How Casinos Are Taking More Responsibility When It Comes To Problem Gaming

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On the surface, there seems to be an inherent dichotomy between gaming and responsible gaming.

However, as the casino industry continues to evolve, casino and gaming operators are drawing a potentially counterintuitive conclusion: gaming and responsible gaming go hand in hand.

After decades of viewing responsible gaming as a burden, many operators are now embracing it. And in coordination with regulators and non-governmental organizations (NGOs), like the National Council on Problem Gambling, they’re leading the responsible gaming charge.

We’ve come a long, long way together

Progressive gaming companies are coming around, but the gap they need to cross is substantial.

Convincing other companies with more entrenched views isn’t going to be easy. Getting everyone up to speed and on the same page is going to take time.

During a G2E 2017 responsible gaming panel, International Center for Gaming Regulation Executive Director André Wilsenach said there is a fundamental misunderstanding of “the stigma, the nature of the issue, its seriousness, and how to deal with it.”

Part of the problem to which Wilsenach is alluding is due to the novelty of responsible gaming.

“Gaming has such a long history, and responsible gaming doesn’t,” said National Council on Problem Gambling Executive Director Keith Whyte during a telephone interview.

Whyte should know, as he’s seen the change firsthand. In his 20-plus years in the responsible gaming field, Whyte has watched standards go from next to nil to what they are today.

“It can be jarring for people who’ve been in the industry for a long time to look at the expectations in place now,” Whyte said. “Views haven’t just shifted slightly; the change has been revolutionary.”

Still a long way to go

Progress has certainly been made, but responsible gaming standards are still severely lacking on at least three fronts, all of which are interconnected to varying degrees:

  1. Uniformity in standards
  2. Funding
  3. Reliance on a reactive approach

Problem #1: Uniformity in standards

Responsible gaming faces a hodgepodge of gaming laws and regulations in the United States.

In some states, the legal age to gamble is 18. In others, it’s 21. And in others, it’s a mixture of both depending on the type of gambling:

  • Lottery
  • Racing
  • Commercial casino gaming
  • Tribal gaming
  • Card rooms
  • Charity card rooms
  • DFS

How wide-ranging are the rules governing gambling? By the National Council on Problem Gambling’s count, there are nearly 1,000 gaming regulatory agencies overseeing commercial and tribal gaming, each with its own rules and lists.

Because regulations lack uniformity, the US lacks a uniform responsible gaming policy. Therefore, the industry has struggled to define what the standards for responsible gaming should be.

That presents a serious problem for regulators and operators. That confusion trickles down to the consumer — particularly the consumer who gambles in multiple states and through multiple channels.

In the same day, a Philadelphia resident could conceivably:

  • Visit a Pennsylvania land-based casino
  • Drive an hour or so to an Atlantic City land-based casino
  • Stop at convenience stores along the way to put in their Pennsylvania and New Jersey lottery numbers
  • Gamble online on New Jersey

Each of these forms of gambling is regulated in different ways, by several different agencies.

Different regulators make it tougher on customers to self-exclude

Whyte says this not only sows confusion but also diminishes the efficacy of responsible gambling policies like self-exclusion. Most self-exclusion, after all, is limited to a property, company, or state.

“In Massachusetts, you can exclude yourself from DFS by going through the Attorney General, from the casinos by going through the Gaming Commission, but you can’t exclude from the lottery or tracks,” Whyte said.

This is problematic when taking into account that a Massachusetts gambler could also be a patron at Foxwoods and Mohegan Sun in Connecticut, Twin River in Rhode Island, and multiple state lotteries. Again, different regulatory bodies oversee all these locales and methods.

If our fictitious Philadelphia gambler self-excluded at Parx Casino in the morning, it would have no effect on his ability to gamble on the Pennsylvania or New Jersey lottery, online in New Jersey, or at Atlantic City casinos.

Taking this example to the extreme, with nearly 1,000 regulatory agencies in the country, problem gamblers could spend their enter lives self-excluding from all of the different US gaming jurisdictions.

So what’s the fix?

One of the things the NCPG is trying to establish is voluntary standards. Whyte explains.

“We’re big believers in voluntary harmonization. As a NGO that works with — operators, regulators, vendors, manufacturers, gamblers, the whole nine — we can devise some voluntary national standards by bringing all these stakeholders together and then encourage all these same groups to utilize these standards in their operations, regulations, and product design.”

