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OMB Control No: 3141-0004	ICR Reference No: 202511-3141-002
Status: Received in OIRA	Previous ICR Reference No: 202206-3141-001
Agency/Subagency: NIGC	Agency Tracking No:
Title: Indian Gaming Management Contract Provisions
Type of Information Collection: Revision of a currently approved collection	Common Form ICR: No
Type of Review Request: Regular	Date Submitted to OIRA: 12/01/2025

	Requested	Previously Approved
Expiration Date	36 Months From Approved	02/28/2026
Responses	51	41
Time Burden (Hours)	620	401
Cost Burden (Dollars)	125,271	19,729

Abstract: The Indian Gaming Regulatory Act requires the National Indian Gaming Commission Chairman to review and approve all management contracts for the operation and management of class II and/or class III gaming activities, and to conduct background investigations of persons with direct or indirect financial interests in, and management responsibility for, management contracts. The Commission has promulgated parts 533, 535, and 537 of title 25, Code of Federal Regulations, to implement these statutory requirements.

Authorizing Statute(s): US Code: 25 USC 2701 Name of Law: Indian Gaming Regulatory Act

Citations for New Statutory Requirements: None

Associated Rulemaking Information
RIN:	Stage of Rulemaking:	Federal Register Citation:	Date:
	Not associated with rulemaking

Federal Register Notices & Comments
60-day Notice:	Federal Register Citation:	Citation Date:
	90 FR 45205	09/23/2025
30-day Notice:	Federal Register Citation:	Citation Date:
	90 FR 54739	11/28/2025
Did the Agency receive public comments on this ICR? No

ICR Summary of Burden

	Total Request	Previously Approved	Change Due to Adjustment in Estimate
Annual Number of Responses	51	41	10
Annual Time Burden (Hours)	620	401	219
Annual Cost Burden (Dollars)	125,271	19,729	105,542

Burden increases because of Program Change due to Agency Discretion: No

Burden Increase Due to:

Burden decreases because of Program Change due to Agency Discretion: No

Burden Reduction Due to:

Short Statement: Updated burden estimates are based on consultations with stakeholders and it should be cautioned at the outset that tribal gaming operations and their business practices are unique to each gaming Tribe and influenced by a variety of local, state, and regional factors. Tribal gaming facilities vary in size and complexity and range from small truck stops and lotteries to world-class casino mega-resorts. The amount of time and resources that gaming tribes expend fulfilling regulatory requirements can vary dramatically and is further complicated by different Tribal governance practices and varying levels of investment in, and adoption of, new technologies and technical expertise. For these reasons, time and cost estimates provided by a statistically insignificant group of rotating tribal consultants has limited value and it would be improper to extrapolate from these estimates any definitive trends. Overall, this collection cycle shows an increase in the number of responses and this increase in management contracting activity is understandably reflected in the increase of time and cost expenditures. In general, a certain amount of the cost increases would be due to the fact that this collection cycle coincided with a period of higher than average price increases. Also, in general, as the gaming industry matures, business contracts grow in complexity and require greater expertise and cost to assemble and review. And there are other factors that appear to have contributed to additional increases in these estimates. The increase in the Burden Hour Wage Cost estimate under part 537.1 is partly caused by the attempt that was made this cycle to capture in greater detail the full wage costs of the information collections upon high-level management executives. For example, although individual fingerprint submissions by management executives were previously overlooked and, although it may require only 2-3 hours of time per individual, because it is calculated at the wage rate of approximately $300/hour, it caused aggregate burden estimates to increase significantly. It also should be understood that, although the estimates for this cycle are higher than that of the last cycle in 2022, in looking at the broader picture, they are actually in line with – and in many cases, lower than –the estimates submitted in the 2018 cycle. For example, in comparison to the 2022 cycle, the Non-Burden Hour Cost rose 540%, however, in comparison to the 2018 cycle, this cost actually decreased 67% (from $379,480 in 2018 to the current $125,271). Finally, it should be kept in mind, as stated at the outset, that burden estimates invariably fluctuate due to the different burden experiences of the limited number of stakeholder that are consulted. For example, it may be reasonable to generalize that executives who are relatively new to gaming will often contract services to assist them through the process of collecting and submitting information for a background investigation. In contrast, seasoned executives will have already prepared such information and are familiar with the process and, therefore, may incur lower expenditures. This is to simply reiterate the observation that costs can significantly vary depending on the particular experience of the consulted individuals.

Annual Cost to Federal Government: $513,900

Does this IC contain surveys, censuses, or employ statistical methods? No

Does this ICR request any personally identifiable information (see OMB Circular No. A-130 for an explanation of this term)? Please consult with your agency's privacy program when making this determination. Yes

Does this ICR include a form that requires a Privacy Act Statement (see 5 U.S.C. §552a(e)(3))? Please consult with your agency's privacy program when making this determination. Yes

Is this ICR related to the Affordable Care Act [Pub. L. 111-148 & 111-152]? No

Is this ICR related to the Dodd-Frank Wall Street Reform and Consumer Protection Act, [Pub. L. 111-203]? No

Is this ICR related to the American Recovery and Reinvestment Act of 2009 (ARRA)? No

Is this ICR related to the Pandemic Response? No

Agency Contact: Tim Osumi 202 632-7054 tim_osumi@nigc.gov

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