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10 Critical Questions for Reducing Information Technology Risk in Tribal Gaming

Key Takeaways:

IT operational assessments help Tribal nations and gaming enterprises by enhancing efficiency, security, compliance, and overall business performance.

Tribal nations can use this 10-question checklist to evaluate current IT practices; identify areas to improve security, compliance, and risk management; and guide future strategic planning and decision-making.

Your Tribal nation and its gaming enterprises demand robust and secure information technology (IT) systems. IT operational assessments can significantly contribute to the overall success and sustainability of your property — helping you identify vulnerabilities, optimize systems, verify compliance, and enhance guest experiences.

Checklist: 10 Key IT Questions You Should Be Asking

Understanding the importance of IT assessments for your Tribal nation and gaming entities begins with asking these questions:

1. How can we identify potential vulnerabilities in our technology?

Conducting thorough evaluations of your systems, networks, applications, and data assets helps to pinpoint security weaknesses and potential risk within your systems before they can be exploited. Regular assessments help improve defenses against cyberattacks, fraud, and data breaches.

2. What steps should we take to enhance our security posture?

By evaluating the current IT infrastructure, you can identify outdated or inefficient systems and processes that need upgrading or replacement. Streamlining processes through better technology integration can lead to more efficient operations, reducing downtime and increasing productivity. By enhancing your cybersecurity, you safeguard critical data and increase stakeholder confidence.

3. How can we achieve regulatory compliance in our Tribal gaming and business operations?

Maintaining compliance with industry standards and regulatory requirements, such as the Payment Card Industry Data Security Standard (PCI DSS), Gramm-Leach-Bliley Act (GLBA), and other relevant security frameworks, can provide a roadmap to identify risk while upgrading and optimizing IT systems.

4. What strategies should we use to manage risks effectively?

Prioritizing risks based on their potential impact is essential for effective risk management. Allocating resources efficiently to address the most critical threats allows for a comprehensive risk management strategy tailored to the unique needs of your Tribal nation and its gaming entities. This proactive approach helps mitigate potential risks before they become significant issues.

5. How can we support a disaster recovery and business continuity plan?

Continuous gaming and business activities play a pivotal role in the success and reputation of your Tribal entity. Preserving the integrity and availability of your IT systems is indispensable in shielding your operations from potential disruptions. By building a plan, your organization will be able to handle IT incidents efficiently and recover swiftly when challenges arise.

6. What methods can we use to review and update our IT policies and procedures effectively?

Evaluating your current IT policies and procedures for comprehensiveness and relevance keeps them effective. Updating your policies to reflect the latest industry standards and regulatory changes keeps them applicable. And facilitating enforcement and adherence minimizes the risk of IT-related incidents and enhances your overall security.

7. How can we prevent unauthorized access to sensitive data and systems?

Reviewing user access rights, privileges, and authentication mechanisms is essential for preventing unauthorized access to sensitive data and systems. Also, by implementing a robust third-party vendor evaluation process and access controls, you can help mitigate the risk of data breaches and protect valuable information. This process is critical for maintaining the security of your Tribal nation operations and gaming entities.

8. What actions are necessary to secure our network architecture?

To identify vulnerabilities in firewalls, intrusion detection and prevention systems (IDPSs), virtual private networks (VPNs), and network segmentation practices, a thorough evaluation of your network architecture, configuration, and security controls is necessary. Addressing these weaknesses enhances your network security and prevents potential points of compromise. A secure network architecture serves as the foundation for a resilient IT infrastructure.

9. How can we protect our data assets?

Maintaining data protection measures such as encryption, data loss prevention (DLP) controls, and backup procedures is vital for the confidentiality, integrity, and availability of sensitive information. By protecting data against unauthorized access, disclosure, or alteration, your organization can safeguard its critical assets and keep your IT systems secure.

10. What measures should we take to prepare for incident response and maintain effective IT operations?

Establishing efficient incident detection, reporting mechanisms, and escalation processes helps minimize damage and reduce recovery time during IT incidents. Being ready for incidents allows your Tribal nation and gaming entities to respond quickly and effectively to any disruptions.

