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The State Bar of California

Process Improvement Analysis

Findings and Opportunities

December 14, 2012

Revised Draft

State Bar of California Process Improvement Analysis Page 1 of 13 Draft Findings & Opportunities 12/14/2012 Framework LLC

I. Overview

Framework LLC was asked by the State Bar of California’s Chief Financial Officer to complete a

focused review of selected business processes performed by the Office of Admission’s Operations

and Management (O&M), Examinations, and Administration Departments. The objectives of this

review were to:

1. Document business processes and identify opportunities for process improvements within

the following functional areas:

Registration with the Committee of Bar Examiners

Exam application (First Year Law Student, General Bar Exam)

Eligibility evaluation (law study evaluation, pre‐legal eligibility evaluation, law office

study evaluation and management)

Examination administration (site reservation, preparation, staffing, materials

management, system set‐up)

Testing accommodations

Examination grading

Motions

2. Determine the extent to which processes are people‐dependent or may be at risk given

planned retirements,

3. Identify opportunities to use information technology more effectively that can be included in

agency plans to replace key computer systems over the next few years,

4. Develop process analysis tools, reporting formats, and methods that can be used to analyze

other processes, departments or programs.

The primary product of this review is a set of “as is” process flow diagrams and descriptions (under

separate cover). This report describes findings and process and/or technology opportunities that

were identified during this analysis.

For the purposes of this report, a business process is a collection of activities that takes one or more

kinds of inputs and creates an output that is of value to the customer. Processes may (and generally

do) cross organizational units. An activity is a concrete, tangible, and discreet piece of work carried

out by an individual. A function is a collection of related business processes and activities.


II. Summary of Findings

The O&M department and the Examination Grading section are for the most part executing complex,

mission‐critical business processes with a minimum of errors and according to required timeframes.

Processes are successful in large part because employees are long‐tenured and very knowledgeable

about process steps and business rules. There are risks to the organization as employees retire or

leave, but risks are partially mitigated in O&M by the presence of complete and current written

procedures. (Examination Grading’s procedures are in transition.) Risk could be further reduced by

making use of appropriate technologies to help replace manual, paper‐dependent processes.

The Office of Admissions plans to implement technology improvements to support/enhance

application management, project management, and materials management. All processes would

benefit from expanded use of imaging and document management/sharing technologies.

There are significant opportunities for process improvement in three high‐risk functional areas:

testing accommodations, examination grading, and motions. Processes in these areas should be

evaluated in advance of the implementation of the new Admissions System.

Process Observations

Most processes are paper‐intensive. In some cases, paper is used because there is no alternative for

sharing the information contained in key documents. In other cases, paper records are “more

comfortable” for graders or analysts to use in making determinations, or are needed to support

litigation. Extra copies are created at various process points in order to maintain a record of

information that is not available electronically.

Processes often require extensive correspondence between applicants, law schools, and the State

Bar, creating a large volume of correspondence to be managed. O&M makes effective use of bar

coding technology to manage key documents and forms. However, an O&M Administrative Assistant

manually logs all letters and certain forms or applications.1 Correspondence that requires a response

is manually logged before a bar code tracking slip is attached.

Some impacts of the State Bar’s reliance on paper include:

O&M devotes a significant amount of Los Angeles office space to files and offsite storage of

archived files. The Los Angeles file room is 1,133 square feet. The offsite warehouse contains

approximately 205 boxes at 1.2 cubic feet of storage space per box.

1 According to Examination Administration procedures dated 4/25/2012 these include Social Security Exemption Forms, Withdrawal Forms, requests for refund of fees, wall certificate orders with credit card information, test center changes, applications for testing accommodations, and requests to begin law study again.


Applicant files can only be maintained in one location at a time and must be physically

transported by courier to the other office if a physical record is needed.2

O&M determined that it would not attempt to file transcripts and certifications in the individual

applicant’s file because demand for these documents is low. These are maintained in boxes in

the file room.

Paper‐based processes can be labor‐intensive. The Examination Grading section spends

approximately three weeks after each general bar examination printing, assembling, sorting,

filing and coding laptop examination booklets. The section recruits up to 20 temporary

employees to assist with this process.

