With the gradual reopening of gaming and hospitality facilities, RubinBrown’s business and consulting experts have outlined some of the reopening themes and suggested procedures being discussed and shared among clients and throughout industry. This is not meant to be an exhaustive list, and it is recommend operators consult their state’s gaming commission for specific guidance for their jurisdiction1. In addition, this is a fluid process, and we encourage operators to consult the Center for Disease Control (CDC), state/local health agencies, and industry best practices continually for ideas and procedures for addressing public health in their property. Our goal as business professionals is to help you prepare your business for a successful reopening process.
While this summary tends to focus on the front-of-house protective health and cleanliness measures, do not forget to address back-of-house and employee-specific procedures. Employee safety is extremely important to the success of the organization’s reopening as is the fact that the facility is safe, clean, and prepared to protect the public’s health.
The below guidelines summarize guidance from various gaming commissions and are intended to help gaming and hospitality operators and facilities develop a successful business plan for reopening.
Sanitizing Measures for High-Traffic Guest Areas
- Provide, and make easily accessible, hand sanitizer in all public high-traffic areas.
- Sanitize all guest areas when guests conclude their use (i.e., doors, ADA assistance buttons, concierge and bell desks, parking kiosks, valet desks, front desk, elevators and escalator handrails, etc.).
- Use of ultraviolent lights as a disinfectant for difficult or sensitive items. For example, Venetian and Palazzo resorts plan to use ultraviolet lights to kill the virus and decontaminate shipments arriving at their loading docks, mailrooms, and warehouses.
Social Distancing Measures in Gaming-Specific Areas
- Assign employees to focus on ensuring guests do not congregate in groups around gaming machines and tables.
- Each gaming control board may provide specific guidance on the number of positions for each game type where the reopening plan should specifically limit the number of players. For example, player limits in Nevada casinos should be limited to: (a) three players per blackjack table, (b) six players per craps table, (c) four players per roulette table, and (d) four players per poker table.
- Limit occupancy to some amount; say 50%, of allowed occupancy per fire codes.
- Plan for the slot areas to create proper social distancing between patrons. For example, Wynn Resorts will turn off every other slot to create enough space between players. Extra attention needs to be given to the placement, number, and cleaning of chairs and stools in front of each gaming machine.
Sanitizing Measures for Gaming-Specific Areas
- Sanitizing all gaming areas after guest use. Establish intervals for sanitizing all gaming areas after guest use (some intervals may be determined by federal, state, and local health and safety agencies).
- Guidance from the CDC is helpful when designing training programs and communicating how and why cleaning is necessary in all guest use areas.
- Sanitizing of gaming chips, cards, table games, rails, chairs, dice, card shoes, shufflers, roulette wheels, Pai Gow tiles, pit podiums, blackjack discard holders, toke boxes, and other gaming items where players interact with the area.
- Sanitizing intervals will need to be specific enough to remove and kill germs. This may be as frequent as every hour in high-traffic gaming areas. We noted the Venetian and Palazzo resorts will disinfect casino chips in play every two hours, while the Wynn Resorts will sanitize the outside of shufflers every hour and the inside of shufflers once a week.
- Scheduling for disinfection of gaming machines, devices, chairs, and other ancillary equipment multiple times throughout the day. May consider closing areas of the gaming floor periodically throughout the day for deeper cleaning that is visible to guests.
- Availability of hand sanitizer or disinfectant wipes for patron use on the gaming floor.
- Patron advocates (customer service agents) encouraging patrons to participate in keeping the gaming areas free of germs by wiping down machines before and after use (the way guests do at the local fitness center).
- Increased monitoring and oversight of sanitization procedures (may require additional technology, training, and tools).
Gaming Compliance Requirements - Accounting, Liabilities, and Licensee
- Timely submission of a reopening plan to the gaming commission.
- Loading and replenishment of the bank and cage.
- Annual, semi-annual, and quarterly audit and tax reporting - seek extensions where appropriate (make sure your organization and the gaming commission are on the same page).
- Patron liabilities are appropriately accounted for and reconciled.
- Plan to address the expiration of items during the temporary shutdown such as TITO tickets, promotions, awards, comps, etc.
- Bankroll calculation and cash-on-hand requirements are met during the reopening and new operating environment.
- Plan for employee licenses that may have expired during the shutdown.
- Game certifications and approvals for any changes or modifications during the shutdown period.
- Internal control submissions are current and approved for the post-pandemic operating environment (or the reopening period). Pay special attention to remote access and system access being necessary during and after the shutdown.
Social Distancing in Food and Beverage Areas
- Increase spacing of restaurant, bar, and food courts seating and gathering areas. For example, Caesars Entertainment will separate restaurant tables by six (6) feet and reduce bar capacity by half. We noted the Nevada Gaming Control Board released restrictions on March 16, 2020, mandating that patrons may not serve themselves from buffets that remain open. In addition, employees may not serve themselves in employee dining areas.
- Disinfect all:
- Dining tables, bar tops, stools, and chairs after each use.
- Host podiums, service stations, service carts, beverage stations, counters, handrails, and trays on a regular basis.
- Point-of-sale terminals between uses and after each shift.
- Employees who handle food should comply with state and local health district guidelines.
