35 Days to Train Your Staff: How to Prepare Your Georgia COAM Team for Gift Card Payouts Before July 1

Most conversations about HB 353 compliance focus on systems: the gift card hardware, the GLC portal, the EFT form, the quarterly reports. Those things matter. But when a GLC Compliance Inspector walks unannounced through the front door of your location on July 2, the system isn't what they observe first. They observe your staff.

If a player presents a ticket at the counter and your employee opens the register and counts out $20, no amount of back-office compliance infrastructure protects you from a violation. The gift card system might be perfectly installed and fully operational — but if the person behind the counter defaults to the habit of reaching for cash, you have a violation. That's what makes staff training the most consequential item on your pre-July 1 checklist, and the one most operators are treating as an afterthought.

With 35 days remaining, there is still time to train every employee who handles COAM payouts thoroughly and confidently. This guide covers what they need to know, how to structure training, and how to handle the situations that will inevitably arise in the first weeks after July 1.

Why Staff Training Is a Compliance Issue, Not Just an Operations Issue

The GLC's Compliance Inspectors don't schedule visits in advance. They arrive unannounced, observe operations at the counter level, and evaluate whether what they see matches what the regulations require. Their primary focus areas — as the GLC has documented — are cash payouts and inducements, both of which involve staff behavior directly.

After July 1, 2026, under O.C.G.A. § 50-27-71.1 as amended by HB 353, the only legal forms of redemption for Class B COAMs are replays, Georgia Lottery products, and nonreloadable and reloadable gift cards. There is no exception for partial cash payments, no exception for "change" given alongside a card, and no exception for players who say they'd prefer cash. A staff member who makes any of those accommodations — even with good intentions — creates a violation at your location.

Inspectors also work with information from the GBI's anonymous COAM tip line. Competitors, disgruntled employees, and observant players can all file reports. In the early weeks after July 1, locations where cash is still changing hands are more likely to attract tips. Your staff's visible compliance — confident, consistent gift card payouts every time — is also your best protection against anonymous reports.

What Every COAM Employee Must Know Before July 1

Your training doesn't need to be elaborate. It needs to be clear, specific, and repeated enough that it becomes reflex rather than conscious recall. Here are the five things every relevant employee must know before July 1:

1. Cash Payouts Are Illegal After July 1 — No Exceptions

This must be stated plainly and without qualifications. Staff need to understand that it isn't a preference or a policy choice — it is Georgia law. From July 1, 2026 forward, paying out COAM winnings in cash is a violation of O.C.G.A. § 50-27-71.1, regardless of the amount, regardless of what the player requests, and regardless of whether anyone is watching.

The "regardless of what the player requests" piece is important. Players who have been receiving cash for years will push back. Some will be insistent, some will be angry, and some will claim they know the manager or that "the other place does it." Staff need to know that accommodating any of these requests — even once, even for a regular customer — is a violation at your location, and that a complaint or tip afterward does not create legal risk for the player; it creates legal risk for you.

2. The Exact Payout Procedure

Staff shouldn't have to figure out how to execute a gift card payout under pressure in front of a player. Walk them through the exact steps with your specific system before July 1:

1. Player presents their winning ticket or machine printout.
2. Staff verifies the credit amount.
3. Staff selects the correct denomination(s) and loads the gift card using the payout terminal or kiosk.
4. Staff hands the loaded card to the player along with any receipt the system generates.
5. Staff explains how the player can check their balance (on-card instructions or issuer's number).

Every location's system will have slightly different steps. Make sure the procedure posted at the counter matches exactly what employees are trained to do — and that both match what your payout provider actually supports.

3. What Cannot Be Combined With Gift Cards

Two categories of confusion trip up new operations in the first weeks of the transition:

No cash + card combinations. If a player wins $35 and you only have $25 and $10 cards, load two cards. Do not give $10 in cash and a $25 card. The moment cash changes hands as part of a COAM redemption, you have a violation.

No cash "change." The same rule applies if a player uses a gift card to make a purchase and the transaction triggers change — that interaction involves your retail operation, not the COAM system. But staff should understand clearly that giving cash in connection with a COAM redemption event, regardless of the framing, is prohibited.

4. The Right Response to Player Pushback

Players who want cash will ask for it. Your staff needs a prepared, confident answer that de-escalates the situation without creating a compliance risk. A script along these lines works well:

"Starting July 1, Georgia law requires us to pay out winnings on gift cards — we can't give cash anymore. The card works anywhere [Visa/Mastercard] is accepted. I can show you how to check your balance."

Staff should not apologize excessively, argue the merits of the law, or suggest the player try a different location. A simple, factual explanation delivered without defensiveness handles most player objections. For players who escalate, the fallback is management — but management must know the same rules and give the same answer.

It also helps to have printed player-facing signage at the machines and at the counter explaining the change before July 1. Players who arrive on July 1 having already seen the notice are much easier to handle than players who feel ambushed by a new rule. This signage also demonstrates to GLC inspectors that your location is actively communicating the change — a detail noted in our inspection guide.

5. When to Escalate — And to Whom

Not every situation has a clear answer at the counter level. Staff need to know who to call and what to do when:

• The gift card terminal is down or unresponsive.
• A card doesn't load correctly or the wrong amount is loaded.
• A player claims a card issued at your location isn't working.
• A player becomes hostile or threatening over the new payout method.

None of these situations justify giving cash. Staff should know that if the system is down, the correct answer is "I can't process payouts right now" — not "here's cash in the meantime." They should have a direct number for your gift card provider's support line and a clear chain of escalation: shift supervisor, then manager, then owner. Write it down and post it near the payout station.