O&M produces a high volume of letters and notices, many of which are manually created using

Microsoft Word templates.3 Re‐keying of applicant information in letters and notices increases the

probability of error. While some letters are saved to shared directories for common use, most are

retained in hard copy. (The Bar’s Information Technology Department is planning to implement a

SharePoint‐based document management solution, but it is not clear that Admissions was included in

this project.)

Two processes are subject to excessive verification or review:

Grading re‐counts and prepares an audit list of completed Multi‐State Bar Exam (MBE) forms

received even though forms have been counted and packed at the exam site. (The administrator

reports that they “rarely find errors, but errors do happen.”)

The Senior Executive of Admissions reviews staff and consultant determinations on petitions for

testing accommodations at least twice: first at the time a transmittal sheet with a

recommendation is created and again at the time a decision letter is generated.4

Handling and movement of materials in Grading appears to be excessive. Several of Admission’s

processes require physical handling and movement of large quantities of materials. In the case of

Grading some handling appears to be excessive. Grading sorts examination booklets by applicant

number and then re‐sorts or “interfiles” them so that they may be stamped with a code number.

Booklets are placed on shelves in code number order. To prepare for grading, staff must re‐sort

booklets by grader range and question number. After grading, booklets are returned to the shelf in

code number order.

2 According to the Senior Executive of Admissions, moral character files that are assigned a rating of “1” or above are transferred between offices so that analysts may work with the physical file.

3 The IBM i5 (aka AS/400) produces 62 automated letters for Admissions, 33 of which are related to processes and activities other than moral character evaluations. We found 25 examples of letters that must be generated using Microsoft Word templates or copies.

4 This process may have changed, as testing accommodations processes are in transition.


Very few processes are evaluated using performance objectives or measures. In a few cases,

process timeliness is dictated by state law or State Bar policy. The Office of Admissions has not

established measures of efficiency, effectiveness or service levels for most of the processes we

reviewed.

High‐Risk Functions

Three functional areas present special risks to the State Bar:

Testing Accommodations processes are used to determine if examination applicants with

permanent or temporary disabilities should receive special accommodations or considerations

during the exam. We found process, technology, staffing, and organizational issues that have

contributed to errors and workload management challenges. Errors can directly and adversely

impact examinees if correct accommodations are not available on the examination date. The

examination application calendar leaves no room for error. Any processing delays on the part of

the Bar could compromise a last‐minute applicant’s ability to appeal testing accommodations

decisions. Decisions are subject to litigation by disgruntled applicants, and contested decisions

have attracted media attention in the past.

Examination Grading processes directly impact individuals who have taken a bar examination.

The Director of Admissions Administration is integrally involved in all aspects of this complex

process, and without her direct supervision the process could fail. Written procedures are not

up‐to‐date.

Motions processes include monthly and post‐examination processes used to refer eligible

candidates to the California Supreme Court for admission to the Bar. Weekly motions are

initiated by staff in Los Angeles and are completed in San Francisco. Any errors or omissions in

the motion can results in substantial negative press for the Bar, as happened with the Sergio

Garcia case. It was not clear from this limited review5 that the motions process is well

understood by all participants.

Employee Tenure and Experience

O&M’s business processes are complex, and successful performance is largely dependent upon the

knowledge and skills of senior employees. Certain eligibility processes require knowledge of

complex business rules and policies. Other processes are less technical in nature but require

significant attention to detail. The average tenure of employees we interviewed within Operations

and Management was high (15‐18 years) and staff turnover appears to be very low. The Grading

Section also includes very experienced employees. Two “temporary” employees in Grading have

been with the agency for many years.

5 We did not interview representatives from General Counsel.


While there is a risk to business processes as senior employees retire or leave, this risk is partially

mitigated by well‐documented procedures, at least for O&M. O&M has compiled complete and

well‐organized procedure manuals. Written procedures vary only slightly from the processes

described in group interviews, indicating that the procedures are current. Grading’s written policies

and procedures are outdated, although the Director for Admissions Administration and the Section

Chief are in the process of updating them.

