For Immediate Release Media Contact: Michael Odle

 (202) 632-7003 

NIGC releases five year strategic plan 

WASHINGTON, July 18, 2013 – National Indian Gaming Commission Chairwoman Tracie 

Stevens announced today the release of the agency’s strategic plan for fiscal years 2014 – 2018. 

The plan includes the Commission’s emphasis areas of consulting and relationship building with 

tribal governments; providing technical assistance and training to tribal regulators and operators; 

and continuing its regulatory and Agency operations reviews. 

“All of the Commission’s future activities stem from the principles outlined in our strategic 

plan,” said Stevens. “The plan will provide a road map to help us focus priorities and ingrain a 

philosophy based on strong government-to-government relationships.” 

The National Indian Gaming Commission’s Strategic Plan for FY 2014 – 2018 provides clear 

direction to carry out the NIGC’s mission of regulatory compliance and gaming integrity. By 

strengthening collaboration with tribal and state governments, as well as other Federal agencies, 

the Commission will continue effective regulation of Indian gaming. 

“While the NIGC has an important regulatory role, Tribes are the on the ground regulators of 

gaming, and, through our focus on technical assistance, training, coordination and the A.C.E. 

Initiative, this strategic plan will enhance the capability of the NIGC to provide greater support 

to tribal regulators,” said Stevens. 

The NIGC strategic plan also includes finalizing current regulatory revisions, examining and 

assessing the efficiency and effectiveness of the NIGC’s internal operations and enhancing the 

Commission’s information-technology infrastructure. 

The NIGC Strategic Plan is available online at www.nigc.gov. 

The National Indian Gaming Commission is committed to the prompt and efficient regulation of 

the Indian gaming industry, which spans more than 420 gaming establishments, associated with 

nearly 240 tribes across 28 states. The Commission’s dedication to compliance with the Indian 

Gaming Regulatory Act ensures the integrity of the $27 billion Indian gaming industry. For more 

information, visit www.nigc.gov.

### 

The National Indian Gaming Commission is an independent regulatory agency established within the Department of the Interior 

pursuant to the Indian Gaming Regulatory Act of 1988.
National Indian Gaming Commission

U.S. Department of the Interior

Strategic Plan

For Fiscal Years 2014-2018

Regulatory Compliance Gaming Integrity
MESSAGE FROM THE CHAIR i

I am pleased to share with you the Strategic Plan: 2014-2018 of the 

National Indian Gaming Commission (“NIGC,” “Commission,” or 

“Agency”). This document outlines the Commission’s goals and 

measures by which we will assess our success over the next several 

years. This Strategic Plan replaces the FY 2009-2014 Plan.

We must continue to build a stronger, more effective agency. As this 

document outlines, we will strive to do so in very specific ways. We will 

strengthen our collaboration with tribal and state governments as well as 

other Federal agencies to enable effective regulation of Indian gaming. 

By facilitating tribal participation in the development of the NIGC policies, 

regulations, and other matters affecting tribes, we will strive to build 

strong government-to-government relationships, as well as increase effectiveness and efficiency 

within the NIGC. We will promote tribal self-sufficiency by offering opportunities for tribal 

governments and tribal gaming operations to continue to increase their proficiency and 

knowledge through technical assistance and training. We will also continue to review our 

regulations based on the changing needs and challenges within the Indian gaming community to 

ensure consistency and an up-to-date regulatory framework. Finally, we will hold ourselves to the 

highest standards of transparency and accountability, providing the public and tribal governments 

insight into our processes and decision-making.

The governmental entities regulating Indian gaming have grown along with the industry. In 

addition to the Commission, there are approximately 256 tribal gaming commissions serving as 

regulators of their gaming operations. There are also 28 states that provide varying levels of 

regulatory support to fulfill their responsibilities pursuant to the Indian Gaming Regulatory Act 

(“IGRA”) and tribal-state compacts. In addition to the NIGC, tribal and state regulatory agencies, 

the Department of the Interior (“DOI”), the Department of Justice (“DOJ”), the Federal Bureau of 

Investigation (“FBI”), the Internal Revenue Service and the Department of the Treasury all 

implement and enforce laws that impact Indian gaming and are used to ensure that tribes are the 

primary beneficiaries of Indian gaming. The NIGC coordinates with all of these governmental 

entities to fulfill Congress’ mandates in IGRA. 

