If a FOIA request costs £293, how much does it cost to answer a letter?

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Over the past couple of years, I have seen an increase references to the cost of FOI requests.

When the cost is calculated, it is usually use a number methods (Opportunity Costs, Activity Based Costing (ABC)), or just asking the number of hours and multiplying it by £25, the statutory amount used to calculate the fees notice. For example, here is some early research on the costs from CIPFA http://www.cipfa.org.uk/thejournal/download/jour_vol7_no1_d.pdf

Over time, the calculations became more sophisticated. In some cases, these figures represent the full cost of the FOIA service within an organisation. In other cases, it is just the cost for the request.  Here is some more recent research by UCL on it (2010).

http://www.ucl.ac.uk/constitution-unit/research/foi/countries/cost-of-foi

In this research, it suggested that an average cost for an FOIA request response in the UK was £293 per response.

Table 18: Cost of one FOI request in British Pounds

Cost in £GBP** (UK figure taken from 2005 and methodologies vary by countries).

U.K.                293

Scotland        189

Ireland            364

Canada          637

Australia        748

U.S.                248

(Source http://www.ucl.ac.uk/constitution-unit/research/foi/foi-and-local-government/2009-foi-officials-survey.pdf (p.50))

On one level, this is welcome and expected because it suggest that FOIA is maturing as activity. The organisations are beginning to fit it into a cost and performance management framework. Yet, despite that positive assessment, there are those who may see this in a less benign light.  For example, some may see the reference to an opportunity cost as a way to deter applicants? Perhaps this is the price of transparency. Is the cost, an attempt to show the regulatory burden faced by organisations? One must remember that when FOIA was first agreed, the ODPM (now DCLG) gave a small grant to local authorities, after much lobbying about the potential cost of FOIA on local government, to offset the expected costs of implementing the Act.  The questions are interesting, but my focus here is on something more mundane-the cost of responding to a letter.

How much does it cost to respond to a letter?

We have seen organisations calculate the cost of responding to an FOIA, but what is the cost of responding to a citizen asking for advice (a non-FOIA request) or a complaint (non-FOIA again) or any other business as usual requests that a Council receives?

It strikes me as odd that we can calculate one type of correspondence so accurately, but at the same time miss the rather obvious cost of responding to a letter. Before FOIA, there must have been a cost to responding to letters. Moreover, there must still be a cost to responding to letters and emails today.

I have searched the internet around issues such as channel migration or channel shifting in which customers are moved from high cost interactions (such as face to face) to lower cost and higher convenience ones (like online access). In the various documents, I found there were references to the lower cost of online and face-to-face being the most expensive. However, I have yet to see the cost of responding to a letter.

I realize that some letters or emails may need more work or involve specialists (children’s services or Adult Care issues), and some complaints can become complicated. Yet, there has to be a cost of business as usual requests (non-foia requests) just as a “cost” to FOI requests.

If the cost of responding to an FOIA comes in at £293, what then is the cost of responding to a letter? Are they easier or harder to respond handle? Do complaints cost the same or are they more expensive? What is it exactly, that makes an FOIA so expensive to answer? Is it one of the four steps set out in the ICO guidance note on fees notices?  http://www.ico.gov.uk/upload/documents/library/freedom_of_information/practical_application/usingthefeesregulations.pdf

When we look at letters and emails that come into contact centres, they come in by the thousands year (Barking and Dagenham show they receive on average 1300 emails a month to their contact centre alone.  http://www.lbbd.gov.uk/AboutBarkingandDagenham/PlansandStrategies/Documents/customer-access-and-channel-strategy.pdf (p.15) (I chose their figures because they came up first on a Google search) By contrast, FOIA requests come in their hundreds (at most authorities) per month and most authorities may handle over 700 FOIA requests in a year. For more detail, see the UCL research on requests.

What is it about FOIA that makes them so expensive? The contact centre receives and responds to 1300 contacts a month. I would not imagine that they cost £293 per response.

One might argue that the FOIA requests are much more complex and need specialists to handle. This is true. There are costs associated with exemptions. Yet, the UCL research over the last 5 years shows that, on average, organisations use exemptions in less than 10% of the responses and those lead to internal reviews in 20% of the cases.  http://www.ucl.ac.uk/constitution-unit/research/foi/foi-and-local-government/FOI-Surveys-5-year-Summary-01Dec2010.pdf (p.1)

Thus, we return to my original question. How much does it cost to respond to a letter?

I would be interested to know if anyone has done any research on the average cost and average time to respond to a non-FOIA letter. Has anyone done any Activity Based Costing on them?  I have looked at channel migration strategies and service migration research, but I have not found anything. I can find cost per contact, but nothing specifically on the cost of responding to an email or a letter.

I would be interested in your views on the issue and your thoughts about why FOIA requests are so expensive on average?  Is this a question of improving knowledge management to cut costs?  Are there less expensive channels offered by social media and microblogging to improve response rates and quality of responses?  There are a number of ideas to consider if one wants to drive down the cost and improve the response rate and quality.

Finally, I would be interested in the views as to whether this represents a new trend in public services where all services are “costed” so that citizen or customer can know what they have paid for any why.  At the same time, though, it could raise the issue of how much some people “cost” an organisation.  However, one doubts that such an approach would take root given the strong focus on efficiency and the need to sustain services in the face of the growing challenges within the public sector. In any case, that is a subject for a different post.

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• Why Agencies Should Not be Allowed to Lie About FOIA Requests (nsarchive.wordpress.com)
• Geoffrey R. Stone: When the Government Lies (huffingtonpost.com)