An online success story

Whyte touted the success of the NCPG’s internet responsible gaming standards as a template for a national voluntary standard.

According to Whyte:

“In 2012, we worked with a diverse group of NCPG Members, including internet gambling operators, casino operators, and regulators and surveyed the jurisdictions internationally that had exceptional internet responsible gaming regulations, and hand-selected the regulations to use as the foundation for the US market.”

“When New Jersey launched internet gambling, they voluntarily harmonized their responsible gaming standards to meet those set forth by the National Council.”

In addition to New Jersey, the five current online lottery states have also developed their responsible gaming policies to the NCPG’s national template. They’ve received accreditation through NCPG’s Internet Compliance Assessment Program (iCAP) that their operations meet the responsible gaming standards. The NCPG uses GamblingIntegrity, a UK-based specialist in compliance and responsible gaming, to perform a thorough assessment.

The national standard for online gambling has not only created uniform policies but also positively impacted internet vendors certified under the NCPG program.

According to Whyte, NCPG certification allows potential vendors to go to legislators and regulators in a new market and say, “As you’re developing your responsible gaming regulations, here’s the National Council’s guidelines, and our platform and software are already set up to meet [them].”

Problem #2: Funding

The good news is funding for problem gambling is on the rise. In 2013, state funding for problem gambling services totaled $62 million. Three years later, that number ballooned by 15 percent, to $71 million.

The bad news is funding is unequal.

Most of the recent increase is because of a single state, Massachusetts. Ten states with legalized gambling don’t even contribute a cent to public funding for problem gambling. In others, like Georgia, the funding is absurdly small. Georgia contributes just $400,000 annually to cover eight million people.

And there’s worse news: $71 million represents a tiny fraction of the revenue gaming creates.

According to Whyte, the NCPG would like to see the equivalent of one percent of revenue dedicated to problem gambling.

If that was the case, funding wouldn’t be $71 million annually but around $1.1 billion.

Changing people’s attitudes about problem gambling funding has been one of the most difficult aspects of bringing responsible gaming to light. The baseline is so low, and historically, so underfunded, that the industry has trouble wrapping its head around the idea of spending $1 billion.

But as Whyte reiterated, “that’s less than one percent of revenue.”

Problem #3: The reactive approach

According to Whyte, the industry previously relied on a very reactive approach when it comes to dealing with problem gamblers.

The general model is as follows:

  1. Casinos bring in and monetize customers (many of whom lack an understanding of how gambling works)
  2. ICasino will point players toward help, but only if they know what the problem is

This circles back to the lack of uniformity. Operators are only tasked with meeting the regulations different jurisdictions put in place. Many go no further.

But as Whyte notes “The regulation is the floor, not the ceiling.”

Some operators becoming more proactive

Some global operators are starting to raise the floor, turning to more proactive policies. Thanks to their experiences in different jurisdictions, they’re able to implement more aggressive and sophisticated responsible gaming practices.

Whyte praised these operators, noting that many are already going above and beyond the floor set by regulators .

“They’re bringing back what works from [other, more mature markets], adapting, and importing these policies,” he said.

Going beyond the minimum regulations is in the operators’ best interest, Whyte added.

“The casinos don’t have an obligation to provide responsible gaming education to school kids, but it can become a significant problem if no one is doing it.”

Whyte says that requires cooperation and communication:

“When we talk about responsible gaming it is important to know where your role as an operator or vendor lies. In many cases it may be to  enable the work of others like health agencies, educational institutions, and NGO’s like the NCPG.

“As the industry matures and as technology changes, you’re going to see more and more discussions about being proactive in using loyalty programs, player databases and slot tracking software to identify potentially risky behavior and to provide those players with tools and information to help them moderate their behavior or seek help before a problem gets out of hand.”

A Massachusetts success story


MGM stands as one example of a casino corporation adopting a proactive approach — via the GameSense program.

“GameSense is only required in Massachusetts casinos, but MGM has chosen to implement it at all their properties nationwide,” Whyte said. “They chose to do it. I think that’s one of the strongest signals possible. They’ve seen enough at Plainridge Park to license GameSense nationally.”

In addition to its proactive and educational approach, GameSense is lauded for its ability to reduce the larger stigma Wilsenach described.