The Commission’s Strategic Plan for Fiscal Years 2014-2018 focuses primarily on improving 

coordination and collaboration with other Federal agencies; improving coordination and 

collaboration with tribes; continuing and expanding tribal consultation; providing training and 

technical assistance to tribal gaming commissions and operations; conducting ongoing regulatory 

reviews; finalizing current regulatory revisions; examining and assessing the efficiency and 

effectiveness of the Commission; and enhancing the NIGC’s information-technology 

infrastructure.

It is my pleasure to submit the NIGC’s Strategic Plan. Please feel free to contact us with your 

comments at www.nigc.gov.

 Sincerely,

 

 Tracie L. Stevens

 Chairwoman

National Indian Gaming Commission’s Strategic Plan 2014-2018
TABLE OF CONTENTS

ii

Message From the Chair ................................................................................................. i

Mission & Organization ................................................................................... 1

Mission ........................................................................................................ 1

Vision .......................................................................................................... 1

History ......................................................................................................... 1

Commission Structure...................................................................................... 2

Overview of the FY 2014 – 2018 Plan................................................................. 3

Goal 1 Continue the Assistance, Compliance and Enforcement (“ACE”) initiative ......... 4

Goal 2 Improve technical assistance and training for stakeholders............................... 6

Goal 3 Improve and update the NIGC’s regulations ................................................. 7

Goal 4 Improve consultation, communication and relationship building 

 with tribal regulatory authorities and, federal and state agencies ..................... 8

Goal 5 Increase efficiency, transparency and accountability....................................... 10

Key External Factors....................................................................................... 11

Strategic Plan Framework................................................................................ 13

National Indian Gaming Commission’s Strategic Plan 2014-2018
MISSION

The NIGC’s primary mission is to work within the framework created by the Indian Gaming 

Regulatory Act (IGRA) for the regulation of gaming activities conducted by sovereign Indian 

tribes on Indian lands to fully realize IGRA’s goals: (1) promoting tribal economic 

development, self-sufficiency and strong tribal governments; (2) maintaining the integrity of 

the Indian gaming industry; and (3) ensuring that tribes are the primary beneficiaries of their 

gaming activities. 

VISION

The Commission’s vision is to adhere to the principles of good government, including 

transparency and agency accountability; to promote fiscal responsibility; to operate with 

consistency and clarity to ensure fairness in the administration of IGRA; and to respect the 

capabilities and responsibilities of each sovereign Indian tribe in order to fully promote tribal 

economic development, self-sufficiency and strong tribal governments.

HISTORY

IGRA was enacted to support and promote tribal economic development, self-sufficiency and 

strong tribal governments through the operation of gaming on Indian lands. The Act provides 

a regulatory framework to shield Indian gaming from corruption, and to ensure that the games 

offered are fair and honest and that tribes are the primary beneficiaries of gaming operations. 

The Act created the Commission to protect tribal gaming as a means of generating revenue 

for tribal communities. IGRA placed the Commission within the Department of the Interior 

(DOI), but also provided it with independent Federal regulatory authority.

The Commission monitors tribal gaming activity, inspects gaming premises, conducts 

background investigations and audits of Class II gaming operations (and Class III gaming 

operations, upon request or as provided by applicable law, such as tribal gaming ordinances 

and tribal-state compacts). The Commission also provides technical assistance and training 

to tribal gaming commissions and operations and, when appropriate, undertakes 

enforcement actions. 

The Commission fulfills its responsibilities under IGRA by: 

 regulating and monitoring certain aspects of Indian gaming; 

 coordinating its regulatory responsibilities with tribal regulatory agencies through the 

 review and approval of tribal gaming ordinances and management agreements;

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

 seeking to manage Indian gaming; 

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

 referring law enforcement matters to appropriate tribal, Federal and state entities; and 

 when necessary, undertaking enforcement actions for violations of IGRA, NIGC’s 

 regulations and tribal gaming ordinances, including imposing appropriate sanctions for 

 such violations. 

MISSION & ORGANIZATION

1

National Indian Gaming Commission’s Strategic Plan 2014-2018
WA

OR

CA

NV

AZ NM

CO

TX

OK

KS

NE

Alaska

SD

ND

MN WI

MI

IA

LA

MS AL

FL

NC

NY

DC

DE

RI ID

MT

WY

UT

MO

IL IN OH

KY

TN

AR

GA

SC

WV VA

PA

ME

VT

NH

MA

NJ

CT

MD

RI

As the Commission fulfills these responsibilities, it pays close attention to any indications of 

corrupting influences, such as those posed by organized crime and persons known to be 

attracted to cash-intensive industries, such as gaming. 

