The Horseracing Integrity and Safety Act's proposed 2026 budget has been out for its mandatory public comment period and is now before the Federal Trade Commission (FTC).
The topline comes out to just over $78.4 million. If credits to the industry are fully applied, then the cost to the industry is around $60.4 million.
HISA has already responded to nine public comments posted to the federal register. Its response, however, doesn't include those subsequently submitted by Churchill Downs Incorporated's (CDI) CEO, Bill Carstanjen.
CDI is hardly an impartial voice in this matter. The company is suing HISA because the 2025 budget was approved under the old formula for calculating assessments, based in part on purses. The current formula (based on both starts and purses) is set to change for next year (to one solely based on starts).
Nevertheless, Carstanjen's comments mirror in effect many of the questions and concerns industry stakeholders frequently raise about the cost of operating HISA.
For its part, HISA has broached budgetary matters from the public before, including a 90-minute Town Hall earlier this year. The organization has also posted a two-page factsheet on the budget.
To talk CDI's comments and next year's proposed budget in general, the TDN sat down Wednesday with Lazarus. The following has been edited for brevity and clarity.
TDN: Before we get to the budget specifically, let's quickly talk the sport's economic health. I've written a lot over the years about the economic dangers of concentration at the top end of the market hitting a winnowed out middle and bottom end. What's your response to fears of a shaky middle and bottom end of the sport?
LL: I would say some of that is a false narrative related to the fact that people have a general opposition to HISA because they don't want to be regulated. For example, Emerald Downs just had its best year in a really long time. Turf Paradise was just [leased] to an investor that plans to put some real money into Turf Paradise. Tampa [Bay Downs] has had a good year.
I would love for somebody to share with me which racetracks are struggling. I'll tell you who is struggling. Hawthorne's struggling because they half-built the casino and then stopped. There are [also] some existing conditions that well predate HISA.
For our product to be better and to be more professional, there does need to be some retraction. For example, it's hard to understand why certain racetracks are running at the same time in certain states.
Our job, which is welfare, we [need] to be able to deliver the right amount of racing for the horse population. We don't want to overtax the horses that we have and run them too often because we know that too many high-speed furlongs are one of the things that has the potential to cause injuries and ultimately death. So, do we have enough horses to run the races that we have?
I'm out there because I care about Finger Lakes and Tampa and Emerald Downs-racetracks that do a really good job on safety and care, but don't have access necessarily to gaming revenue or the same sorts of [horse] populations the strongest racetracks have. So, I agree that that's an area we need to focus on.
TDN: Let's get to the budget. Carstanjen points to this overall dynamic: While the number of covered races HISA oversees has dropped by around 25% between 2023 and 2025, the HISA budget hasn't fallen commensurately with it. As such, the per-start fee has risen sharply. Is the current per-start fee the right number?
LL: First, I'll say his numbers are wrong. He's basing his calculations on numbers that are not accurate. In 2023, we only had the [Anti-Doping and Medication Control] program for half a year. So, it's not a good barometer. In addition to that, he's not taking credits into account.
But putting all that aside, I do think that a per-start fee is a good barometer. And one of the challenges that we face there is, we're not at scale. Because of the Supreme Court case and litigation, we have some very big racing jurisdictions are not under HISA's authority, two of whom have tremendous number of starts, West Virginia, Louisiana, for example.
As we get to a resolution from the Supreme Court on HISA, we're either going to be all in or out.
If we're all out, then this conversation's irrelevant. If we're all in, that means that West Virginia, Louisiana, Texas, they'll all be part of the overall cost structure. And if you look at the numbers, because I've looked at them very carefully, the amount that they assume of fixed costs is much more than it takes for us to service them. So, bringing them into the system will make a huge difference.
The other thing about the 2023 numbers is that we included West Virginia and Louisiana in those numbers. We thought they'd be in. They ultimately ended up not being in. So, those numbers [used by CDI to calculate number of covered races] are just not accurate based on where we ended up at the end of the year.
Either way, there's very little correlation between the number of starts and HISA's costs. I think there's this sort of misunderstanding or misconception that the majority of HISA's job is to run an anti-doping program. We have so many more responsibilities than that.
We have technology responsibilities to build a portal, to collect information, to create risk assessment models. We've created five apps. We have integrated with about 12 different companies to make life easier for veterinarians when they put their billing records in. We do racetrack accreditations-we took over from the [National Thoroughbred Racing Association].
We spend a lot of time on jockey welfare, physical and mental. We have a national medical director who, when Brian Hernandez got hurt last week, was on the phone coordinating his care, making sure that his medical records were transferring. None of that happened before HISA. We have a national database now for jockeys that didn't exist before. We've public affairs initiatives.
