Minimum Internal Control Standards (MICS)
Five of the Most Commonly Noted Class II Exceptions

– By George Metkovich

Although the Class II National Indian Gaming Commission (NIGC) Minimum Internal Control Standards (MICS) have been in place for over four years, there are still certain findings that tend to appear more often than others during the performance of internal audit procedures. Discussed below are five of the most commonly identified exceptions:
1) Property Integration It is important to consider the Class II MICS from the perspective of the whole casino and not just from the individual Class II areas offered at the casino. For example, if the casino offers card games, consideration should be given to how card games and card games patrons interact with the rest of the casino. If card games players redeem their chips at the main cage, the main cage then needs to follow the requirements as outlined in §543.18. If the casino is offering a promotion catered to gaming machine and table games players but patrons can also gain entry through card games play, then the promotion must follow the requirements of §543.12. Consideration should also be given to determine whether any of the requirements noted in surveillance, audit and accounting, and auditing revenue are applicable as well.

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