by David Vialpando
The ever-evolving complexity of casino gaming regulation demands a multi-dimensional gaming regulator possessing expertise in a variety of disciplines – from sophisticated gaming technology to multi-channel payment options, suitability backgrounding of multi-national companies, cybersecurity threats, and iGaming and sports wagering regulatory compliance. The challenge for Tribal Gaming Regulatory Agencies (TGRAs), also referred to as gaming commissions, is how to ensure knowledge acquisition and retention for present and future generations of regulators.
Few professions are as proficient in sharing industry best practices, experience, and skills as the casino gaming industry. The alphabet soups of organizations and associations offering a plethora of opportunity to learn virtually every aspect of gaming regulation is indeed impressive: IGA, NTGCR, NIGC, NAGRA, TGPN, MGIR, OIGA, WGRA, G2E, IAGR, OTGRA, IMGL, CNIGA, ICE, WGPC, and many others. Gaming commissions assign personnel to attend training, virtual and live, offered by these organizations. The job-related skills of the professional attending training are no doubt enhanced by the information they receive.
The challenge for TGRAs is to maximize the return on investment for every training dollar spent and every hour sacrificed in providing direct service in regulating gaming. Another priority is capturing acquired knowledge and making the information available to regulators unable to attend the training provided to others, including future generations of regulators.
In April 2022, the National Indian Gaming Commission (NIGC) announced the agency’s “3 for 35 Project: Regulating for the Future.” NIGC Chairman E. Sequoyah Simermeyer has described the project as, “a campaign to promote preparedness in the regulatory community’s workforce. A commitment to assess and plan for the next generation of regulators to encourage all Indian gaming regulatory bodies to identify risks and anticipate opportunities for Indian gaming’s continued successful regulation in the future.” The project’s three components focus on strategic recruitment, knowledge retention, and skills planning.
Among the strategies employed by TGRAs to develop, organize, coordinate, prioritize, and archive regulatory skills training is to establish a Training and Education Unit (T&E) within the TGRA. This unit can be an ancillary duty for existing senior TGRA personnel familiar with the wide variety of casino business processes, gaming vulnerabilities, and areas of regulatory responsibility of the TGRA. The T&E Unit responsibilities may include the following:
• Coordinate a TGRA-wide training needs evaluation to assess organizational required, recommended, and professional growth training.
• Review and evaluate potential course materials for completeness, accuracy, and relevance. Identify qualified instructors and training venues. Evaluate the delivery and effectiveness of training attended by TGRA personnel.
• Design, assess, and recommend training for TGRA personnel.
• Manage the delivery of TGRA-provided training.
• Develop and administer training evaluation instruments.
• Acquire industry standard and regulatory best practices training to bring back to TGRA personnel.
• Develop staff training certification instruments and record-keeping processes.
• Gather and evaluate information from TGRA line staff and management regarding previous training to identify weaknesses and areas requiring additional training.
• Attend seminars and meetings to learn new training methods and techniques and use the knowledge to prepare and coordinate future TGRA training courses.
• Recommend training materials and methods, request and maintain in-house training equipment and facilities and manage the TGRA training budget.
• Coordinate TGRA staff training with the Tribal Government Human Resources Department and casino departments.
• Establish and maintain a TGRA Digital Training Library containing reference documents, presentations, and training material for staff access.
• Publish a monthly training newsletter highlighting upcoming online training and highlighting presentations conducted by TGRA personnel.
• Design and manage a TGRA Learning Management System to facilitate access to online training, manage training certification, assist in annual employee training assessments, and assist in resume creation for promotion opportunities.
Implementation of a TGRA T&E Unit can ensure that staff skill-required, perishable, and professional growth training is strategically focused, cost-effective, and that out-of-the-area training assignments are based on objective job-related criteria. The primary calculus in assigning training becomes the professional benefit to the employee and the return on investment to the TGRA.
An organized and strategic approach to training encourages the development of subject matter expertise among TGRA personnel. TGRA subject matter experts are likely to author articles for publication in trade journals and receive requests to present at trade conferences and regional training forums. A frequent ancillary benefit of presenting at trade conferences is a waiver of conference registration fees, a further cost savings for the TGRA.
Strategically focusing on an organized and comprehensive training strategy ensures that the job skills of TGRA personnel remains cutting-edge, that best-practice knowledge is archived for access by existing and new employees, and that staff are encouraged to develop subject matter expertise reinforcing innovation and industry networking enhancing the overall effectiveness of TGRA regulatory compliance administration. Designing an organized training and education process is a smart investment in the future of gaming regulation.
David Vialpando is Executive Director of the Pokagon Band Gaming Commission and Vice-Chairman of Tribal Gaming Protection Network. He can be reached by calling (269) 926-5485 or email [email protected].
