Good GRAMA: Evaluating the State Records Committee Appeal Process

March 15, 2024

The Legislative Fiscal Analyst’s Performance and Operations Team recently published two new efficiency evaluations of state agency programs:

Last December, we highlighted some of the operations methodologies that the team uses for process improvement. In this post, we describe how various methodologies relate to each of the recommendations made to the State Records Committee for their appeal process for Government Records Access and Management Act (GRAMA) requests. Separate from their auditor counterparts in the Office of the Legislative Auditor General, the Performance and Operations team strives to provide consultant-like services to state agencies with the goal of improving outcomes for Utah’s citizens.

State Records Committee
When a GRAMA request is denied, a member of the public can appeal the decision to the State Records Committee (SRC). The committee is made up of seven volunteer members representing the media, private sector, public, and state and local government. The Division of Archives and Records Service, housed within the Department of Government Operations, staffs the SRC.

The SRC works to find a balance between providing the public access to government records while ensuring statutorily protected records maintain their limited distribution. Dealing with hundreds of cases per year, the committee spends many hours understanding both Utah’s record laws and the perspectives of all parties involved.

After reviewing current practices, the team, along with the Governor’s Office of Planning and Budget (GOPB), made three recommendations aimed at boosting efficiency, clarity, and effectiveness of the appeal process:

  1. Formalize internal procedures for managing received appeals through the entire State Records Committee process. The intent is to develop standards so that staff spend less time on incomplete cases while improving the accuracy of information received. 
  2. Use the role of the ombudsman more effectively and strategically. The ombudsman is a fancy term for someone appointed to investigate and facilitate resolution of complaints. This recommendation centers on using this role proactively to resolve cases before they reach a hearing, and to clarify how the executive secretary and ombudsman work together during the process.
  3. Standardize the facilitation of State Records Committee appeals. The intent is to determine if the SRC should be a formal body in how they facilitate appeals. Where recommendation one aimed to standardize internal case management, recommendation three looks to clarify the role of the SRC, and the formalized administration of the hearings. 

Principles of Process Improvement
The recommendations were based on the following process improvement principles:

  • Standardizing work: documenting a process leads to greater consistency. In the case of the SRC, this means using clear terms and definitions that help citizens navigate the appeals process.
  • Triaging and batching: by grouping similar types of cases and treating them the same, this should help all customers move more quickly through the appeal, saving time for both agency personnel and citizens.
  • Full kit: keys to reducing frustration include: making sure everything the committee needs to process a case is available before starting a review, and ensuring citizens know which documents are needed for a complete application.
  • Visualization through process mapping: knowing how a case should proceed through the system helps employees know when a case is on track and provides insights for improvement opportunities.
  • Control work-in-progress (WIP): too many overlapping, unfinished cases result in decreased work quality and tends to lead to longer resolution times. WIP can also drain employee morale, as staff are faced with an unmanageable caseload.
  • Front loading: address problems at the beginning of the process that are more costly and difficult to solve later. With the ombudsman resolving simple cases before a hearing, the SRC’s workload can decrease, saving time for more difficult and nuanced cases. 
  • Synchronization of resources: aligning work performed with system priorities can reduce the length of time a case is open, leading to both manageable caseloads for employees and shorter cases for citizens. A win for everyone involved.
  • Mistake proofing: incorporating automation within a process can reduce human-caused error. For the SRC, this applies to time limits (automated through use of a mechanized timer) and other hearing specifications.
  • Buffer Management: planning strategies to identify extra or needed capacity to handle an increase in work due to a crisis, seasonality, or other factors.

The Performance and Operations Team is currently hard at work (along with GOPB) evaluating efficiencies in the Department of Corrections. Stay tuned for their next report which is expected to be released later this year.