Commission Structure

The Commission provides Federal oversight to 421 tribally owned, operated or licensed 

gaming establishments operating in 28 states. The Commission maintains its headquarters 

in Washington, DC, and has seven regional offices and three satellite offices. The 

Commission is divided into four separate divisions with a combined staff of over 100 full-time 

employees, as of 2012. Approximately half of the Commission staff is assigned to 

headquarters in Washington, DC, with the remaining staff assigned to regional offices located 

in Portland, OR; Sacramento, CA; Phoenix, AZ; St. Paul, MN; Tulsa, OK; Washington, DC; 

and Oklahoma City, OK; and satellite offices in Rapid City, SD; Temecula, CA; and Flowood, 

MS.

The Commission established its field offices to improve the level and quality of services it 

provides to tribes, and to enhance its ability to communicate, collaborate and interact with 

tribes located within each office’s geographic region. The field offices are vital to carrying out 

the statutory responsibilities of the Commission. By having auditors and compliance officers 

close to tribal gaming facilities, the Commission seeks to facilitate compliance with the Act 

and better relationships with tribal leaders, officials and regulatory personnel. In addition to 

auditing and investigative activities, the field staff provides technical assistance and training 

to promote a better understanding of gaming controls within the regulated industry, and to 

enhance cooperation and compliance to ensure the integrity of gaming operations.

MISSION & ORGANIZATION

2

PORTLAND REGION

SACRAMENTO REGION

WASHINGTON, DC REGION NO INDIAN GAMING

OKLAHOMA CITY REGION

PHOENIX REGION ST. PAUL REGION

TULSA REGION

National Indian Gaming Commission’s Strategic Plan 2014-2018
NATIONAL INDIAN GAMING COMMISSION

Associate Commissioner Chair Vice Chair

Counsel to the Chair

General Counsel Chief of Staff

Internal

Auditor

Deputy

Chief of Staff

Division of

Compliance

Associate

General

Counsel

Associate

General

Counsel

Division of

Finance

Division of

Public Affairs

Executive

Administrator

OVERVIEW OF THE FY 2014 - 2018 PLAN

OVERVIEW OF THE FY 2014 - 2018 PLAN

3

Development of the NIGC Strategic Plan is a collaborative effort to ensure that all 

stakeholders have an opportunity to participate in establishing agency-wide strategies based 

on the Commission’s priorities.

This document provides a concrete basis for establishing strategic goals, and outlines those 

strategies by which the Agency will achieve those goals. This document will also address 

how the NIGC will prioritize the allocation of its budgetary, personnel and other resources.

The NIGC Strategic Plan focuses on the four priorities of the Commission and strategies, 

which are seen as key for agency improvement over the next five years. The Performance 

and Accountability Report outlined the Commission’s four priorities and were included in the 

NIGC Budget Justification for FY 2013. The Commission identified management and 

performance priorities in four areas:

 consulting and building relationships with tribal governments;

 providing technical assistance and training;

 continuing its regulatory review; and

 reviewing its internal operations.

Based upon these priorities, the NIGC developed goals and strategies designed to ensure 

that the NIGC uses its resources to implement, support and monitor the four priorities. All 

strategies listed here are essential to successful implementation of the NIGC Strategic Plan.

National Indian Gaming Commission’s Strategic Plan 2014-2018
GOAL 1

4

GOALS

Strategic goals assert the general direction the agency wants to take to realize its mission 

and vision. Each goal reflects an area of focus for improving performance across the agency. 

The NIGC developed the following five goals:

 1. Continue the Assistance, Compliance and Enforcement (”ACE”) initiative;

 2. Improve technical assistance and training for stakeholders;

 3. Improve and update the NIGC’s regulations;

 4. Improve consultation, communication and relationship building with tribal regulatory 

 authorities, and federal and state agencies; and

 5. Increase efficiency, transparency and accountability.

STRATEGIES

Strategies represent the critical link between planning and implementation. They describe 

how the agency is going to achieve each goal. The NIGC developed 12 strategies for 

achieving the goals.