[Note: The TDN followed up post-interview on the actual number of covered starts. According to HISA, there were 214,935 covered starts in 2024, and 220,635 covered starts in 2023. HISA's originally projected covered starts for 2025 is 173,988]
Bill Carstanjen | Coady Photo
TDN: Carstanjen claims HISA's administrative overheads have “created duplication and inefficiencies that are unnecessarily and unsustainably driving up the costs borne by the racetracks covered by HISA.” What's your response?
LL: It's the complete opposite.
It used to be that every state operated in its own silo, okay? [We] essentially built the system from scratch. Now, we're able to achieve these economies of scale by working directly with racetracks and commissions so that we're not duplicating jobs.
One of the best examples is, we took what was something like 15 labs countrywide down to four. We did a great service to the industry by getting rid of the labs that were unprofessional, incompetent, and frankly lacked integrity.
Now that we have fewer labs, we get much better pricing per sample. Like anything else, if you're going to give more volume to one lab, they're willing to be more accommodating on price. Same thing with shipping. Now, we have uniform equipment, we handle the shipping from one central place, and we take advantage of those efficiencies.
I think where Mr. Carstanjen gets that impression is how when HISA launched, a lot of changes happened in Kentucky statewide, particularly with their commission. Mark Guilfoyle came to work for us-he had been the head of the [former] Kentucky Horse Racing Commission.
And on top of that, the current administration [the Kentucky Horse Racing and Gaming Corporation] got sports betting and tripled and whatever [in revenues]. So, Churchill Downs hasn't seen those efficiencies as much in Kentucky as they've seen them elsewhere because of the growth of HHR and all the additional regulation that they've needed to put in place on the commission side.
TDN: While the budget has become more detailed with each passing year, I hear often from stakeholders they'd like HISA to much more thoroughly detail key aspects of the budget, including a detailed breakdown of salaries. Isn't this something HISA should be doing?
LL: Absolutely we should be giving as detailed a budget as possible. Anybody who writes to me or writes to our CFO and ask questions that are not answered by looking at our online documents, we answer those questions.
We're detailing as much as we can in terms of the salaries. There's only 26, 27 I think employees. [Some of] our salaries are already in our 990s, which are public. I think it's the top 10 or 12 [who are].
I've had to get used to this because I was never in public service before. I was always in the private sector. As a personal view, it doesn't feel great for people to know what you're earning. But as somebody who leads the organization with my senior staff, that is an understandable quid pro quo.
Laboratory technician | ARCI
We do what every other nonprofit does in terms of sharing the top salaries. Should [we] have to share the salary from a more junior employee? I'm not adverse to that. But that's also a little bit unfair to somebody who's just starting their career.
In terms of being accountable for how we spend salaries and at least sharing with the industry what we spend on salaries in the IT department versus the comm's department, that I am very happy to share.
And by the way, we're required to provide the FTC every year with a market index on our salaries versus market. They heavily scrutinize salaries. We do have significant oversight there. And we also have a board that approves our finances.
TDN: What about the vendors? A more detailed breakdown of requests for proposals, who responded, costs?
LL: I'm happy to be transparent and share information with anybody who wants it.
The challenge with saying, 'we're going to share because we have a lot of vendors and we have a lot of responsibilities to share every single proposal and every single process,' we're just going to end up increasing our costs because we're going to need more people.
It's a constant balance between what resources we want to spend money on and what sort of transparency we think is important. But certainly, if the feeling is that there's more information the public wants to see, we'll look at that.
TDN: The lab testing and sample collection expenses in the proposed 2026 budget are only slightly reduced from the 2025 budget. What explains this, given the decrease in races needing to be processed and the efficiencies you identified earlier?
LL: Because we were already realizing those efficiencies. They're not necessarily new efficiencies. [Some], they've [only] been in place since this year. We've only had four labs this year.
The money we spend with the laboratory isn't just on sample analysis. It's also on research, on making sure that, with certain substances that recur in our samples, we are in the right place from a science standpoint in terms of screening limits and all that.
For example, the Metformin study that we did recently should be completed any day now. That was funded through our lab testing budget line. That's a number that we use as like a credit line. If we can gain more efficiencies as time goes on, we won't spend up to that. We haven't spent up to the budget number for lab testing to date.
TDN: Another point CDI raises is the lower sample-per-race testing ratio in Kentucky now than pre-HISA (a ratio that's also lower at other states). Should the sample-per-start ratio be more uniformly higher across the country?
LL: It's a complicated question because the testing plan is based on intelligence, experience, and a number of different factors that are not just simply about volume. So, it's hard to say that we need to be at a certain test-per-race.
