Efficiency and Effectiveness of Public Information Center (PIC)

8. Efficiency and Effectiveness of Public Information Center (PIC)

ยท The Department"s Public Information Center (PIC) is one of the primary points for staff planners to provide information to the public. However, (a) service and information are unevenly dispensed, (b) policies and procedures for service provision at the PIC are not up to date, (c) physical arrangements and signage at the PIC are inadequate and sometimes confusing for the public, (d) accurate and useful data regarding public use of the PIC are not collected, (e) available technology applications are not used at the PIC, and (f) staff assignments to and rotation at the PIC are not made uniformly. Taken together, all of these symptoms reflect an operation that--while perhaps improved over historical service-- remains inefficient and does not always evidence necessary quality assurance measures in providing information.

ยท Since the Budget Analyst"s 1988 audit of the Planning Department, it has implemented the two recommendations made at that time for the Planning Commission; (set specific objectives for providing information services and establish hours of operation), and four of the six recommendations for the Director; full-time planners allocated to PIC, handout materials review, Information Manager reporting to Director, and enhance status of Information Office.

Public Information Center

The Public Information Center (PIC), located on the ground floor to the immediate right upon entering the 1660 Mission Street facility, is the Planning Department"s front line for face-to-face public interaction and primary delivery of basic planning services. The Work Program budget for this unit for Fiscal Year 2001-2002 is $1,027,000, covering 7.5 FTEs. In the 1988 management audit of the Planning Department, a total of eight recommendations were made by the Budget Analyst for the Planning Commission and the Director. The two recommendations for the Commission were accomplished and four of the six measures for the Director completed. The recommendations and their current status are shown in Exhibit 8.1, below.

Exhibit 8.1
Status of Prior Audit Recommendations
(December 1988)

Planning Commission

Status

ยท Set specific objectives for providing information services to the public and monitor progress on these objectives.

Completed and now shown in the annual Work Program, but formal monitoring needed.

ยท Establish 8:00 a.m. - 5:00 p.m. as the Information Counter"s hours of operation.

Completed; changed from 10 to Noon & 1 to 5.

Director of Planning

ย 

ยท Reallocate a minimum of two existing, highly qualified, full-time planners to the Information Office.

Completed and now w/ a core staff of five (see text, below)

ยท Require all Departmental planners, including the Assistant Directors, to provide public information counter service for two to three hours each week.

Staff services shared by all units in shift distribution, but no requirement for all planners.

ยท Have all written handout materials, including all of the various applications, reviewed for currency and legibility.

Review of materials an ongoing activity, but no time priority for revisions.

ยท Provide for the Information Manager to report directly to the Director for a period of one year.

Completed and Manager now reports to Director permanently.

ยท Rotate Information Office staff to regular staff assignments on a phased basis.

Not done.

ยท Enhance the status of the Information Office and assignment thereto in every way possible.

Ongoing

The PIC"s core staff of five Planners (two Planner IVs, two Planner IIIs, and one Planner I), along with the numerous Planners who rotate from the Neighborhood Planning and Code Enforcement, Citywide Policy and Analysis, and Major Environmental Analysis units are scheduled to provide nine hours of service daily to the public live and by telephone on four shifts of 2 hours and 15 minutes each from 8 A.M., through 5 P.M., including through the lunch hour. A student Intern currently augments the core staff on a reduced work schedule. Scheduling is arranged to provide from three to four staff members per shift. Distribution of the resulting 80 weekly work shifts among the different organizational units is shown in Exhibit 8.2, below.

Exhibit 8.2
PUBLIC INFORMATION CENTER WORK SHIFTS BY UNIT

UNIT
NUMBER OF WORK SHIFTS
WEEKLY
PIC Core Staffing Group
28
Neighborhood Planning (+TAC)
42
Major Environmental Analysis
6
Citywide Planning
______4
Totals
80

A review of actual staff coverage and completed work schedules, reflecting approved vacation and sick leave, confirmed recently improved staffing levels at the PIC -sometimes exceeding the schedule. The distribution of shifts and level of staff coverage at the PIC as observed over the course of this audit appear reasonable and appropriate for the volume of PIC activity.

Staff meetings of the core PIC staff are held each Monday at approximately 10:30 A.M.1 Included among the types of items typically addressed at these meetings are the following:

  • scheduling
  • potential problems with specific cases and issues,2
  • counter demands
  • proposed and pending legislation
  • application processing procedures
  • consistency of interpretations.

