Regulation: Integrating a Gaming Technology Unit Within the Tribal Gaming Regulatory Agency

by Brandon Macheta

Gaming technology regulation today is a much different challenge from what it was 10 years ago, or even a year ago. As the technology in the casino gaming industry advances, Tribal Gaming Regulatory Agency (TGRA) regulators have found it challenging to keep up with these changes, particularly with the plethora of new gaming offerings. With these technological advancements, TGRAs should strategically evaluate enforcement of TGRA regulations, casino policies and their everyday operations in an attempt to stay ahead of these changes. One solution is the formation of a Gaming Technology Unit (GTU) within the TGRA specifically tasked with ensuring regulatory standards compliance.

The first step in the formation of a GTU is an honest evaluation of TGRA regulations and internal processes related to gaming technology verification and regulatory oversight. At the Pokagon Band Gaming Commission, our Compliance and Enforcement Division embarked on a process of strategic improvement that led to a rebuilding of our regulatory armor and effectively navigating the ever-evolving landscape of gaming technology. The chosen solution was to consolidate the highly specialized tasks associated with ensuring the integrity of electronic gaming device (EGD) technology into a GTU led by staff possessing the specialized skillset required to operate in this environment.

Establishment of a Gaming Technology Unit

Three questions you are likely to face when considering the formation of a GTU include: why form a separate unit; what will be the unit’s responsibilities; and after the unit becomes operational, is it achieving its intended objectives?

Most casino gaming professionals understand the depth of knowledge that a gaming maintenance or EGD technician must possess to prepare an EGD for game play, as well as to maintain the EGD throughout its lifespan. Add in an EGD system engineer responsible for configuring a Class II gaming server and a ball call server, as well as the plethora of gaming staff needed to install, configure, and service newly introduced iGaming and sports wagering platforms, and you begin to answer the first question. The TGRA is responsible for ensuring the regulatory compliance and integrity of all, these tasks and more.

TGRA regulators must not only learn the casino staff roles outlined above but must also determine how to regulate the activity associated with these roles. Regulators must understand how the software conversion occurs at an EGD to develop testing procedures to ensure that the EGD being offered to the patron is operating fairly, while minimizing risk that could cause a disruption in EGD operation. The ever-changing complexity of EGD processes and integrity monitoring may cause some regulators to defer to the casino’s slot department or EGD vendor personnel as the subject matter experts in ensuring operability. This defeats the independent responsibility of the TGRA to regulate EGD operation.

Once TGRA management grasps the inherent complexities, the next challenge is to ensure that compliance staff at the TGRA understand their responsibility and develop the requisite skills to handle the tasks at hand. As mentioned earlier, gaming technology in our industry can change overnight and there are always advancements in EGD technology. The usual strategy is to create training documents, training videos, and rely on vendor-provided training to convey necessary skills to TGRA personnel. This process can be inefficient and by the time necessary skills are mastered, emerging gaming technology renders the newly acquired skills obsolete.

An essential role of the GTU is to provide on the job training to a limited number of TGRA compliance staff on a continual and recurrent basis until all personnel master the requisite skills. It is much easier to train and communicate daily changes with five people than it is forty or more. One benefit of minimizing the number of staff members utilizing TCRA EGD verification equipment and internal compliance software is the reduced risk of inputting incorrect data into TGRA tracking documents. Concentrating gaming technology responsibilities among a small number of highly trained individuals and other personnel serving temporary duty within the GTU, significantly reduces the error rate in data collection. A single misplaced digit in an EGD verification signature renders the data totally useless.

A dedicated GTU component within the TGRA frees other staff members to focus on other areas of regulation such as table games protection reviews, processing patron complaints and voluntary exclusions and other areas of concern covered by TGRA regulations, gaming compact, Minimum Internal Control Standards (MICS), and the gaming ordinance.

GTU and Gaming Technology Inspector Responsibilities

With the establishment of the GTU, gaming technology inspectors are responsible for the many tasks related to EGD and casino gaming technology compliance. The Pokagon Band Gaming Commission GTU is responsible for regulating over 4,300 Class II and Class III EGDs throughout four properties in two states, as well as regulating an iGaming platform in the State of Michigan and sports wagering platforms in both Indiana and Michigan.

