Tracking Records Requests and Reporting PRA Metrics (JLARC Reporting)
This page provides guidance on how to comply with tracking records requests and reporting PRA metrics requirements for local governments in Washington State, including sample policy language.
It is part of MRSC's Electronic Records Model Policy Tool Kit, created in partnership with the Washington State Auditor's Center for Government Innovation.
Tracking Records Requests
In 2017, the State Legislature adopted ESHB 1594 which, among other things, requires all agencies to track and log the following information with regard to public records requests:
- Identity of requestor (if provided)
- Date and text of request
- Description of records produced in response to request
- Description of records redacted or withheld and the reasons for redaction/withholding
- Date of final disposition of the request.
Agencies with $100,000 or more in annual staff and legal costs associated with fulfilling public records requests during the prior fiscal year must take this tracking several steps further (additional tracking is optional for agencies with costs of less than $100,000/year). These agencies must track additional information related to records requests and report the information to the Joint Legislative Audit and Review Committee (JLARC) annually by July 1.
Although not required by the PRA, an increasing number of Washington agencies are using portal software to assist with PRA responses, such as GovQA, NextRequest, and Airlift Response (cloudPWR).
These public records portals allow for administration and tracking of PRA requests and agency responses from a central online location. All requests are processed through this system and requesters are able to set up a personal account through which they can submit requests and track the agency’s response to their request.
The logging and JLARC reporting requirements are codified at RCW 40.14.026(4) and (5) respectively. JLARC also provides information on its public records reporting website, has detailed agency guidance, as well as reporting instructions. In addition, MRSC published a blog article with FAQs on reporting requirements, JLARC Unveils Public Records Reporting System.
The JLARC reporting requirements are quite detailed. The following suggested policy language is designed to call attention to the reporting requirements to agency personnel, assign responsibility for complying with the requirements to the agency public records officer, and authorize the agency to obtain technology and resources that will assist agency staff in meeting the requirements.
Sample Policy Language - Drafted by MRSC
The public records officer for the Agency shall maintain a log of all public records requests submitted to and processed by the Agency, and, at a minimum, shall record the information required in RCW 40.14.026(4) as it now exists or may hereafter be modified.
In addition, the public records officer shall be responsible for meeting the Agency JLARC reporting requirements set forth in RCW 40.14.026(5), including the following:
- Determining whether actual staff and legal costs associated with fulfilling public records requests for the prior fiscal year were $100,000 or greater for the purposes of RCW 40.14.026(5) and reporting that information to JLARC;
- Tracking and reporting to JLARC the metrics set forth in RCW 40.14.026(5)(a) through (q) if Agency staff and legal costs for the prior fiscal year are $100,000 or more;
- Reporting to the Agency governing body, or its designee, on staffing, technology and any additional needs for the purpose of fulfilling JLARC reporting requirements;
- Recommending to the Agency governing body, or its designee, whether the Agency should voluntarily report the metrics set forth in RCW 40.14.026(5)(a) through (q) if the Agency’s staff and legal costs associated with fulfilling public records requests for the prior fiscal year were less than $100,000.