In addition to providing services directly to the public, the PIC"s core staff members have other responsibilities that include plan review, preparing Letters of Determination, forwarding cases to the Zoning Administrator for clarification, assisting with Web Site development and maintenance, and working on a broad range of projects as assigned.

Signage at the PIC is confusing and generally inadequate. Customers either go directly to the counter if no one else is there, stand in line when one is formed, sit in the waiting area when the counter is full and no line is formed, or as it happens more often when the counter is busy, go to the adjacent Department of Building Inspection (DBI) counter only to be referred back to Planning -and usually after waiting there. The two most confusing aspects of the signage are:

(a) the continuous header above the counter is numbered sequentially from right to left, and above the Planning Department section at the far right end is the number "1," causing -if not directing-many people improperly to go there, and

(b) between the Planning and DBI counter sections is a numerical ticket dispensing machine and an associated electronic message board that indicates the number of the person being served; however, nothing is there to clarify that this system applies only to DBI customers and not to Planning customers.

Another sign at the PIC specifies a 15-minute time limit on staff service, but it does not appear to be enforced -even when the counter is busy and other customers are waiting. Overall signage can and should be improved, including the elimination of the time-limit sign.

The PIC currently accommodates three customers simultaneously, two standing and one seated. Some chairs are available in the waiting area located several feet away from the service counter.3 PIC staff services are facilitated by three personal computers at the counter, three in the non-public rear workstations that are also used by the staff, and one computer is available in the waiting area for use by the public. This "Public PC" is made possible by a grant from the Friends of Planning. All of the equipment, excepting the Public PC, has access to the Department"s Parcel Information Database and the Department of Building Inspection"s Permit Tracking System. The Public PC cannot access the Permit Tracking System. The PIC will be physically modified -expanded-to accommodate an additional customer-service station at an unspecified future date. The expansion will include the placement of two additional computers for use by staff, bringing the staff total to eight (four at the counter and four in the rear workstations) along with the Public PC. Signage improvements could be made at this time if they are not already completed.

A revolving rack of various application forms and information handouts stands adjacent to the PIC entrance area. None of the bins on this rack was labeled, so it was necessary to read a portion of the different documents in the bins to understand specifically what they were. There was, of course, no way of knowing what is normally stocked in any of the empty bins. On the date of one field visit, 5 of the 16 total bins (31 percent) were empty. These bins should be labeled and stocked at all times.

Except for persons who have scheduled an appointment with staff at the principal offices on the fourth and fifth floors, project proponents, representatives, residents and the general public typically come to the PIC for information and assistance on the full spectrum of planning, zoning and development matters in San Francisco.4 Actual approvals can be authorized over the counter for the very limited number of planning cases that are exempt from requirements of the California Environmental Quality Act, that do not require notification of adjacent property owners, and for which there are no Block Book Notations on file with the Department.

A major generator of activity for PIC as well as other planning staff is the filing, monitoring and notification process associated with Block Book Notations (BBN). Block Book Notations are made by the Department upon request by any person or organization upon the payment of a fee.5 Such filing covers a period of one year and it prevents approval of any development application on the affected property within 10 days of the notification date. BBNs are maintained as a separate file in the Parcel Information module of the Department"s automated database. BBNs are on file currently for 84 separate filers, including organizations, with 93 notations that cover 302 blocks and 8,623 parcels in the City. Most of the Block Book Notation filers are individuals; however, the greatest impact derives from organizations. Within the universe of filed BBNs are those for 16 different organizations (only 19 percent of the total), primarily homeowner associations, that have paid $2,531 in fees for notations that cover 208 blocks (69 percent of all notated blocks), and 7,539 parcels (87 percent of all notated parcels). Checking on filed BBNs and providing the required notifications represent just two of the myriad tasks performed routinely by staff assigned to the PIC. However, BBN-related activity is seen as second in volume and labor intensity only to that required for Discretionary Review applications.

