication plan

to market and promote FEVS participation;

• Create and execute FEVS Agency Action Plan based on previous year’s survey results; 

and 

• Develop other tools to garner employee feedback to improve the Agency.

Performance Measures

• Increase in Employee Engagement Index as measured by the FEVS.

• Increase in New Inclusion Quotient as measured by the FEVS.

• Items identified in FEVS Agency Action Plan addressed within established timelines.

• Develop varied tools to garner employee feedback.

Objective 2.4: Invest in the Agency’s employee training, work-life programs, and performance 

management to recruit, hire, and retain the most qualified and motivated employees to ensure 

a talented and diverse workforce.

To ensure that the NIGC employees maintain expertise and are prepared for the future, we will 

continue to implement employee programs that foster development and knowledge sharing. 

We will assist our employees by providing timely training and development opportunities. We 

will also support supervisors and managers through training and providing resources to 
NIGC Strategic Plan FY 2018-2022 

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strengthen our leadership. The NIGC will implement the seven strategies described below to 

achieve this objective.

Strategies:

• Conduct organizational development activities that involve skill-based and work-life 

opportunities or programs;

• Provide training that addresses skill gaps;

• Recruit and retain a high-quality, diverse staff through workforce planning;

• Support a culture of health and safety;

• Ensure access to employee services regardless of geographic location;

• Ensure effective use of the performance management system to manage employee 

performance; and

• Recognize employees for accomplishments and achieving the Commission’s vision.

Performance Measures

• Number of professional development opportunities for employees to attend within the 

agency.

• Number of health and safety courses and updates provided to employees annually.

• Percentage of employees recognized annually for accomplishments and achieving the 

Commission’s vision.

• Number of challenges (negative ratings of 35% or more) as reported by the FEVS or 

Number of strengths (positive ratings of 65% or more) as reported by the FEVS.

• Number of work-life opportunities or programs for employees to participate in within 

the agency.

Technology

Strategic Goal 3: Technology – Leverage reliable and emerging industry 

technology trends to support tribal economic development, 

self-sufficiency, and the integrity of Indian gaming

The NIGC is committed to staying ahead of the technology curve by integrating research,

analysis and agency work to provide solutions and services in a manner that enables informed 

decisions and understanding of industry technology systems. The NIGC is committed to 

providing industry technology information for stakeholders to promote sound decision-making 

and dissemination of industry best practices.

A tribal gaming operation’s data and security measures are arguably the most valuable part of 

many gaming operations. The NIGC’s Division of Technology conducts training to bring 

awareness to and assist in alleviating technological vulnerabilities. The Division of Technology 
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also offers Information Technology Vulnerability Assessments (ITVAs) to tribes to evaluate the 

security vulnerability of their gaming data systems.

Within NIGC, technology also plays a vital role in improving agency communication, knowledge, 

and decisions by transforming and supporting data capabilities in a timely manner. Technology 

can enhance the learning experience, improve operations to deliver quality services and 

information, and improve the use of data.

This goal is achieved by the following: (1) staying up to date on developments in the gaming

industry, including best practices and emerging technologies and utilizing the knowledge to 

raise awareness of these developments; (2) providing subject matter expertise to the Indian 

gaming industry in the field of technology; (3) strengthening information and communication 

systems to support timely decision making and the dissemination of information to all agency 

staff; and (4) maintaining the internal technology infrastructure and continuity of technology 

services.

Objective 3.1: Stay up to date on developments in the gaming industry, including best 

practices and emerging technologies and utilize the knowledge to raise awareness of these 

developments to our tribal regulatory partners.

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

in providing information on industry technology trends and best practices. We will conduct 

research, collect data, 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 four strategies described below to achieve this objective.

Strategies:

• Research industry technology trends and best practices;

• Identify or develop agency staff subject matter experts;

• Disseminate information to tribes, tribal regulators and operators; and

• Accelerate discovery of developments through the sharing of knowledge.

Performance Measures

• Number of bulletins or reports issued providing technical assistance on gaming data 

systems.

• Number of engagements conducted on industry technology trends and best practices.

Objective 3.2: Provide subject matter expertise to the Indian gaming industry in the field of 

technology.

The NIGC will focus on addressing and helping to manage industry technological vulnerabilities 

and continue to play a role in supporting educational efforts to enhance preparedness in 

alleviating these vulnerabilities of gaming data systems. These efforts will focus on providing 
NIGC Strategic Plan FY 2018-2022 

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ITVAs at tribal gaming operations and providing training. The NIGC will implement two 

strategies described below to achieve this objective.