PERFORMANCE MEASURES

As the NIGC implements its goals and strategies, it is useful to monitor various performance 

measures so that the Commission can evaluate progress toward achieving its goals.

As with any agency there are many possible choices that may be used to measure 

performance. The NIGC will focus on key measures to guide success in achieving the 

strategic plan goals. 

GOAL 1

CONTINUE THE ASSISTANCE, COMPLIANCE AND ENFORCEMENT (”ACE”) INITIATIVE

The basic principle in enforcing IGRA is through ACE: Assistance, Compliance, and 

Enforcement, in that order. The ACE approach to enforcement is consistent with the NIGC’s 

priorities. This approach prevents foreseeable problems through effective communication, 

training and technical assistance, and compliance efforts.

The first step of this initiative is to provide assistance to achieve compliance with IGRA and 

the NIGC regulations. The Agency will respond to changes in the Indian gaming industry, 

anticipate the needs of stakeholders regarding such changes, and expand the Agency’s 

understanding and resources to serve gaming tribes in regard to the changes. The Agency 

will continue to provide technical assistance and training to tribes to enhance compliance and 

reduce the potential for future violations. The Agency will work with Tribes to ensure 

compliance with IGRA by communicating with Tribes early in the process if there is a potential 

compliance issue and working with Tribes to resolve compliance issues voluntarily so that 

enforcement action is taken only when necessary.

The NIGC is expanding its public awareness and outreach to gaming tribes through the ACE 

initiative. The initiative helps connect gaming tribes with a broad array of technical assistance 

and trainings offered by the NIGC.

National Indian Gaming Commission’s Strategic Plan 2014-2018
GOAL 1

5

Strategy 1

Increase the availability of technical assistance available and provided to tribes, gaming 

commissions, and gaming operations.

Strategy 2

Provide timely responses to Tribes on audit findings and IGRA violations to allow adequate 

time for corrective action and voluntary compliance. 

Strategy 3

Conduct site visits, audits and evaluations, with particular focus on improvements in tribal 

internal control systems to maintain the integrity of the gaming industry.

Supporting Performance Measures 2014 - 2018 Target

Number of voluntary audit technical assistance requests. 350

Number of technical assistance sessions provided to 

tribal gaming commissions to enhance success in 

maintaining compliance with IGRA.

Developing baseline

Supporting Performance Measures 2014 - 2018 Target

Percent of NIGC staff compliance with informing, 

assisting, and providing technical assistance to Tribes 

within established internal deadlines in regard to audit 

findings and compliance issues.

Developing baseline

Supporting Performance Measures 2014 - 2018 Target

20

Number of tribal gaming facility site visits completed 

annually.

Percent of MICS audit exceptions satisfactorily resolved 

by tribal gaming operations as a result of an audit or 

evaluation conducted by the NIGC.

Percent of tribal gaming facility audited financial 

statements and management letters received in 

compliance within timelines.

Percent of quarterly fees worksheets received in 

compliance with timelines.

Number of audits and evaluations of tribal gaming 

facilities completed annually.

Number of IGRA/NIGC regulation compliance reviews 

completed annually to assist in voluntary compliance by 

tribal gaming operations.

Developing baseline

500

70%

99%

99%

National Indian Gaming Commission’s Strategic Plan 2014-2018
Supporting Performance Measures 2014 - 2018 Target

Number of technical assistance sessions provided to 

tribal gaming commissions to enhance success in 

maintaining compliance with IGRA.

Proactively respond to tribal needs and industry changes 

by modifying course offerings, and methods of providing 

technical assistance.

Percent of respondents who “agree” or “strongly agree” 

that the training they have received from the NIGC has 

assisted them with the work they do.

90%

Feedback reviewed 

annually

Developing baseline

Strategy 1

Provide guidance, technical assistance, training, and other forms of assistance to tribes to 

build and sustain the capability to prevent, respond to, and recover from weaknesses in 

internal controls and violations of IGRA and NIGC regulations.

GOAL 2

6

GOAL 2

IMPROVE TECHNICAL ASSISTANCE AND TRAINING FOR STAKEHOLDERS

In partnership with the Indian gaming 

industry and other Federal agencies, we will 

provide technical assistance and training to 

tribes within all NIGC regions through 

targeted training events, site visits, and 

inquiries. We will build on the agency’s 

information technology infrastructure to offer 

training and technical assistance 

opportunities through the agency’s website, 

web portal, or online.