During this management audit, the general flow of customers and manner in which service was provided by Department staff was observed over several days. In addition, we noted actual numbers of visitors, phone calls and Public PC usage on a specific day. Over three hours of one specific site observation, the following service activity counts were noted:

Exhibit 8.3
PIC Service Activity Counts
Over a Three-Hour Period

ย 
Totals
Avg. Per Hour
Persons at Counter:
24
8
Telephone Service:
15
5
Public Computer:
____6
____2
Totals
45
15

Source: Audit Observation, February 2002

If the total service activity count of 15 combined customers per hour is assumed to be representative over a 9-hour work day, this would produce 135 units of service daily.6 For comparison, we examined the service activity recorded by the Department for October through January 2002. Tally sheets were maintained by the PIC staff for telephone calls and counter visits only, covering the above-referenced four months (no attempt was made to log PIC utilization prior to that time). These tally sheets do not accurately reflect the true service volume of the PIC because not all inquiries and calls are logged during times of high service activity7. Nevertheless, the tally sheets are currently in use and the information obtained from the audit sample revealed the following (please refer to Exhibit 8.4, below, for details):

ยท over a period of 69 business days in the sample, a total of 6,544 telephone calls and 5,409 drop-ins was logged for a total of 11,953 units of service;

ยท the average number of total service units was 173 per day, of which 95 were telephone and 78 were drop-ins.

Exhibit 8.4
Daily and Monthly Totals of Service Activity at
Public Information Center - Four Selected Months

Daily and Monthly Totals of Service Activity at Public Information Center - Four Selected Months

The audit field counts included all activity at the PIC, but over an extremely limited time period. Thus, the imputed 135 daily service units becomes 117 for a more direct comparison with the 173 average derived from the PIC data.8 Unfortunately, these numbers are of limited significance in light of the fact that they do not indicate any data that might prove useful for improving service, generally, and in structuring a PIC-specific, service-delivery training program. The use of the current daily tally sheet should be discontinued and a more relevant and sensitive instrument employed on a selective basis to obtain the best service data possible. Exhibit 8.5 below provides examples of what is not in the current tally sheet and what should be in the type of instrument suggested.

Exhibit 8.5
Examples of Information that, if Captured, Would Provide the Department
with Data More Useful for Improving Customer Service
at the Public Information Center (PIC)

1. Whether or not service call was based on a prior reservation.

2.Type of customer, e.g., owner, representative, contractor, architect, other.

3.Type of service, e.g., prospective or real time application filed, zoning and development potential inquiry, response to notification of pending action, inquiry re procedures, picked up forms, etc.

4.Materials provided, both free and purchased.

5. Where applicable, the nature, type and size of project, i.e., commercial, industrial, residential and within reasonable ranges of size and unit parameters.

6.Elapsed time for service.

7. Number ofusers of Public PC (some not necessarily requiring staff).

8.Customer satisfaction survey, including request for recommendations (card or single sheet that can be completed easily).

This type if information is important to the Department in two crucial areas: (1) it provides a level of specificity to facilitate design of training programs for PIC-assigned planners, (2) it helps in documenting the cost of various services. Thus, the specific implementation method of the recommendation for this item is tied to other components of the management audit, such as fee recovery, and reflects that linkage.

Observations

The management audit team also made the following observations during its examination of the PIC operation:

ยท The treatment of Departmental materials at the PIC is inconsistent in that some documents contain explicit language of enabling legislation regarding sale of the documents while other documents are silent in this regard and are given away to customers at no charge.9 If more information pertaining to the Department and its development regulation services were made available through its web site, this would become less of a problem.

ยท There does not appear to be a formal mechanism or procedure to ensure quality control of responses beyond the periodic PIC meetings involving all PIC staff, the Monday staff meetings, and the Friday morning drop-in "consistency" meetings that involve only PIC"s five core staff members. A written procedures manual for the PIC does exist; however, it is so outdated that it is never used by the staff.

ยท On one day, we observed staffing of the two afternoon shifts that included five staff members working the counter and phones, and three in the non-public work areas behind the counter for a total of eight staff members on each shift (previously noted from our review of completed work shifts). This may be too high an allocation of staff over an extended period.

ยท The three telephone cords in the PIC public area prove to be somewhat disruptive and an impediment to the flow of staff traffic, especially during periods of high service activity levels. These phones should be shifted to the non-public area and headsets considered for use by the dedicated PIC core staff when some services can only be provided in the public area (such as access to the Sanburn maps).

ยท Senior staff, both PIC and rotation, seemed relatively comfortable and authoritative in providing information both live and over the telephone, while the interns and junior staff almost always seemed to check with senior staff, appropriately, before giving out final answers.