Strengthening Your Tribal Nation with IT Assessments

Regular IT assessments are not just a regulatory requirement but a strategic necessity for your Tribal nation and its gaming entities. By investing in IT assessments, your organization can protect its digital assets, support business continuity, and maintain stakeholder trust. Stay ahead in the digital age by making IT assessments an integral part of your IT strategy.

For more insights and to explore how our IT advisory solutions can fortify your Tribal enterprise’s defenses, visit MGO’s IT Advisory Solutions.

Latest Update: GASB Expert Panel

Governmental Audit Quality Center

The Governmental Audit Quality Center (GAQC) promotes the importance of quality governmental audits and the value of such audits to purchasers of governmental audit services. GAQC is a voluntary membership center for CPA firms and state audit organizations that perform governmental audits. The GASB Matters section of the GAQC site highlights key interest areas, key resources, and advocacy efforts related to state and local government engagements.

Pension-related matters

GASB Pensions: Issues & Resources page of the GAQC Web site consolidates the various resources available to practitioners to assist with understanding the new standards and developing appropriate audit strategies. This page also includes links to various whitepapers and related auditing interpretations addressing cost-sharing and agent multiple-employer plans.
Comment Letters

September 16, 2019 comment letter on GASB’s Exposure Draft, Public-Private and Public-Public Partnerships and Availability Payment Arrangements
September 16, 2019 comment letter on GASB’s Exposure Draft, Omnibus 20XX
April 30, 2019 comment letter on GASB’s Exposure Draft, Leases Implementation Guide
March 8, 2019 comment letter on GASB’s Exposure Draft, Fiduciary Activities Implementation Guide
February 14, 2019 comment letter on GASB’s Financial Reporting Model Improvements & Recognition of Elements of Financial Statements

$432 Billion in COVID-19 Relief Slated for State, Local, and Tribal Governments

Throughout the COVID-19 pandemic, state, local, and Tribal governments have been on the frontlines, organizing and providing essential medical care and navigating the endless complications created by shutdowns in their communities. Until now, these government agencies have received aid to directly support COVID-19 responses, but not address disastrous budget deficits, looming layoffs and other emerging issues.

That all changed on March 11, when President Biden signed the American Rescue Plan Act of 2021 into law. The bill allocates $432 billion in direct financial support to U.S. territories, states, and local and tribal governments. In the following, we highlight how the bill affects state, local, and Tribal governments, and breakdown the details of key provisions.

American Rescue Plan of 2021: Impact on State, Local and Tribal Governments

The American Rescue Plan of 2021 contains wide-ranging programs designed to support state, local, and Tribal governments through the financial crises resulting from the COVID-19 pandemic. These include active support for COVID-19 response and planning, funds for in-state capital improvement projects, emergency housing support, and much more.

Much of the relief funding is allocated and disbursed automatically using metrics that include population, economic conditions, and unemployment rates. While each program has different disbursement details, broadly speaking, payments are delivered in two or more installments, the first coming within a 60-day window following the bill becoming law, and future installments through 2022 and beyond.

Other programs will require state and local authorities to apply for grants based on specific needs.

One of the highlights of the revised funding and plan is looser restrictions on how funds from the Coronavirus State Fiscal Recovery Fund can be utilized. The accepted uses include:
• Funding government services that have been curtailed due to decreases in tax revenue caused by the pandemic.
• Aid to households, small businesses and nonprofits, and impacted industries like tourism, hospitality and travel.
• Making “necessary investments” in water, sewer, or broadband infrastructure.

While potential uses have been broadened, all programs require stringent rules for intended use, tracking and reporting.