Strategies:

• Continue to educate by offering information technology courses; and

• Provide information technology vulnerability assessments (ITVA) at tribal gaming 

operations.

Performance Measures

• Number of training events held annually related to information technology;

• Number of ITVAs conducted annually.

Objective 3.3: 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:

• Ensure consistency in services by improving communication and customer service 

with agency staff;

• Develop and maintain appropriate records management procedures and tools;

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

and securely disseminate data and information internally; and

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

Performance Measures

• Percentage of employees who are “satisfied” with information technology services and 

systems through evaluations.

• Increase number of resolutions resolved on Agency technology related issues

• Develop appropriate records management procedures and tools.

Objective 3.4: Maintain the internal technology infrastructure and continuity of technology 

services.

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

exploring new technologies and improving the current infrastructure. The NIGC will replace any 

outdated and time-consuming applications. If our applications and systems are not functioning 

properly then our employee performance decreases. We must maintain a strong internal 

technology infrastructure to provide reliable and high-quality services. The NIGC will 

implement four strategies described below to achieve this objective.
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Strategies:

• Increase process automation;

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

efficiency;

• Assess agency applications for value and use; and

• Operate an effective secure network.

Performance Measures

• Number of data outages annually.

• Cost of information technology services and transactions.

Rural Outreach

Strategic Goal 4: Rural Outreach – Develop and execute a plan for small rural 

gaming tribes that reviews training, technical assistance and 

regulations

The NIGC is focused on developing an effective rural outreach plan to reach small rural gaming 

tribes. NIGC outreach to these tribal gaming operations supports the purpose of the IGRA to 

protect tribal self-sufficiency and the integrity of the gaming industry. Small rural gaming 

operations provide important revenue and jobs in areas that may have no other, or limited, 

opportunities to grow an economy.

We will work to deliver a more responsive program to small rural gaming tribes. Specifically, 

we will focus on improving targeted services and strengthening policy development. This will 

be achieved by the following: (1) increasing engagement and outreach with small rural gaming 

tribes through training and technical assistance; and (2) reviewing regulations to determine 

whether they are overly burdensome to smaller operations.

Objective 4.1: Increase engagement and outreach through agency training and technical 

assistance for the unique circumstances of small rural gaming tribes.

NIGC training and technical assistance needs may be different for larger tribal gaming 

operations than for smaller rural gaming tribes. The NIGC will review its current data to 

determine whether there are regulatory issues that may be more prevalent with smaller rural 

gaming operations and develop and undertake new technical assistance methods and trainings 

that meet the needs of smaller rural gaming tribes. The NIGC will implement two strategies 

described below to achieve this objective.
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Strategies:

• Support demonstration or pilot projects for improving how training and technical 

assistance is delivered to small rural gaming tribes; and

• Review data from the Agency to determine whether new training and technical 

assistance can better meet the unique needs of smaller rural gaming tribes.

Performance Measures

• Number and types of training developed for the unique circumstances of rural gaming 

tribes.

• Number and types of technical assistance developed for the unique circumstances of 

rural gaming tribes.

Objective 4.1: Review regulations to determine whether they are overly burdensome to 

smaller operations.

NIGC has historically taken into account the needs and capabilities of smaller gaming 

operations through its regulations. For example, NIGC’s regulations for Minimum Internal 

Control Standards and accounting requirements differ between Tier A facilities that earn less 

than $8 million; Tier B facilities that earn between $8-15 million; and Tier C facilities that earn 

over $15 million. Further, annual gross gaming revenue highlights that the majority of tribal 

gaming operations throughout Indian Country are smaller facilities with lower gross gaming 

revenue. Therefore, the NIGC must consistently review its regulations to determine whether 

smaller operations are overly burdened. The NIGC will implement the following two strategies 

to achieve this objective:

Strategies:

• NIGC staff will make recommendations to the Commission regarding whether there are 

regulations that overburden smaller operations, or whether other corrective actions are 

required to support smaller rural tribes.

• The Commission shall consult with tribes regarding any potential change to the 

regulations to support smaller rural operations. 

• The Commission shall institute other corrective action as needed to support rural 

outreach.

Performance Measures

• Annual recommendations to the Commission regarding potential regulations that may 

overburden smaller operations.

• Number of regulatory changes or other corrective action, if any, advised by the 

Commission to tribes.