To improve the training program’s 

effectiveness and improve participants’ 

response to trainings offered, the NIGC 

plans to update and revise course content 

so that it is immediately applicable and 

engaging for participants. Sacramento Regional training event

National Indian Gaming Commission’s Strategic Plan 2014-2018
GOAL 3

7

Strategy 2

Provide opportunities for tribes located within all NIGC regions to participate in trainings.

National Indian Gaming Commission’s Strategic Plan 2014-2018

Supporting Performance Measures 2014 - 2018 Target

Percent of attendees satisfied with training (indicating 

such by surveys at training events).

Number of training events held annually.

Percent of tribes who attended annual training events .

Number of attendees attending training events annually.

Number of site visit technical assistance events provided 

annually.

70%

12

2000

85%

70

Strategy 1

Finalize and implement new and revised regulations developed through the regulatory review 

process.

Supporting Performance Measures 2014 - 2018 Target

Percent of trainings provided to agency staff and Tribes 

to enhance understanding of new and revised 

regulations.

Number of Tribal Advisory Committee meetings held 

annually.

Conduct ongoing evaluations of regulations to determine 

the need for regulatory updates and changes through 

consultations, Tribal Advisory Committee meetings, 

Tribal Gaming Working Group meetings, and input 

received from agency staff and Tribes.

Continue to inform Tribes of new regulations through the 

use of NIGC’s website and other media outlets, including 

social media.

Annually reviewed

Annually reviewed

100%

As needed

GOAL 3

IMPROVE AND UPDATE THE NIGC’s REGULATIONS

The Agency will continue the regulatory review implemented in 2010, by continuing to 

improve and update the NIGC’s regulations after meaningful consultation with stakeholders. 

We will respond to issues and changes in the Indian gaming industry by addressing present 

needs and anticipating needs and expanding our understanding and resources for gaming 

tribes. For the benefit of the gaming tribes, efforts will be directed towards ensuring gaming 

equipment, associated products and services, games and the rules governing their play are 

commensurate with that of the overall gaming industry. We will maintain Tribal Advisory 

Committees as needed to establish collaborative rulemaking.
GOAL 4

8

National Indian Gaming Commission’s Strategic Plan 2014-2018

GOAL 4

IMPROVE CONSULTATION, COMMUNICATION AND RELATIONSHIP BUILDING WITH 

TRIBAL REGULATORY AUTHORITIES, AND FEDERAL AND STATE AGENCIES

The Agency will identify methods of communicating information to tribal gaming operators, 

regulators and government officials that will provide for meaningful, timely and respectful 

consultations; improve transparency, accountability, collaboration and participation; and 

continue to enhance and build upon relationships with tribal, Federal and state regulatory 

authorities and/or agencies.

Communication and other assistance services are integral to the NIGC’s support of this 

strategic goal. The NIGC’s processes help ensure services are accurate and responses are 

timely. The NIGC is also developing surveys and other metrics that will assist in gauging 

gaming tribes and stakeholders’ needs.

Strategy 1

Conduct meaningful consultations with tribes on NIGC proposals for regulations, rulemaking, 

legislation, guidance, policy formulation or actions that may have a substantial, direct effect 

on one or more tribes, on the relationship between tribes and the Federal government, or on 

the distribution of power and responsibilities between tribes and the Federal government.

Supporting Performance Measures 2014 - 2018 Target

Conduct meaningful tribal consultations in conjunction 

with national and widely attended meetings to conserve 

tribal and Agency resources.

Percent of gaming tribes and their officials, and 

employees attending consultations.

Adoption and full implementation of the NIGC’s tribal 

consultation policy.

By 2014

Developing baselines

80%

Strategy 2

Implement the NIGC’s responsibilities under the 

Open Government Initiative as defined by the Office 

and Management Budget’s Open Government 

Directive of 2009 and improve the NIGC website to 

provide information about the agency and its work.

A tribal regulator addresses the Commission

at a consultation in Washington State.
Supporting Performance Measures 2014 - 2018 Target

Regularly inform tribes of Agency financial resources 

(Gross Gaming Revenue, Agency Budget, etc.).

Number of increased opportunities for tribes to engage 

and collaborate with the agency through a forum for 

feedback through the NIGC website and social media 

platforms.

