Improving on the First

When Caesars Entertainment (then Harrah’s) first began to study responsible gaming, the goal was simple: to create a prevention program that will keep the vulnerable safe. Dr. Jennifer Shatley, the woman who led that program, shares practical tips and key components for operators to enhance efforts to promote responsible gaming based on lessons learned through that experience.

Improving on the First

Over the past several years, the gambling industry has sharpened its focus on responsible gaming. The American Gaming Association’s expansion of what was historically Responsible Gaming Education Week to Responsible Gaming Education Month is, perhaps, the best reflection of this growing importance.

The field has evolved extensively since 1989, when Harrah’s (now Caesars) established the first task force to study the issue, culminating in a historic first: the industry’s inaugural responsible gaming program. These programs have grown from simply providing an informational brochure about help services to guests that specifically state they have a gambling problem into robust programs that give practical information about skills and attitudes consistent with gambling responsibly.

Today, the appreciation that RG is a critical business function that ensures the sustainability of the gambling industry—and its player base—is stronger than it has ever been. While this increased emphasis may be a by-product of the expansion of legal sports betting and mobile gaming—as conversations around new forms of gambling are always accompanied with concerns about possible increases in problem gambling—enlightened operators know the impact of these programs is multitudinous. Not only do these programs play a vital role in reducing negative public perception, allowing for the expansion of the industry, they also facilitate positive experiences for guests and improve morale among employees, which directly affects engagement and retention.

Despite the growing appreciation for these programs, there continues to be a lack of clarity around their programmatic intent. To be clear, responsible gaming programs are prevention programs. Their primary goal is to promote responsible play and help prevent problems from occurring. Put simply, these programs provide customers with the information they need to make informed decisions about their gambling and offer basic strategies for keeping it fun. For example, setting both personal time and monetary limits; gambling for entertainment, not as a way to make money; understanding the house has an advantage; not gambling when lonely or depressed.

However, a confusion persists that responsible gaming programs are problem gambling programs. Unfortunately, discussions about responsible gaming seem to shift immediately into talks about problem gambling. This conflation has two harmful effects. Firstly, it makes the majority of customers—who are the intended target of RG programs—ignore these efforts. They conclude responsible gaming-related tools and messages do not apply to them because they are not problem gamblers. Secondly, it gives the mistaken impression these programs somehow give employees the ability to diagnose problem gambling—a task that is complex even for trained clinicians.

It bears repeating, responsible gaming programs are prevention programs.

This is an important distinction because it shapes responsible gaming policies, as well as the employee training programs and customer communications that support them. Too often, employees are just as confused as customers about what RG programs are trying to accomplish.

There is an alternative. Based on my 25-years’ worth of experience achieving many industry “firsts” – such as implementing the first nationwide self-exclusion program, operationalizing the first efforts to proactively engage with customers about RG (instead of simply responding to customer requests), creating the role of RG Ambassadors, patenting the first RG technology solutions, and creating the first RG-specific ad campaign—I offer a few key components operators should consider to resolve this confusion and enhance their efforts to promote responsible gaming:

RG Policies Should Be Scientifically Driven

Operators must build RG programs with clear and measurable objectives, which, in turn, are based on scientific research and evidence. Policies based on good intentions are insufficient (and often have unintended negative consequences). Many policy solutions to promote RG focus on perceived logical solutions; however, in practice, many of these solutions actually have no effect, or more worrisome, the opposite effect (as was the case when Australia slowed down the speed of machines and actually exacerbated the problem they intended to prevent). While I have always been committed to data-driven policies, my recent completion of my doctoral program has convinced me more than ever that evidence matters, and simply must be the foundation of program development.

However, the reliance on science doesn’t stop with development. The only way to ensure the program is meeting its intended goals is to conduct on-going assessment. This should be done by identifying key performance indicators (KPIs) at the outset and tracking success related to the metrics identified. If program results are not measured, there is no way to know if the initiative is creating the desired effects—or potentially creating negative effects that harm customers and RG efforts.

RG Should Be Ingrained In Corporate Culture, Not Simply A Standalone Compliance Program

Truly successful responsible gaming programs advance beyond a compliance-driven approach to one that internalizes a responsible gambling ethos. To do this, RG should be fully integrated in the corporate culture. All departments and initiatives must embrace and reflect these values.

Many operators tend to view RG programs through a compliance-focused lens. This means that regulations require x, y and z; therefore that is all that is done. The company can check off that compliance box because they met regulatory demands.

Instead of simply following prescriptive regulations, responsible gaming should be integrated across the entire business culture. These concepts are not limited to a narrow RG training course; they are relevant to all aspects of the business. Responsible gaming impacts every part of operations and informs every interaction with a guest. Everything an operator does, from implementing new technology to the incentives it provides to customers, should promote responsible gaming. Further, it has to be a sustained effort, not just one ancillary class, a brochure, or a page on a website. It has to be a shared responsibility that informs every aspect of how the company operates.

Responsible gaming affects so many aspects of operations that any operator today who looks at RG as simply a compliance function is missing the big picture and missing out on much of the value that accrues to a company from a robust, dedicated program.

Consider RG As An Extension Of Customer Service

Responsible gaming should be an extension of good customer service, with clear delineation of responsibilities and practical tools for employees who interact directly with customers. The good news is gambling employees are already extensively trained to deliver great customer service. Effective promotion of responsible gaming should leverage and build upon employee’s customer service strengths and skills.

The games operators offer are largely similar, so business success is not just about having the best product. It’s about having the best customer experience. How an operator treats guests is an area that can be a brand differentiator. This means the experience isn’t just about the gambling product, it’s about all the interactions and touchpoints that happen in the pursuit of gambling on that product. Providing the best customer service possible to guests includes giving them information on how to keep the activity entertaining and, if concerns arise, readily engaging with these customers.