We're still figuring out what's the lowest number of tests that [costs] the least amount of money to feel comfortable that we're maintaining that level of playing field. But that's the goal.
Lisa Lazarus | The Jockey Club photo
TDN: Do you have a timeframe with which to get to that sweet spot?
LL: I can't say that we'll be there by a certain time, but it's something I'm seeing real gains with. We have debates all the time: Should we always test the winner? Should we be doing more out-of-competition and less post-race testing? Should we be doing less TCO2 [testing]?
These are things we talk about all the time in order to figure out where that sweet spot is, where we're spending the least amount of money but able to achieve what we need to deliver.
TDN: Factoring in the overall smaller proposed budget for 2026 (compared to 2025), as well as the proposed credits available to the states, it appears the net amount to be charged to the racetracks has increased over 2025 by $1.7 million. What exactly is done to ensure assessments are kept to a minimum?
[Note: While Lazarus responded to this question verbally, HISA also supplied written answers to the same questions once the interview was over. For the purposes of brevity, the TDN has used HISA's written response, the same substantively to Lazarus's comments]
HISA: The net amount has not increased. The 2026 Budget, after expected credits are netted out, is $60.6M. The 2025 Budget, after netting out credits actually given (versus expected/estimated credits from a year ago), is $61.4M. Therefore, the amount to be charged to tracks in 2026 has decreased by roughly $800K.
TDN: How and how often are assessments reimbursed?
LL: We bill monthly. The assessments are split 50 50 [between the horsemen and the track]. In some states, the commission pays for the entire invoice, like in Virginia, for example.
At the end of the year, we look at everything paid and compare it to what the actual numbers show, and we either give them a credit or tell them there's a shortfall.
TDN: Are all tracks and jurisdictions up to speed on their payments?
LL: The only racetracks in the country that have not paid HISA in 2025 are those racetracks owned and operated by Churchill Downs. In Virginia [where CDI-owned Colonial Downs is situated] the commission pays the assessment.
TDN: How is that impacting you?
LL: We haven't [had] to ask anyone for a loan or default on any of our obligations. And if you figure that Churchill Downs owes probably $8, $9 million, I think we're doing pretty well under the circumstances.
By next year, I hope we'll start to at least bring in or realize some outside revenue to start the process of basically decreasing the burden on the industry.
TDN: Right. In the Town Hall you mentioned how you're looking at raising revenues from HISA in other ways. Have you made any meaningful movement on this?
LL: I don't want to say too much yet, but the one area where we're pretty advanced is we have a tremendous amount of data.
We have enabled to package our data anonymized, so it's not exposing or connecting any particular benchmark or metric with us to the course, but in ways that are very attractive to insurers, to other jurisdictions, to companies that are producing either wearables or other interesting technologies for horse racing or even other horse sports.
We've also had some international jurisdictions reach out about licensing some of our technology because, believe it or not, [we're] seen internationally as being a first mover on having the portal that we have and some of the data analysis that's tied to it.
We're collecting about 5,000 records a day. We're well into 6 million records in our database. If we can work also alongside some other industry stakeholders, I think we can even magnify that opportunity.
TDN: You've said by 2035 you hope HISA to be financially self-sustaining. When can stakeholders expect to see some meaningful chunks taken out of these costs?
LL: What I'll continue to say is that by 2030, I think that stakeholders can expect that half of the assessments will be paid for by non-assessment revenues.
TDN: In April of this year, HISA has $2.8 million in outstanding loans and another $1.25 million outstanding in the form of a line of credit. What's the current status on that?
LL: I think it's the same.
TDN: From your discussions with the horsemen and the stakeholders, what other budgetary questions have you gotten?
LL: The cost rate for HISA is not an entirely new cost. They are essentially a 20% increase of costs that existed prior, which I think was the gap between where we were from an integrity and safety standpoint and where we are now, or at least where we're going.
Sometimes people will say to me, 'how is this too expensive?' And I'll say, 'okay, how is it impacting you? What do you find expensive?' And they can't tell me. There's nothing that's affecting their day-to-day life. They see numbers, and they're just saying it's expensive.
Part of it also, while commission budgets were available, nobody took all those budgets and put them into one number. So, the number feels big to people, especially if they don't understand how the credit system works.
The one thing I'm not interested in doing is running an organization that's just keeping the lights on and isn't advancing the sport.
I don't think there's much space to cut costs and still be able to deliver what we're required to deliver. I think the industry deserves a lot more and I'm really confident that in time, horsemen and racetracks will come to realize it's worth it ultimately.
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