The GTU is responsible for monitoring the status of approximately 40,000 pieces of software that are installed on the casinos’ gaming floor to ensure that all software is approved for service according to the Independent Testing Labs (ITL) requirements. GTU staff also pre-verify all software shipped from the manufacture to ensure that the software has been approved and signatures verified to reduce the risk of corrupted software entering EGDs on the casino floor. In addition to the pre-verification practices, the GTU also post-verifies the software after it has been installed onto the EGD to ensure that nothing was corrupted during software uploading.

GTU gaming technology inspectors review all requests to ship controlled and non-controlled items to casino properties to ensure that all items shipped are approved for the TGRA’s jurisdiction. Gaming technology inspectors are also tasked with monitoring both the iGaming and sport wagering software as well as performing annual audits of the gaming floor to ensure compliance with ITL standards. Gaming technology inspectors are responsible for auditing EGD functionality testing for all EGDs that are provided by casino operations to ensure that all EGDs are functioning as outlined by the manufacturer, ITLs, and as required by TGRA regulations.

Is There Enough Work to Justify Establishing a GTU within the TGRA?

• Aside from their daily tasks of monitoring down EGDs reported by the casino operator, auditing EGD work week projects, processing shipping requests, and random EGD projects and operator requests for TGRA service, GTU gaming technology inspectors will find their days filled with highly specialized tasks requiring precise attention to detail.

• GTU gaming technology inspectors will be found working more frequently with the TGRA’s Internal Audit Department and the Licensing and Investigation Department. An impressive synergy is created when highly trained gaming technology personnel are able to answer questions and provide information related to the licensing of gaming vendors, the frequency of RAM clears under examination by the Internal Audit Department, and provide the necessary information during the investigation of patron complaints and other matters related to the operation of EGDs.

• An example of the GTU proving its worth is an unplanned Class II server audit that results in auditing a couple hundred EGDs because the content from the server was mistakenly pushed to the wrong EGDs. GTU gaming technology inspectors frequently find themselves guiding casino EGD technicians and even EGD vendor service personnel due to the high-level expertise and proficiency they develop. Thoroughly trained GTU personnel become the EGD subject matter experts for casino and vendor personnel, as they should be since the ultimate responsibility for ensuring the integrity of gaming resides with the TGRA.

• The Pokagon Band Gaming Commission’s decision to establish a GTU within the Commission’s Compliance and Enforcement Department has proven beneficial on a number of levels, from training TGRA personnel in the latest gaming technology, to increasing response times to casino operator requests for TGRA service, to substantially reducing technology data errors, and coordinating gaming technology information sharing with other TGRA departments. Expressions of satisfaction for the work of the GTU has been near unanimous from casino operations, TGRA management, gaming vendors, and TGRA gaming inspectors.

• Keep in mind that with any innovative process improvement, there will always be hiccups and growing pains. Human nature defaults to resisting change, so staff engagement, collaboration, and buy-in are essential to ensuring the ultimate success of GTU development. It is important not to rush the process of unit development. Rome was not built in a day and neither should a comprehensive GTU. An essential component of unit design is thorough review of relevant TGRA policies, procedures, regulations, MICs, ITL standards and eliminating outdated modes of gaming technology verification. The goal is to maximize effectiveness, accuracy, and efficiency in the areas of gaming technology compliance.

• An essential part of the review process by the Pokagon Band Gaming Commission (PBGC) involved the design and distribution of gaming technology questionnaires to other TGRAs across the country to elicit feedback concerning industry best practices employed by others.

• The past year has taught us that we must remain nimble and responsive to a changing casino gaming environment. An efficiently structured, well-trained Gaming Technology Unit within the TGRA can ensure that the regulatory agency fulfills its responsibility of ensuring the integrity of gaming, minimize disruption to operations resulting from technological malfunctions, and remain abreast of changes in technology and emerging casino gaming offerings.

Brandon Macheta is Coordinator of the Pokagon Band Gaming Commission Gaming Technology Unit. He can be reached by calling (269) 637-9592 or email [email protected].