ยท Petty cash is turned over to the Department"s administrative staff daily and activity is recorded on the petty cash transaction slip. However, there are no written procedures pertaining to the handling of funds at the PIC.

Customers" Views

The audit team interviewed one "customer" who attempted to use the Public PC, but who refused assistance from the planning staff because he didn"t want them to know the particulars of his situation.10 Instead, he was helped by a different customer at the computer who gave him information on the Planning Department"s appeal process, forms and meeting schedule, and who located and printed out from the Department"s parcel information system details of the property at the customer"s address. He was satisfied with the information he obtained and was impressed with the system, even though he did not use it directly. It is unclear what he would have done or what his satisfaction level would have been were it not for the availability of another knowledgeable customer to assist him.

The audit team interviewed another customer who was a representative from a wireless-industry firm in San Ramon. The company currently has 30 sites in San Francisco with transmission facilities and is now applying for an additional four sites (a conditional use permit application is in review and the assigned planner has requested more detailed information). This customer used the Public PC to find among several previously identified buildings those located in the NC2 Zoning District. The worker stated that the Public PC was a "nice tool" and the fastest means to locate lot and block information when provided only with an address.

A less positive experience at the PIC occurred when a member of the management audit team approached the counter for some information. He waited approximately 12 minutes during which time no staff member acknowledged his presence or told him that they would help him when they were done with their present activity. One staff member was talking to a customer at the counter and one was on the phone. Given this, the auditor was prepared to wait but as time went on, a simple glance or nod of the head would have signaled that help would be forthcoming. One staff member completed his telephone call and walked right past the auditor heading to the back room, saying nothing. At that point, the auditor stopped him and asked if he could get some assistance. The staff person told him that he could not help him as he was heading to the back room without any explanation of what that meant or why it precluded providing assistance. While the auditor was waiting, there were others sitting in the chairs in front of the counter and it was very unclear if they were "in line" in front of the auditor or simply sitting there waiting to see someone at some other counter. No oral or written explanation of the proper way to access staff was provided, other than a sign saying help would be limited to 15 minutes. If the auditor had not stopped a staff person and asked for service, it is not clear how long he would have had to wait in silence for service. Overall, the experience was very unpleasant and frustrating, all of which could have been easily averted with some very simple customer service. Waiting in line when there is an obvious reason is acceptable, but being ignored for extended periods of time even after the point when staff appears to be available is very frustrating.

While this is an obviously limited sample, it does include both novice and experienced customers with varying service needs and varying experiences, not all satisfactory. The visitor who used the Public PC did not have direct experience with staff but, on the other hand, a Departmental tool was available and it proved to be the source of the information he was seeking.

Miscellaneous Items

Four additional items surfaced during the examination with input coming equally from PIC and non-PIC staff members.

ยท A critical issue at the PIC is that the Planning Code is very convoluted; it is not readily understandable by anyone -either staff or members of the public. A prior project to make the Code understandable was abandoned some time ago and not revived.

ยท Another issue of note is that some planners view the PIC as an assignment below their stature -a non-prestigious assignment often made punitively.

ยท Some staff members are fearful of being assigned to the PIC because the public is far too frequently "in-your-face," beyond what seems appropriate for the professional level of service typically sought and provided.

ยท On-line, interactive access to the major regulations, guidelines, applications, fee calculations, and real-time project status information is seen as a major way to provide expanded public access while reducing the level of service demand at the PIC.11 This should be given the highest priority for the information systems section.

The audit team frequently heard the first of these issues from a variety of sources and, accordingly, believes the "simplification project" should be revisited. The team found nothing to corroborate the second item. For the third item, occasional irregular behavior by customers comes under the category of occupational hazard for which there are numerous training courses available to assist staff members cope more effectively. The last of these issues involves a different organizational unit within the Department that is dependent to a large extent on another City department to implement any applications involving the Internet. The item must be placed on the agenda for senior management to prioritize among other competing information systems demands. It is not something that the PIC can control.

Other Jurisdictions

Selected members of the PIC core staff participated in a survey of other jurisdictions to ascertain how the public information function is handled by other planning departments and what lessons might be learned for applicability in San Francisco. The jurisdictions included Los Angeles, Oakland, San Diego and San Jose. Costs associated with the Los Angeles and San Diego visits were borne by the Friends of Planning. Recommendations under consideration by the PIC staff based on these visits are listed in the table below.