Percent of users satisfied with the amount and type of 

information available on the agency’s website.

Continue to improve the quality, quantity and timeliness 

of information made available to Tribes through the Tribal 

Access Portal (TAP).

90%

By 2016

Annual Reporting

Developing baseline

Strategy 3

Coordinate and collaborate with tribal regulatory authorities, and federal and state agencies 

using a variety of mechanisms.

GOAL 4

9

National Indian Gaming Commission’s Strategic Plan 2014-2018

Supporting Performance Measures 2014 - 2018 Target

Percent of tribal regulatory authorities who said that the 

NIGC was doing a “good” or “very good” job of fulfilling its 

mission of improving and building relationships 

(indicating such by surveys).

Develop a system for referrals to and from relevant 

federal regulatory authorities and agencies.

Continue to develop partnerships via MOUs with tribal 

regulatory authorities, and federal and state agencies to 

promote efficiency.

Ongoing

90%

By 2015

Employees of the NIGC prepare to deliver staff reports to the Commission during a public

commission meeting.
GOAL 5

INCREASE EFFICIENCY, TRANSPARENCY AND ACCOUNTABILITY

The Commission is committed to building a transparent, high-performance agency. This goal 

is enhanced by developing personnel related policies, improving technology resources, 

recruiting and retaining a highly diverse, skilled and motivated workforce, and ensuring that 

staff is well-equipped with tools and training to work effectively and creating staff performance 

plans. Within the Agency, the Agency will develop annual budgets and develop policies and 

procedures as needed. The Commission will improve management and operations by 

providing ongoing oversight, evaluation and analysis of the NIGC’s policies through regular 

communications between management and staff, refining the Agency’s personnel 

performance-measurement system so that work is clearly related to mission goals and 

performance measures, implementing an information technology (IT) modernization program 

to support networked information and shared-data resources and ensuring that the NIGC’s 

financial resources are allocated in the most efficient and effective manner.

GOAL 5

10

National Indian Gaming Commission’s Strategic Plan 2014-2018

Supporting Performance Measures 2014 - 2018 Target

Develop an Action Plan to respond to employee feedback 

generated by the Employee Viewpoint Survey.

Percent of employees receiving trainings on new policies 

and employee awareness programs.

Percent compliant with mandatory staff training.

Maintain up-to-date human resource policies and 

procedures.

100%

100%

Feedback Reviewed

Annually reviewed

Strategy 1

Update and further develop policies that enhance Agency employees’ ability to perform their 

jobs effectively.

Supporting Performance Measures 2014 - 2018 Target

Number of performance management goals achieved 

within their set timeline.

Implement new performance measurement system.

Implement new career development policy.

Percent of employees who received training regarding 

individual performance management responsibilities.

By 2014

By 2014

Developing baseline

100%

Strategy 2

Implement and monitor a performance measurement system to enhance employee 

performance.
KEY EXTERNAL FACTORS

11

National Indian Gaming Commission’s Strategic Plan 2014-2018

Supporting Performance Measures 2014 - 2018 Target

Increase the number of communication forums for all 

users.

Meet all federally required IT security regulations.

Implement and realize Agency cost savings and 

increased IT resources.

By 2015

Annually reviewed

100%

Developing baseline

Strategy 3

Develop and maintain more integrated information systems and processes that support the 

NIGC staff and functions.

KEY FACTORS

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

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

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

 beneficiaries of gaming revenues. As mentioned previously, these revenues have 

 played a vital role in the economic development of Indian tribes. A sharp downturn in 

 the local or national economy could adversely affect the gaming public’s amount of 

 disposable income, thereby reducing Indian gaming patronage and resulting in a 

 decrease in Indian gaming revenues.

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

 regulatory actions, the Commission can act only if there is a quorum of two 

 Commissioners. The sudden and unexpected departure of two Commissioners would 

 impact the ability of the Commission to act until such time as two new Commissioners 

 are appointed.

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

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

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

 reviews of management contracts and tribal gaming ordinances, drafting of Indian land 

 opinions, etc.) to instead perform litigation defense work.