Sanitizing Measures for Lodging Environment
- Increase wait times between guest occupancy in rooms and suites. Increased turnaround times will allow for increased cleaning and disinfection and help reduce guest exposure. Some reports are suggesting increasing wait time between guest occupancy from 24 to 72 hours, depending on organization preferences and available supply.
- Licensees should ensure that housekeeping staff receive comprehensive training on COVID-19 safety and disinfection protocols.
- Reopening plans should include:
- Cleaning and disinfection materials, products, and protocols. For example, how increased attention will be paid to high-touch items, including, without limitation, remote controls, toilets and handles, door and furniture handles, water faucet handles, nightstands, telephones, in-room control panels, light switches, temperature control panels, and flooring.
- Cleaning products that meet Environmental Protection Agency (EPA) guidelines and are approved for use and effective against viruses, bacteria, and other airborne and bloodborne pathogens. A list of disinfectants approved by the EPA for use against COVID-19.
- Use of cleaning and disinfecting protocols to clean guest rooms approved by the CDC and Occupational Safety and Health Administration (OSHA).
- How equipment used by the housekeeping team members (such as spray bottles, carts, trolleys, or mobile equipment (vacuums) should be disinfected on a consistent basis.
- Access to required Personal Protective Equipment (PPE) for housekeeping team members.
- Linens should be washed at a high temperature and with appropriate cleaning products in order to eliminate viral and bacterial pathogens.
- Separate guest room cleaning and restocking carts/personnel in an effort to keep cleaning, disinfectants and soiled laundry away from guest room restocking equipment and amenities.
Guest and Employee Protection
- Placement of plexiglass shields between guest and employees in areas of increased interaction.
- Use of thermal cameras and temperature reading devices upon arrival and stay at establishment. We have noted that Venetian, Palazzo, and Wynn Resorts have talked about using this technology and will flag guests who register 100.4 degrees Fahrenheit or higher using thermal cameras. See challenges and risks of implementation below for more thoughts on this.
- Kits provided to guests including all protective equipment upon arrival (i.e., kits will include items such as masks, gloves, plastic devices for high-touch items). We read in the Venetian’s reopening plan that they will include a personal care kit with hand sanitizer, disinfecting wipes, latex gloves and a personal facemask for every hotel suite.
- Onsite medical professionals provided for guests and employees to meet with if symptoms are present.
- Consideration is being given to temporary suspension of some convenience services that pose a higher risk of interaction, transmission or risk to patrons and employees (e.g., valet parking).
Employee Training and Responsibilities:
- Wash hands properly and frequently with soap and warm water for 20 seconds or more.
- Wash hands before the start of a shift, at least once during every break period, and several times during their shifts, including, without limitation, when they change gloves or otherwise contaminate their hands.
- Wear appropriate PPE. If required or recommended by a federal, state, or local authority, ensure the PPE is available to employees and provide training on how to properly use and dispose of all PPE.
- Train on COVID-19 safety and disinfection protocols for all employees.
- Provide situational training for employees in areas with frequent patron contact and potential exposure.
- Modify employee performance monitoring and measurement for COVID-19 health and wellness infractions.
- Clean and disinfect the back of the house, with an emphasis on high-traffic areas such as:
- Public intersection points (such as HR, security, job centers, training classrooms)
- Employee entrances,
- Uniform control rooms,
- Employee restrooms,
- Loading docks,
- Security scanning podiums,
- Employee relations service desks, and
- Plan to disinfect any tools and equipment shared by employees before, during, and after each shift, or any time the equipment is transferred to a different employee. This includes, without limitation, phones, radios, computers, other communication devices, payment terminals, engineering tools, safety buttons, folios, cleaning equipment, keys, time clocks, and all other direct contact items used by employees throughout the licensee’s property.
Risks in Implementation of These Procedures
The procedures for health and wellness for patrons and employees alike should not exist in a vacuum. Cross-organization teams should work on the implementation plan to ensure well-intended protective measures do not unintentionally affect gaming integrity and/or property safety. Below are few challenges we anticipate properties will have to work through:
- Placement of plexiglass as a protective measure should be non-reflective so not to encourage or enable cheating activities, hinder or block security camera coverage and clarity, or hinder Gaming Board-Approved Internal Controls (otherwise exemptions/changes will require submission);
- Use of protective masks may allow barred individuals to return to establishments undetected.
- Use of technology in new ways could increase number of false positives, resulting in increased investigative time and procedural bias.
- Thermal cameras may not adjust for summer time temperatures exceeding 110 degrees in desert climates.
- Elevator call times and door response times may need to be adjusted to account for cleaning procedures before and after use (or will we see the return of the elevator attendant?).
- Implementation of procedures such as ones listed above will likely increase operating costs. Take steps to normalize daily operations reports and metrics so the right metrics are measured in the reopening period versus last year or next year.
Nevada Gaming Control Board released guidance on Health and Safety Policies for
Reopening after Temporary Closure on Friday May 1, 2020, which expanded Reopening
Procedures guidance released on April 21, 2020.
Readers should not act upon information presented without individual professional consultation.
Any federal tax advice contained in this communication (including any attachments): (i) is intended for your use only; (ii) is based on the accuracy and completeness of the facts you have provided us; and (iii) may not be relied upon to avoid penalties.