Exhibit 8.6
Summary of Selected PIC Recommendations
Based on Other Jurisdictions

Customer Service Improvements w/ DBI

ยท install Q-matic system12

ยท install automated scheduling of inspections

ยท coordinated handouts from both departments

ยท one-stop style counter service

Physical Redesign Goals

ยท increase counter space for Planning & DBI, w/ additional stations

ยท comfortable seated stations

ยท clear delineation of different staff areas

ยท layout space for plans

ยท relocate telephones

Planning Information Counter

ยท place permit tracking, zoning maps, parcel information, fee calculations & major projects on line

ยท add another public computer

ยท provide a detailed Procedures Manual for PIC services

Public Access Improvements

ยท expand public computer programs and make more user friendly

ยท install FAXback Fax-on-Demand ยฉ programs

ยท clear handouts that explain standards

ยท environmental documents on line

The two issues of significance in this area include (1) the PIC staff are fully aware of the broad range of needed service improvements, and (2) rather than reinvent the wheel, staff examined models of public information and access in other jurisdictions. An overall improvement package for the PIC seems to be taking shape, with only the need for resources and management authorization to proceed.

PIC Feedback from Focus Groups

The Planning Information Center is viewed by some Department staff who participated in focus groups conducted for this audit as being unprofessional and as having interns assigned to work there who are not given sufficient instruction. They also believe that responses to the public from the PIC are inconsistent, and major tools and equipment at the PIC are of poor quality. To remedy these conditions, participants in the focus groups suggested that there should be more equitable staffing by the different organizational units and that no assignment should be made to the PIC until employees are properly trained. Additionally, they strongly urged updating the handouts, completely overhauling the PIC operation, making more planning information available on the web site, and revisiting the use of interns on the PIC at all or requiring a certain minimum of training before interns are allowed to work there.

Conclusion

The PIC is an essential part of the Department"s operation and while several discrepancies and inadequacies exist that prevent the PIC from realizing its full potential to provide an even higher level of professional planning services, including:

  • Signage is inadequate at best and confusing at its worst in the PIC. It appears, however, that signs and other aesthetic aspects of the PIC could be easily and inexpensively improved. Indeed, some improvements are planned for an unspecified date and funding is to be provided by Friends of Planning, an external not-for-profit organization dedicated to providing resources to the Department.

  • Other planned physical modifications should be accelerated, including furniture, telephone equipment and labeled information bins.

  • Scheduling of staff for the PIC appears to be improving with the current level being well above the previous three staff member per shift.

  • Data collection on service activity is inadequate and should be revised.

  • Greater emphasis is needed on staff training and quality control to ensure consistency of service provision and information accuracy.

  • PIC policy and procedures are outdated and not used. The Department"s information system capabilities related to the PIC are underdeveloped and if corrected, could reduce some of the service demands now placed on the PIC staff.

  • Reminders to staff are needed to treat people courteously and communicate to them when they will be helped when there are back-ups at the Counter.

Some of the suggested remedies can be implemented right away and combined with other long-term fixes to render the PIC an important service model for the public as well as a rewarding part of the professional development experience for staff. Given the nature and volume of service activity at the PIC, and in the absence of any substantive public outcry, this unit does appear to represent the Department adequately.

Recommendations

Based on the above findings, it is recommended that the Planning Director:

8.1 Accelerate the physical improvements to the PIC that expand the service area, revise signage, eliminate the 15-minute time limit on staff services (sign), install improved seating, and move telephones;

8.2 Employ a revised tally sheet to ensure useful and accurate data are collected, including:

(a) A more detailed data collection process should be accomplished during a two-week "ratings period" in the spring, summer, fall and winter of each year;

(b) Data should be maintained on a rolling three-year basis. That is, the results should be averaged over a three-year period with annual updates, adding the most recent year and deleting the oldest;

(c) The design of the modified tally sheet should accommodate input from planners in all organizational units to document their project activity as well as interaction with the public during the "ratings period." This will augment the time reporting system;

(d) The modified tally sheet should reflect streamlining to accommodate checklists for ease of planner use and input into the Department"s automated information system; and