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

 country in order to perform site visits of Indian 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. Increased 

 travel costs may also influence such travel.
KEY EXTERNAL FACTORS

12

National Indian Gaming Commission’s Strategic Plan 2014-2018

 Certain statutory limitations inhibit the Commission’s ability to achieve its vision of 

 shielding tribes from corrupting influences. For example, Title 25, United States 

 Code, § 2713 authorizes the Commission to levy and collect appropriate civil fines 

 for any violation of IGRA against a tribal operator of an Indian game or a manage 

 ment contractor engaged in Indian gaming. The Commission, however, lacks the 

 statutory authority to bring enforcement actions against certain other persons or 

 entities affiliated with Indian gaming, such as unscrupulous third-party vendors, 

 developers, and organized crime figures or other corrupting influences.

 The Commission maintains cooperative relationships with other Federal agencies. In 

 those circumstances when the Commission has to rely on these other agencies for 

 factual information or documentation, the Commission may be inhibited in its ability 

 to make timely determinations. Similarly, when the Commission is requested by other 

 Federal investigatory agencies to postpone enforcement actions while they conduct 

 their own criminal and/or civil investigations, the Commission’s regulatory activities 

 may be delayed.

 Finally, a key external factor that may adversely impact the Commission’s ability to 

 achieve its strategic goals is the lack of a “Seminole fix.”  The United States 

 Supreme Court in Seminole Tribe of Florida v. Florida, 517 U.S. 44 (1996) concluded 

 that Congress could not waive States’ immunity from suit by Indian tribes for failing to 

 negotiate compacts in good faith, thus shifting the balance of power in tribal-state 

 compact negotiations.  As a result, some tribes have not achieved the full benefit of 

 the IGRA scheme.  This places a greater Class II compliance oversight burden on 

 the Commission.

The NIGC is participating in a number of tradeshows to increase opportunities for tribes. 
Continue the Assistance, Compliance and Enforcement (“ACE”) 

initiative

Increase the availability of technical assistance available and 

provided to tribes, gaming commissions, and gaming operations

Provide timely responses to Tribes on audit findings and IGRA 

violations to allow adequate time for corrective action and voluntary 

compliance

Conduct site visits, audits and evaluations, with particular focus on 

improvements in tribal internal control systems to maintain the 

integrity of the gaming industry

Improve technical assistance and training for stakeholders

Provide guidance, technical assistance, training, and other forms of 

assistance to tribes to build and sustain the capability to prevent, 

protect against, respond to, and recover from weaknesses in internal 

controls and violations of IGRA and NIGC regulations

Provide opportunities for tribes located within all NIGC regions to 

participate in trainings

Improve and update the NIGC’s regulations

Finalize and implement new and revised regulations developed 

through the regulatory review process

Increase efficiency, transparency and accountability

Update and further develop policies that enhance the Agency’s 

employees ability to perform their jobs effectively

Implement and monitor a performance measurement system to 

enhance employee performance

Develop and maintain more integrated information systems and 

processes that support the NIGC staff and functions 

Improve consultation, communication and relationship building 

with tribal regulatory authorities, and federal and state agencies

Conduct meaningful consultations with tribes on NIGC proposals for 

regulations, rulemaking, legislation, guidance, policy formulation or 

actions that may have a substantial direct effect on one or more tribes, 

on the relationship between tribes and the Federal government, or on 

the distribution of power and responsibilities between tribes and the 

Federal government

Implement the NIGC’s responsibilities under the Open Government 

Initiative as defined by the Office and Management Budget’s Open 

Government Directive of 2009 and improve the NIGC website to 

provide information about the agency and its work

Coordinate and collaborate with tribal regulatory authorities, and 

Federal, and state agencies using a variety of mechanisms

To work within 

the framework 

created by the 

Act for the 

regulation of 

gaming 

activities 

conducted by 

sovereign tribes 

on Indian lands 

to fully realize 

IGRA’s goals: 

(1) promoting 

tribal economic 

development, 

self-sufficiency 

and strong 

tribal 

governments; 

(2) maintaining 

the integrity of 

the Indian 

gaming 

industry; and (3) 

ensuring that 

tribes are the 

primary 

beneficiaries of 

their gaming 

activities.

STRATEGIC PLAN FRAMEWORK

13

National Indian Gaming Commission’s Strategic Plan 2014-2018

Mission Goal Strategy
National Indian Gaming Commission

U.S. Department of the Interior

For further information, visit the National Indian Gaming Commission website at:

www.nigc.gov

or contact

National Indian Gaming Commission

Division of Finance

1441 L St, N.W. Suite 9100

Washington, D.C. 20005

(202) 632-7003