Impact of Location on Business Processes

While most of the processes examined during this review are conducted either in Los Angeles or San

Francisco, three functions include processes that require significant interaction and some document

hand‐offs between the two offices. These are:

Testing accommodations. Responsibilities are divided between San Francisco’s Admission

Administration Department (petitions for new accommodations, petition tracking) and Los

Angeles‐based O&M (continuation of existing or same accommodations, preparation for

examinations.) Most documents are available to employees in both offices on a shared directory,

but some petitions and related correspondence are delivered between offices as needed by

courier. Lack of automated systems support for testing accommodations has complicated

communication between the offices. Prior to August of this year, Examination Administration

staff relied on petitions and letters posted to the shared directory to confirm accommodations.

In August of 2012 a screen were added to the AS/400 to display requests for certain

accommodations such as assistants, wheelchair access, or special equipment. Information about

petitions from individuals who have not yet applied for examinations is only available to

Examination Administration using a shared Excel spreadsheet.

Motions. O&M’s Application Pre‐Processing section in Los Angeles is responsible for creating a

list of candidates eligible to be included on the weekly motion. A staff person in San Francisco’s

Moral Character Department prepares the motion, obtains an attorney’s signature, and transmits

the motion packet to the Supreme Court. Los Angeles receives and records the Supreme Court’s

action in the AS/400.

Moral character. Pre‐processing of moral character applications occurs in Los Angeles, while

moral character evaluations occur in both Los Angeles and San Francisco, depending on rating.

(The moral character function was outside the scope of this review.)

All applicant files are currently maintained in Los Angeles, and must be shipped by regular courier

service to San Francisco if they are needed for any reason. In practice, only selected moral character

files and files needed for litigation support moved between offices. O&M Examination Administration

ships and receives examinations, materials and supplies statewide, and is highly dependent on ready

access to a loading dock and a secure warehouse.


Use of Technology to Support Business Processes

O&M and the Examination Grading section have developed creative manual processes to compensate for shortcomings in technology. Legacy systems supporting business processes do not include all functionality required for efficient and effective process execution, and will be replaced during the planned Admissions System Replacement Project. Some of the shortcomings we observed:

Some document imaging and sharing capabilities are available, but usefulness is limited. Images

of documents can be preserved in shared directories, but because they are not indexed or key‐

word searchable employees rely on hard‐copy versions for research. Non‐imaged documents in

shared directories are searchable only by using tools such as Windows Explorer. The State Bar

plans to use Microsoft SharePoint to improve its document management capabilities.

Support for event tracking or project management is inadequate. Most of O&M’s business

processes require tracking and management of documents and events according to a fixed time

schedule. For example, O&M must ensure that applications for examinations are complete and

cleared prior to the examination deadline date. O&M must also ensure that exam site

preparations are coordinated well in advance of the actual examination date. The AS/400

supports basic Eligibility processes such as registration clearance and application tracking, but

has limited ability to support other functions.

Daily downloads/uploads of registration and application data require human intervention.

Inability to view history or snapshots of data in the AS/400 is leading to retention of hard copies

of system‐generated reports. For example, O&M’s Examination Administration and Eligibility

sections retain and file copies of the daily “Online Registration Upload Report” because a

snapshot of the information contained in the report is not retained by the AS/400.

Similarly, the AS/400 creates a snapshot of the master record post‐motion, but does not provide

a snapshot applicant status that can be used to determine who should be included on a motion.