• Number of consultations with tribes regarding regulatory changes.
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Operational Excellence

Strategic Goal 5: Operational Excellence – Deliver appropriate resources, 

solutions, and services in an efficient and effective manner to 

benefit stakeholders

The NIGC is focused on improving agency operational efficiencies. By having effective and 

efficient internal operations, it provides the basis for success in achieving the strategic goals 

and objectives. This means developing, maintaining, and improving the policies and procedures 

that are in place to ensure that the NIGC has the resources it needs and uses those resources to 

provide the best solutions and services. This is achieved by the following: (1) monitor 

employee work effectively to provide superior service and to promote continuous 

improvements to routine processes and services; and (2) increase transparency and 

accountability in financial management for the Agency.

Objective 5.1: Monitor employee work effectively to provide superior service and to promote 

continuous improvements to routine processes and services.

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

in an efficient manner. Our employees are committed to providing high quality and robust 

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

timely and effective feedback. 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 workload;

• Simplify processes and procedures for operational improvement by removing 

duplicative tasks or unnecessary steps;

• Develop evidence-based decision making;

• Initiate an annual review of agency policies and procedures for updates as 

necessary; and

• Develop a training/mentoring program for new employees to enhance employee 

skills and efficiency.

Performance Measures

• Percentage of employees who received training on new and updated policies and 

procedures and job specific training.
NIGC Strategic Plan FY 2018-2022 

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• Develop evaluation techniques for employees based on the objective.

Objective 5.2: 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 

five 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;

• Seek out and identify opportunities to share information about the Agency’s 

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

could improve efficiencies;

• Improve the reliability of the secondary accounting system; and

• Provide a budget to all managers and compare budgeted to actual.

Performance Measures

• Percentage of targets met on annual budget calendar timeframe.

• Percentage of financial monthly and quarterly account reconciliations met for accuracy 

in financial reports.

• Percentage of financial reports delivered on time.

• Length of time to respond to written requests for corrections or adjustments to 

customer statements for accuracy in reported balances.

• Annually inform tribes of Agency financial resources (Gross Gaming Revenue, Agency 

Budget, etc.).

• Increase opportunities for tribes to engage and collaborate with the Agency regarding 

Agency financial resources.
NIGC Strategic Plan FY 2018-2022 

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Appendix A: Organizational Chart
NIGC Strategic Plan FY 2018-2022 

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Appendix B: Operating Divisions & Their Functions

The Office of General Counsel provides legal advice and counsel to the Commission on all 

matters relating to IGRA and Commission compliance with all applicable laws and regulations.

The Office of the Chief of Staff implements the policies of the Commission and is responsible 

for the direction, supervision, and evaluation of the work of employees within the office. This 

office oversees human resources, internal audit, executive administration and rural outreach. 

This office is also comprised of four divisions including the Division of Public Affairs, Division of 

Finance, Division of Technology, and the Division of Compliance.

• The Division of Public Affairs provides tribes, tribal regulators, Congress, the public and 

other stakeholders with clear and accurate information about the Agency’s programs 

and activities. The Division is responsible for planning, coordinating and managing the 

Agency’s media relations, community engagement, legislative affairs programs and 

inter-governmental communications, which increases understanding about Indian 

gaming and the Agency’s initiatives to achieve compliance.

• The Division of Finance provides fiscal management and supports the Agency’s day-today financial activities. This Division collects fees for Class II and Class III gaming; 

processes tribal background investigations; conducts management contract review and 

background investigation for third-party contractors that are managing gaming 

operations; processes fingerprint and background investigations payments; prepares 

annual budget and financial reports; prepares annual Gross Gaming Revenue 

information release; supports the Agency’s accounts payable and procurement 

activities; and handles human resource and personnel management matters.

• The Division of Technology provides information technology services; records 

management; and technology support to all Agency employees and provides technical 

assistance and training; background and licensing; fingerprint processing; and 

information technology vulnerability assessments to tribes.

• The Division of Compliance provides technical assistance and training; conducts site 

visits; performs investigations; conducts internal control assessments (ICA); compiles 

the yearly Gross Gaming Revenue figures; reviews the submitted audited financial 

statements; and reviews the agreed-upon procedures (AUP) reports to monitor 

compliance of tribal gaming operations with IGRA. This Division consists of seven 

regional offices and two satellite offices. The audit and training programs reside within 

this division.
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Appendix C: NIGC Offices