(e) Managers should be expected to provide very close scrutiny and supervision as well as real-time approval over the completion of tally sheets and timesheets during this period. The process should be designed and implemented as a self-auditing one with the source documentation maintained in a separate, secured place in the Finance Unit.13

8.3 Emphasize the importance of PIC training for staff and see that service data are used to develop targeted instruction;

8.4 Encourage reservations for persons wishing to access planning services at the PIC;

8.5 Consider reviving the internal Planning Code Simplification Project to determine what resources are needed for its completion and then schedule if practicable;

8.6 Update, then implement a streamlined policy and procedures manual for the PIC including discussion of basic customer service and the importance of communicating to customers that help will be forthcoming when there are backlogs at the Counter;

8.7 Develop an assignment and rotation system that ensures balanced staffing for the PIC from all organizational units and enables employees who have expressed a preference for the PIC to be assigned beyond their scheduled shifts;

8.8 With assistance from the Department"s Chief Financial Officer, prepare and implement written procedures for handling cash at the PIC;

8.9 Designate a set number of hours per week for assigned staff to work exclusively on updating all handout materials; and

8.10 Vigorously encourage and support the prioritization of on-line computer applications as a means to provide accurate, consistent and timely information to users of the Department"s services.

Costs and Benefits

Costs to the Department for expansion and improvement of the Public Information Center cannot be accurately determined at this time, in part because of the potential funding from the Friends of Planning, a not-for-profit organization dedicated to providing resources to the Department. Similarly, implementing some of the information systems solutions is already budgeted -these item are more a matter of timing than of funding. Other proposed recommendations are actually net no-cost methods that replace existing practice. Overall benefits include more effective and consistent service delivery, and improved employee morale.

1 Unfortunately, the Information Services Chief who manages this unit and the Office of Analysis and Information Systems has a standing meeting at 11 A.M., with other Planner Vs and is not always able to stay for the full duration of the PIC staff meeting.

2 An example involves outdoor commercial advertising (billboards). On the ballot in the March 2002 primary election, Proposition G prohibits additional signs and regulates relocation of existing signs. This measure was viewed by many as one that will restrict the incomes of certain property owners. As a consequence, there was a rush of applications to obtain approval for signs before the election. [The measure passed by a margin of 109K votes (79%) to 29K votes (21%)].

3 During our inspection of the PIC, one of the waiting-area chairs was in ill repair and needed to be repaired or removed as it presented a hazard to the waiting public and was unsightly.

4 This does not include matters under the jurisdiction of the City"s Redevelopment Agency, Port, Transportation Authority, etc.

5 A project notification is given to the individual or organization requesting notification of project application when the following fee is paid: $25 per annum for the first address or first Assessor"s Block, and $10 per annum for addresses in each new Assessor"s Block thereafter. This matter is covered in Section 351- Miscellaneous Services, of the San Francisco Planning Code.

6 This is not an unreasonable assumption given that our analysis showed service activity spread almost evenly across the four work shifts (24% from 8 to 10:15, 27% from 10:15 to 12:30, 25% from 12:30 to 2:45, and 24% from 2:45 to 5).

7 This was readily apparent during one afternoon of field observation in which the telephones were occupied continuously for over one hour and there were at least 15 different customers at the counter. We checked the tally sheets before and after this rush, but the logged numbers were unchanged.

8 Tally sheets do not include use of the Public Computer, noted by the audit team at the rate of two visits per hour. Over nine hours this is 18 service units per day. 135 minus 18 = 117.

9 Examples of both include: Westwood Park Association Residential Guidelines, PC Res. No. 13521(5.6.93), no charge; Miraloma Park Residential Guidelines, PC Res. No. 14903 (10.21.99), no charge; Cow Hollow Neighborhood Design Guidelines, PC Res. No. 16147 (4.26.01), available for purchase.

10 This gentleman was a tenant facing eviction who wanted information on the specific property in which he had lived for the past 17 years. He knew that if his residence was a legal unit, he lived there more than 10 years and he was older than 60 that eviction was not allowed under local regulations. He did not know how to use the Public PC and had no previous experience with the Planning Department.

11 Currently, the Planning Code is available on line.

12 This is an electronic ticketing and noticing system to prevent long queues while enabling customers to know when it is their turn for service.

13 Finance is most appropriate for this placement because (a) the documentation on planners should not be in the custody of planners, (b) the data are integral to the fee recovery process, and (c) this location provides more direct access for management review.