Highlights of the American Rescue Plan of 2021

Coronavirus State Fiscal Recovery Fund

Sec. 9901, SSA-Sec. 602

50 States and the District of Columbia receive $195.3 billion in aid:

$25.5 billion will be split evenly among each state and the District of Columbia, with each state and the District of Columbia receiving $500 million in aid.
$168.55 billion distributed based on each state’s share of total unemployed workers over the period of October 2020 to December 2020.
District of Columbia receives additional $1.25 billion.
Tribal governments receive $20 billion (further discussion to come).
U.S. territories receive $4.5 billion.
U.S. Treasury receives $50 million to cover costs of administration of the fund.

Coronavirus Local Fiscal Recovery Fund

Sec. 9901, SSA-Sec. 603

Local governments to receive $130.2 billion in aid to be split among counties, metropolitan cities, and non-entitlement units of local government:

Counties receive $65.1 billion in population-adjusted payments, with additional adjustments for Community Development Block Grant (CDBG) recipients.
Metropolitan cities receive $45.57 billion.
Non-entitlement units of local government receive $19.53 billion, distributed by individual states and funded by the U.S. Treasury. Each jurisdiction receives population-adjusted payments based on such jurisdiction’s share of the state population.

Coronavirus Capital Projects Fund

Sec. 9901, SSA-Sec. 604

$10 billion available for states, territories, and Tribal governments to support critical capital projects directly enabling work, education and health monitoring in response to COVID-19:

Each state receives $100 million.
U.S. territories receive $100 million to be split among them.
Tribal governments and the state of Hawaii receive $100 million to be split among them.
Remainder of funds to be allocated to states based on population.

NOTE: The Treasury Department will establish an application process for grants from the fund within 60 days of enactment of the law.

Local Assistance and Tribal Consistency Fund

Sec. 9901, SSA-Sec. 605

$2 billion for eligible revenue-sharing counties and tribal governments:

Eligible revenue-sharing counties will receive $750 million allocated based on economic conditions for each FY 2022 and FY 2023.
Eligible tribal governments will receive $250 million allocated based on economic conditions for each FY 2022 and FY 2023.

NOTE: Payments from this fund may be used for any governmental purpose other than a lobbying activity and will remain available until September 30, 2023.

Other State, Local, and Government Funding Sources

Additional federal government programs have received funding earmarked to support recovery efforts in states, Tribes, and territories. These funds can be applied for via grant applications depending on each government agency’s circumstances.

Homeowner Assistance Fund

Sec. 3206

$10 billion allocated to states, territories, and tribes through grants to prevent homeowner mortgage defaults, foreclosures, and displacements.

Funds may be used to reduce mortgage principal amounts, assist homeowners with housing payments and other aid needed to prevent eviction, mortgage default, foreclosure, or the loss of utility services.

Funds may also reimburse state and local governments that have provided similar assistance since January 2020.

Each state, along with the District of Columbia and Puerto Rico, will receive at least $50 million. Additional amounts will be set aside for other U.S. territories and tribes.

States, territories, and Tribes receiving funding will have to set aside at least 60% of their allocation to assist homeowners who make less than 100% of the local or national median income.

Homelessness Assistance and Supportive Services Program

Sec. 3205

$5 billion allocated to state and local governments to provide supportive services for homeless and at-risk individuals. Permitted fund uses include tenant-based rental assistance, housing counseling and homeless prevention services, and acquiring non-congregate shelter units.

Low-Income Home Energy Assistance Program (LIHEAP) and Water Assistance Program

Sec. 2911
Sec. 2912

$4.5 billion allocated to fund the LIHEAP program, and $500 million provided in state grants to assist low-income households with drinking water and wastewater services.

FEMA Disaster Relief Fund

SEC. 4005

$50 billion to reimburse state and local governments for the costs of ongoing COVID-19 response and recovery activities, and other emergencies.

Funding to remain available through FY 2025.

Final thoughts

With billions of dollars in aid becoming available to state, local and tribal government agencies, the use of these funds is going to be tracked very closely by federal regulators. If you have any questions about how funds can be utilized, and how to track and report this use, MGO’s dedicated State and Local Government team can help. Contact Us.