Compliance

Remove the Clutter

Now is the time to clean house on policies and procedures

Simply put, clutter is anything that gets in the way of your success.  If you want more control, less confusion, and increase compliance, but your daily operations is filled with too many distractions a Spring cleaning just may do you good.  Here are three easy ways to tidy up your operations.

1. Dust Off Policies & Procedures

One of the first things I ask for as an auditor are polices and procedures. Most of the time, this is not a major issue for clients. Because our industry is so regulated, many already have the polices on a flash drive ready to hand over. Don’t get me wrong, it makes sense. I certainly appreciate the efficiency of it. However, it does beg a question about the effectiveness of the policies. Many casinos have processes in place that requires a routine review of policies and procedures to ensure they are accomplishing their purpose. For some, though, it has been years since a review and the outdated policies are serving no purpose!

2. Organize MICS & TICS

As casinos are preparing to reopen, many are looking for a checklist to complete to feel confident they are ready before unlocking the doors. Unfortunately, that checklist is probably going to look different for every casino. When the NIGC issued Minimum Internal Control Standards (MICS), the intention was to offer a foundation for Tribal gaming to operate within. Those standards have not changed. Further, as the primary regulators, TGRAs across the nation of developed Tribal Internal Control Standards (TICS) to reinforce the MICS and add further clarity and consideration for jurisdictional-specific risks. The TICS should narrow the broad regulatory foundation that has been created to allow the casino the most appropriate framework to operate.

To demonstrate this, I like to use the comparison of building a house. The MICS are the foundation. A well-built house requires a solid foundation. The continued sustainability of Tribal gaming suggests that the MICS are a good foundation. No need to start from scratch. The TICS, then, would equate to the framework of the house. The walls and ceiling in which the casino can operate. There are going to be cases where this needs some attention. This may be a prime opportunity to make some of those changes, allowing the casino to reach its maximum potential. That is not a business decision, though. The casino does not have the liberty to make those changes. While they can make suggestions, there is no sense spending too much time or resources trying to change something outside your realm of control.

3. Scrub Through the Grime

Following the house example, the casino gets to decide what color to paint the walls, how the furniture will be arranged, and how the house will be decorated. If you are like me, the last couple of months have been Spring cleaning at its finest. Our lives are so demanding that my house was cluttered. I would even say some rooms were downright messy. But today, my house has never been so clean! Room by room, we had the time to really work through what we wanted to keep, what we wanted to rearrange, and even made a few purchases along the way to make home a little better. The business decisions the casino makes should follow that same logic: are our decisions making our business better?

Squeaky Clean

Policies and procedures are the outline for a clean house. Their purpose is to create and maintain internal control, so your proverbial house does not get cluttered or messy. As plans are being made to reopen, maybe it is a good time to take a good look at your policies and procedures. Once business returns to life as usual, this simply won’t be a priority. This time next year, wouldn’t it be nice if your house was still clean? Still operating at its maximum potential? Still mitigating the risks that we just don’t make time to deal with while up and running? Policies and procedures should be more than files on a flash drive. Take this opportunity to make them meaningful!

Doug Parker
MBA, BS Accounting
Supervisor, Finley & Cook
dparker@finley-cook.com

“Our business is built on relationships.  We are responders, because we listen first then make a plan.  Many solutions are cookie-cutter quick fixes and people are forced to fit their problem into the shape of that solution.  Our team creates solutions catered to the specific issues people face – that is how it should be.”

– Doug Parker

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