Historically, responsible gaming has carried a negative and judgmental connotation, largely focused on people with severe problems. That’s beginning to change. GameSense is a step in this direction.

At the National Council of Legislators From Gaming States conference in June 2016, speakers from Massachusetts praised the program, noting players choosing self-exclusion rate Massachusetts’ system far superior to other locales.

They cited that’s largely because the GameSense employees don’t make them feel like criminals. They also emphasize what an important and good decision gamblers are making.

Rather than framing problem gambling as a personal failing, GameSense strives to present difficult choices like self-exclusion as a person arriving at a constructive choice.

“There’s an enormous amount we can do to make responsible gaming messaging accessible and appealing,” Whyte said. “Instead of being positioned in opposition to advertising and promotional messages, responsible gaming should be incorporated with other marketing that reflects the company brand.”


Whyte also mentioned another responsible gaming pilot program Massachusetts put in place, the pre-commitment program PlayMyWay. Roughly eight percent of Plainridge Park Casino patrons are enrolled in the program, according to data from the Massachusetts Gaming Commission.

“Casinos incentivize everything else, but PlayMyWay is the first time gamblers have been incentivized to participate in a responsible gaming program,” Whyte explained.

PlayMyWay registrants receive a $5 food voucher from the casino. Roughly 25 percent of enrollees redeem the voucher, per the MGC.

Whyte went on to say casinos should embrace and build on these programs. Integrating responsible gaming into marketing campaigns further incentivizes people to participate.

The online advantage

When it comes to responsible gaming, a lot is happening in terrestrial casino. However, the biggest advancements in responsible gaming are in the online sector. These online parameters are well ahead of any policies in place at physical casinos.

“There is an attempt to take what has happened in the online sector and bring it to terrestrial casinos,” Wilsenach said during his G2E panel.

“Online really challenges aspects of the traditional terrestrial responsible gaming model,” Whyte concurred.

Online casinos have inherent advantages:

  • The ability to track every dollar wagered
  • Online gaming laws are newer, thus include responsible gaming regulations like self-exclusion, deposit and wagering limits, cool-off periods, and preset time.

But as Whyte notes, “If you can do responsible gambling online, why can’t you do a better job at your terrestrial operations?”

How big of a difference is there between online and land-based responsible gambling standards?

Take self-exclusion programs as an example. In well-regulated online jurisdictions, the standard is 100 percent ID compliance. In a land-based setting, the operator relies on a security worker with a three-ring binder filled with thousands of pictures of people on a self-exclusion list.

“Terrestrial casinos don’t require any ID verification, just someone eyeballing thousands of people a day and trying to match them to one of thousands of faces in their binder,” Whyte said. “And trying to spot someone at a lottery vending machine is a lot harder.”

Whyte’s concerns are borne out in the Pennsylvania Gaming Control Board’s most recent annual report. The board’s finding show 30 percent of self-excluded patrons violated their self-exclusion. According to Whyte, a 30-percent violation rate is relatively consistent across the country.

But that’s only part of the self-exclusion problem.

Excluded from winning

Self-exclusion on its own cannot be effective. According to Whyte, self-exclusion is best thought of as relapse prevention.

As originally conceived, problem gamblers went to a counselor. After they successfully completed therapy, they were excluded. But states flipped that on its head. Self-exclusion went from post-treatment to pre-treatment. And with so few states funding problem gambling treatments, the problem only gets worse.

In many terrestrial casinos, self-exclusion is nothing more than a restriction from winning.

Casinos don’t require ID to enter the casino. They don’t require ID to start gambling. They don’t require losing patrons to show ID.

But ID is required when a player wins enough to trigger a W2 withholding form. If they are on the exclusion list, they forfeit their jackpot.

“Self-exclusion doesn’t treat the gambling problem, nor does it address the root of the disorder,” Whyte commented.

At some point, Whyte believes US casinos might consider moving toward a European system where every patron must show ID to enter the casino. He predicts matching customers to loyalty programs, as well as security reasons, will drive the change. Its positive impact on responsible gaming policies will simply be an extra bonus.

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Steve Ruddock


Steve covers nearly every angle of online poker in his job as a full-time freelance poker writer. His primary focus is the developing legal and legislative picture for regulated US online poker and gambling.

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