Focus Employee Training On Promotion Of RG, Not “Signs And Symptoms” of PG

Instead of focusing on gambling disorders, training should focus on techniques for providing guests information on how to keep the activity entertaining. Responsible gaming training should tell employees specifically what to do, how to do it, and when to it. Training should not simply provide an overview of so-called “signs and symptoms” of disordered gambling.

Of course, training should include an overview of problem gambling, emphasizing its complex causes, its impact, and resources available for help. However, the focus should be on providing employees the skills to encourage responsible gaming. Again, it is important to remember the primary intent of responsible gaming programs is prevention, and training should be consistent with that goal.

Employees should not only be trained to utilize opportunities to promote RG strategies with guests, but also to respond when there are concerns that a guest may not be gambling responsibly. The reality is that employees have interactions with guests where they are made aware of negative ways in which gambling is affecting guests’ lives, and they should be explicitly trained on how to respond in those situations.

In 2000, we decided to create defined procedures for dealing with employee concerns based on these interactions at Harrah’s/Caesars. As part of this process, we embarked on a three-year campaign that led to the development of “Responsible Gaming Ambassadors,” who are specially trained employees that have conversations with customers when there are concerns that the customer may not be gaming responsibly. It’s important to note this concept took several years to create because we engaged various stakeholders about best practices, reviewed existing research and regulations, engaged academics, and conducted numerous research studies for a truly collaborative effort. And, of course, the concept was empirically evaluated at every stage of its development and implementation.

Basically, customer-contact employees are trained to report concerns that a guest may not be gambling responsibly—and, notice I say “may not be gambling responsibly” not “has a gambling problem.” Gambling disorders are complex, and the process of diagnosing disordered gamblers has been evolving in the mental health community for the past 30 years. Employees aren’t clinicians or diagnosticians and can’t be expected to identify problem gamblers—that’s something that only a trained mental health professional can do and even for them it can be difficult. Training efforts should not give the mistaken impression employees can somehow identify gambling disorders. However, employees can recognize when they are concerned about a guest and this program provides them with a process to report those concerns.

Based on these reports, an RG Ambassadors will proactively speak to a guest about the concern. The conversation is structured on the principles of motivational interviewing, which is a science-based approach that encourages the customer to reflect on how their gambling is negatively affecting them in order to motivate them to commit to changing existing risky behaviors. Again, the focus is on prevention and the promotion of responsible gaming. The fundamental goal of the conversation is to enhance the person’s awareness and motivate change in order to help prevent a problem from developing.

This is a universal concept that can translate to different types of gambling verticals, from a casino floor to a mobile site to an online sportsbook. The training isn’t based on the type of gambling, it is based on the expectation of what employees can and should be doing to promote responsible gaming. By whatever means risk is identified—an algorithm, interaction with a patron, specific risk identifiers—operators should have mechanisms to engage with customers and try to motivate behavioral change.

Continue To Innovate

Finally, innovation is vital, especially in this area. Because responsible gaming is crucial for a sustainable business, it is imperative for operators to continually evaluate, invest in, and innovate their approach.

Once again, research should inform this process. Operators should always be in a cycle of evaluating and evolving RG business processes. Operators should be propelling this field forward with the same vigor they use to invent the next great gambling product, experience or technological advancement. The benefit of innovation cycles is what was once revolutionary becomes commonplace, and while many of the pioneering initiatives we developed at Caesars were controversial at the time of their deployment, they are now common practice.

RG Education Month provides the perfect opportunity to commit to innovating the tomorrows of responsible gaming and improving these programs in the decades to come.

Articles by Author: Dr. Jennifer Shatley

Dr. Jennifer Shatley currently provides consulting services on all aspects of responsible gaming at UNLV’s International Gaming Institute (IGI). In this role, she leads the initiative to establish a Center of Excellence in Responsible Gaming (subject to final university approvals), oversees the organization’s consulting and training efforts, and conducts policy sessions through the International Center for Gaming Regulations. She also serves as the principal consultant for Logan Avenue Consulting, LLC. Dr. Shatley has worked in gaming for 25-years with extensive leadership to support current and future goals surrounding the progression of gambling policy and compliance. As a thought leader in the gambling industry, Jennifer has been the catalyst for the development and innovation of numerous “firsts.”
Serving as the Vice President of Responsible Gaming Policies and Compliance for Caesars Entertainment, she led the development, implementation and administration of the company's programs. She conceptualized and created first-of-its-kind training in the US, developing the role of Responsible Gaming Ambassador designed to further business practices by proactively engaging customers to promote responsible play. Her innovation led to the development of the industry’s first patented responsible gaming IT application that leveraged technology to improve compliance and allow for tracking and implementation of policy and regulatory mandates. Jennifer continues to advise Caesars Entertainment on policies and programs, most recently advising on the company’s efforts in the developing Japan market.
Dr. Shatley is a highly sought speaker and advisor to a multitude of organizations, casinos, tribal councils, states, and countries considering legalizing gambling within their jurisdictions. She has presented at numerous conferences both domestically and internationally and works closely with the treatment community, academics, researchers, government bodies, state councils, and gaming industry representatives.
In addition, she serves as President for the Nevada Council on Problem Gambling and as a member of the National Council on Problem Gambling. She previously served on the Nevada Governor’s Advisory Committee on Problem Gambling, serving as the Chair for the Sub-Committee on Problem Gambling Prevention, as well as serving on the board of directors of the International Center for Responsible Gaming.
Jennifer holds a Doctorate of Public Policy from the University of Nevada Las Vegas, a Master’s Degree in Communication from the University of Tennessee, and a Bachelor’s Degree in English from Christian Brothers University.