This has resulted in the need to lock‐down the application (restrict access) during upload of

grades and preparation of the post‐examination (mass) motion.6

To compensate for technology shortcomings or limitations, O&M, Examination Administration and

Examination Grading have developed stand‐alone applications and tools using Microsoft Access and

Excel. O&M’s Technology Services Analyst has created at least eight data base applications and a

variety of spreadsheet‐based applications. Similarly, Admissions Administration has created a stand‐

alone spreadsheet application for tracking Testing Accommodations. These are maintained by the

6 A Work Order Request to create this snapshot has been submitted to IT, but according to Arlene Lyne it has yet to be evaluated.


analyst or by users – not by State Bar Information Technology – and data contained in these

applications are not available for agency‐wide use.7

7 The TA Tracking Spreadsheet is available to users of a shared directory.


III. Opportunities by Functional Area

Testing Accommodations

Re‐design business processes to reduce errors and improve process efficiency. Some of the process

issues we observed include:

Quality reviews are insufficient to catch errors in letters, notices or schedules. Letters or

notices are not automated, and staff must re‐type applicant information into Microsoft Word

document templates. Errors have been made in applicant number, type of examination

(writing, laptop) and in accommodations granted. Some errors made in San Francisco may be

caught and corrected by Los Angeles personnel but others are found only by exam site

personnel. According to O&M personnel in Los Angeles, errors found in letters result in

problems two to three problems that must be corrected by Examination Administration each

exam. Errors are usually not serious, but require last minute adjustments

Decisions are documented and submitted for approval twice: first using a “Transmittal

Sheet” and then detailed in a “Decision Letter”. It appears that this process was

implemented to ensure that backlogs in letter‐writing did not impact decision timeliness.

However, the dual process appears to be inefficient and may actually increase staff

workload.

Digital versions of original notices/letters are overwritten in the shared directory as errors

are corrected, leaving no digital record of the original notice. Hard copies are maintained, but

digital copies are the primary tools used for communication about accommodations between

San Francisco and Los Angeles.

Letters granting same accommodations as a prior examination are issued from the Los

Angeles office. Applicants submit petitions for changes to San Francisco. Interviewees cited

instances where late changes to an applicant’s disability status were made in San Francisco at

the same time Los Angeles staff were generating a same accommodations letter for the

individual.

Improve applicant tracking capabilities. The AS/400 does not support tracking of applicants who

have requested testing accommodations but have not yet registered for an examination. (Individuals

are encouraged to submit petitions well before an examination to allow for adequate review.) These

individuals are tracked by San Francisco staff in a separate spreadsheet that is not visible to O&M in

Los Angeles. Additionally, O&M must manually match letters, forms and correspondence (hard copy

and imaged) to each record in the AS/400 or the spreadsheet in order to track petition progress.

In August of 2012 Information Technology implemented two changes in the AS/400 to improve

communication between San Francisco and Los Angeles. Testing Accommodations staff can now

indicate if an applicant has requested an assistant, special equipment or other accommodates that


must be arranged by O&M as soon as the applicant’s request is reviewed and approved. Staff can

also access and use a consultant tracking screen to record referrals of petitions to consultants.

Determine if staffing is adequate to meet workload requirements. Confirm the extent to which

workload management problems develop as examination dates approach. Last‐minute petitions test

staffing capacity, impact O&M’s ability to make examination arrangements and restrict an applicant’s

ability to appeal in time for an exam. Staff indicated that the letter acknowledging the receipt of a

petition may not be sent during high workload periods, but this letter is not critical as the exam date

approaches.

Establish written guidelines for evaluating accommodations based on type of disability.

Interviewees were concerned that decisions to grant accommodations for physical disabilities are

overly subjective, and are not based on written decision guidelines or policies.

Develop written procedures to support re‐designed processes. Interviews revealed that the testing

accommodations processes and procedures are understood differently by management and staff. A

common, written understanding is needed.

Redirect incoming mail. The “Petition for Testing Accommodation” (Form A) does not instruct an

applicant to forward the completed petition to San Francisco. (Both office addresses are identified on

the petition.) Any petitions that are mailed to Los Angeles must be sent by courier to San Francisco,

adding delay to the process.

Reconsider State Bar deadlines for exams and petitions. State statutes require that applicants must

petition for testing accommodations no later than the deadline to apply for an examination.

However, if a petitioner waits until that date he or she may not have time to appeal a determination

before the examination begins. While there is a legitimate concern that applicants requiring

accommodations should not be treated differently than other applicants, the Bar should also

consider the applicant’s loss of right to an appeal.