How to Structure the Training

You don't need a formal training program — you need a documented one. Here's what "documented" means in a COAM compliance context:

Live Walkthrough With the Actual System

The most effective training happens in front of the real hardware. Once your gift card payout system is installed and live, run every relevant employee through the full payout procedure — from the player presenting a ticket to the card being handed back — at least once before July 1. Have them do it themselves, not just watch. Muscle memory for where to tap and what to enter matters when there's a line at the counter and a frustrated player on the other side.

Run through error scenarios too: what happens if a card fails to load, what happens if the terminal times out, what the screen looks like when a transaction is successful versus pending.

A Posted Quick Reference

Mount a laminated quick-reference card at or near the payout station. It should include:

• The payout procedure in numbered steps (specific to your system)
• The rule: no cash, no exceptions
• The player script for pushback situations
• The escalation chain (supervisor name and number, provider support line)
• The card balance-check instructions to give players

This reference serves two purposes: it's a real-time resource for staff under pressure, and it's visible evidence during a GLC compliance inspection that your location has operationalized the gift card payout requirement.

Acknowledgment Records

Have each trained employee sign a brief acknowledgment confirming they've been trained on the new payout procedure and understand that cash payouts are no longer permitted after July 1. Keep these records on file. The GLC requires COAM location licensees to retain records for the current year plus the last five full calendar years — training documentation is part of the compliance record that inspectors may request.

A one-page acknowledgment that says "I understand that cash payouts are not permitted for COAM winnings after July 1, 2026, and I have been trained on the gift card payout procedure" — signed and dated — is sufficient. It doesn't need to be legally complex. But its existence, if an inspector asks about your training program, demonstrates that you took the transition seriously.

Training for New Hires After July 1

Staff turnover is a reality in retail and hospitality — the sectors where most Georgia COAM locations operate. If you hire a new cashier in August 2026, that person has never worked in a world where COAM cash payouts were legal. They may bring assumptions from other states or other industries. Your training process needs to be repeatable, not a one-time pre-July event.

The simplest approach: build the gift card payout procedure into your standard new-hire orientation. Include the written acknowledgment sign-off in your new employee paperwork. Make the posted quick reference a permanent fixture, not something you put up before July 1 and take down after.

From an inspection standpoint, the GLC doesn't distinguish between violations by longtime employees and violations by people hired last week. If someone on your floor is handing out cash, you have a violation — regardless of how long they've worked for you or what they understood about the rules.

The First Two Weeks of July: What to Expect

Even well-trained staff will encounter situations in the first two weeks of July that weren't covered explicitly in training. Prepare your team for the reality that the transition period will have friction, and that the correct response to friction is always to hold the line — not to accommodate the player at the expense of compliance.

Expect these scenarios in early July:

• Players who insist the previous cashier gave them cash. That may have been true before July 1. After July 1, it's not possible — and even if it were, it wouldn't make it legal at your location now. Staff should acknowledge the player's expectation without validating it as a current option.
• Players who claim gift cards are "unusable" for what they want. A Visa or Mastercard prepaid gift card is accepted at millions of locations. The player may prefer cash — but the legal form of redemption is the card.
• Staff asking "just this once" exceptions for regular customers. There is no "just this once." Make this explicit in training and reinforce it in the first weeks of July when good-natured accommodations are most likely to happen.
• Technical issues with cards or the payout system. Have your provider's support number posted and your escalation chain clear. If the system is genuinely down and payouts can't be processed, document the outage — don't substitute cash while you wait for a fix.

The Bigger Picture: Staff Compliance Is Operational Compliance

Georgia's COAM compliance environment is more rigorous than it was two years ago, and it will continue to become more rigorous after July 1. The GLC's Compliance Inspectors are actively checking locations. The GBI's anonymous tip line routes complaints to investigators. Quarterly reporting data lets the GLC flag locations where machine activity and reported receipts diverge.

In that environment, the compliance burden doesn't fall on your paperwork alone — it falls on your operation at the moment of transaction, every day. That moment is owned by your staff. Their training is the difference between a clean inspection and a violation report that starts a penalty process.

The operators who will navigate July 1 and beyond without enforcement exposure are the ones who treated staff training with the same urgency they gave to getting their gift card system installed. Both matter. Both need to be complete before July 1. One is the hardware; the other is the human infrastructure that makes the hardware work compliantly every time.

With 35 days on the clock, there is still time to build that human infrastructure correctly. Start with your most frequently scheduled cashiers, run them through the system, document the training, and work outward to every person who might be behind the counter on or after July 1.

For the full compliance picture — systems, reporting, license renewal, and inspection readiness — see our Georgia COAM Compliance Checklist. For a detailed look at what inspectors evaluate when they arrive unannounced, our GLC Compliance Inspection Guide covers every category.

Action Items for This Week

1. Audit who handles payouts. List every employee — full-time, part-time, fill-in — who could be at the counter during COAM operating hours. That's your training list.
2. Schedule live training sessions for each employee before June 20, giving at least 10 days before July 1 for questions and reinforcement.
3. Print and laminate your quick-reference guide and mount it at the payout station before training begins — staff will reference it during the walkthrough.
4. Draft your employee acknowledgment form and collect signed copies from each trained employee.
5. Brief your payout provider on the training support they offer — many can provide location-specific training materials or a dedicated support number for staff during the first weeks of July.
6. Put up player-facing signage now, before July 1, so regular customers arrive on July 1 with prior notice rather than arriving as surprised.

None of this takes weeks to complete. A well-run location can close the staff training gap in a single focused week. The time to start is now — before the final pre-July operational crunch consumes all available attention on system installation and portal compliance.