Confirm organization, roles and responsibilities. In the absence of effective leadership, the Senior

Executive for Admissions has been heavily involved in both the leadership and execution of this

process. The testing accommodations function was placed under a new Director of Examinations in

June of 2012, and roles and responsibilities for this function are being redefined and discussed with

the Section Chief and with staff. These roles and responsibilities should be documented as they are

developed.

Grading

Re‐visit the exam coding process. Currently, the Examination Grading section re‐codes examination

booklets prior to grading so that there is no potential for graders to match individual test takers with

an exam booklet. This process is labor‐intensive and depends on competent and experienced

employees to prevent errors. Employees use pre‐generated code numbers that are generated by the


California Bar Grading System (CBG) which must be added to each exam booklet. Two temporary

employees sort (“inter‐file”) exam booklets into code number order by mentally converting applicant

numbers into code numbers. A third employee writes the code number on each examination

packet/set of booklets. Exams are then carried to an area where employees stamp the code number

over on each booklet, based on the handwritten code number. After coding is complete, exams are

shelved in code number order.

The Bar should explore new ways to assign the code number that would eliminate the need for

manual sorting, coding and stamping. For example, a bar code could be generated for each applicant

number and code number. The two could be scanned and linked to create a “code table” type

crosswalk.

Re‐visit the laptop exam booklet preparation process. This is a cumbersome process that relies

heavily on experienced employees to prevent errors. Laptop answers must be printed, sorted, and

put into covers in preparation for grading. This work is performed by staff and by up to 30 temporary

employees. Printing is expensive and time‐consuming: staff estimates that 720,000 pages were

printed during a three week period following the July 2012 general bar examination. Total printing

costs for this exam alone are estimated at $36,000. Laptop examinations now account for 65‐70% of

all exams taken.

Laptop answers could be transmitted to graders in a digital format, significantly reducing preparation

time and processing costs. Laptop booklets would still be printed for those individuals who failed the

examination and that must be sent a copy.

Consider ways to conceal examination read status (first or second) from graders. Currently, graders

are aware that their assignments are either “first read” (never graded) or “second read” (graded not

passing but warranting a second review.) The Director of Admissions Administration indicated that

there is some “drift” in in second read grades resulting from grader awareness, but that this effect

has been reviewed by Admission’s consulting psychometrician and does not significantly impact

scoring. Admissions has an opportunity to eliminate any process‐related “drift” as initiatives such as

on‐line grading are explored.

Create a digital copy of handwritten exam booklets. Original copies of handwritten exam answers

are released to graders and taken off‐site for grading. Even though graders are instructed about

proper handling of these booklets there is a real risk that booklets may be lost, altered or damaged.

The number of handwritten booklets continues to decline; less than 20% of examinees were

“writers” during the July 2012 bar exam. This reduces, but does not eliminate risk. One barrier to

creating a copy of these exams is that booklets are not suitable for sheet‐feeding and would need to

be hand‐processed.

Re‐examine “Grading Lockdown” procedures, and explore possible alternatives. Access to the

AS/400 is restricted for up to two weeks as grades are loaded into Cal Bar Grader application and the

post‐examination motion is prepared. This is done to ensure that the examination result letters


include the same applicant information that was used to generate the motion. The “lockdown”

delays some regular applicant information maintenance work in Los Angeles, but interviewees

identified are some exceptions to restrictions. The Director for Admissions Administration has

considered limiting the information provided in the results letter. It may also be possible to create a

“snapshot” or copy of the AS/400 Master File to support development of the motion without locking

down the application.

Motions

Establish clear organizational responsibility for motions processes. No one organizational unit or

director has responsibility for motions processes. Moral Character8, Operations & Management, and

Admissions Administration each have been involved in processes and it was not at all clear from an

interview who, if anyone, is in charge. Clarify policy regarding who should be contacted in the event

of a major issue involving a candidate.

Re‐evaluate division of labor between Los Angeles and San Francisco. All preparatory work on

weekly motions is performed in Los Angeles. Motions are forwarded to San Francisco in order to

obtain an attorney’s signature and to be submitted to the Supreme Court. Mass motions (exam

results motions) are initiated in San Francisco. According to current practice, any San Francisco‐based

department director who is also an attorney may sign a motion. Determine if the signature could or

should be provided by an attorney in Los Angeles, and find appropriate ways to reduce the hand‐off

of motions between locations if possible.

Revise motions processes and forms to reduce the possibility of error. Determine if additional

reviews or checkpoints are needed to ensure that applicant holds are cleared appropriately before

names are added to a motion. Add descriptive information to each motion that identifies the number

of candidates included, so that the motion can be compared to the attached list of candidates.

Prohibit changes to any motion once it has been signed.

Confirm that all participants and stakeholders in this process understand the impact of their

actions and are following procedures. Document policies and procedures and train all parties as

needed. While some corrective actions were taken in Los Angeles following recent problems with the

motion that included Sergio Garcia, it is not clear that any changes were implemented in San

Francisco nor that stakeholders in General Counsel fully understand the motions process.9

Exam Application and Clearance

Provide on‐line capability for applicants to print admittance tickets.

8 According to the Senior Executive for Admissions, Moral Character will no longer be involved in this process.

9 We did not interview representatives from General Counsel.


Explore ways to provide secure electronic transfer of transcripts and certifications from law schools.

Evaluate the effect of the use of RR numbers (used instead of Social Security Numbers for non‐US

citizens) on systems and processes. Many of Admission’s current systems do not handle RR numbers

well.

Examination Administration

Automate the daily upload of registration and exam application data so that human intervention is

not required. Application Pre‐Processing must execute each daily download from the XAP third party

application and upload data to the AS/400. The responsible analyst estimates that it takes between

20‐30 minutes each day to run this and related processes. The process must be executed according

to specific instructions in order to prevent errors.

Reexamine O&M Exam Administration’s process for packing examination boxes and carts. Exam

Administration counts test center staff materials and supplies such as pens and pencils twice, using

two different people, even though the risk to exam center staff of shorting these supplies is low.

Find more effective ways to reorder supplies as they are used. Explore the feasibility of acquiring a

materials management tool or application. Current processes require staff to visually inspect each

box one or more times so that supplies can be restocked/reordered.

Conduct an analysis to determine if the Apple One agency is still the most cost‐effective way for the

State Bar to staff exam proctors. It appears that the State Bar may not be receiving the benefits of

temporary staffing (pre‐screening of applicants, for example) that it is paying for. Staff we

interviewed suggested that the agency does not always provide timely processing of proctor

applicants that have been recruited by the State Bar. Apple One appears to have a strong incentive to

delay applicant processing, since the State Bar will be forced to request general temporary

employees from Apple One at a 50% premium.


In General

Explore the feasibility of creating a formal document intake process at the point documents are received, usually in the mail room. Documents could be logged in and managed using existing bar code technology or Radio Frequency Identification (RFID). As noted earlier, correspondence requiring a response is logged in by the O&M Deputy Director’s administrative assistant and then sent to the file room for bar coding. Any letters that are addressed to the Eligibility Section are logged in by the administrative assistant and by an employee in Eligibility.

Explore the feasibility of acquiring Microsoft Project or similar project management software to create and manage O&M’s Master Calendar and to support examination preparation functions, if functionality is not provided by the new Admissions System.

Explore the feasibility of implementing a document management/document imaging solution that includes document indexing and key word search capabilities. In the interim, use SharePoint or other State Bar technologies to manage digitized versions of all documents and letters and make them available in shared directories.

Establish performance objectives and measures for each key business process and monitor

performance over time.


IV. About this Review

Linda Lewis, Principal of Framework LLC, conducted site visits and interviews in Los Angeles and San

Francisco. She interviewed the following individuals in the Office of Admissions:

Gayle Murphy, Senior Executive, Admissions

Vanessa Collier, Deputy Director, Operations & Management

Gina Crawford, Director, Admissions Administration

Norma Esperida‐Cummins (and Jane Paragas), Section Chief, O&M Eligibility, and team

Becky Romero, Section Chief, O&M Application Pre‐Processing, and team

Selina Flores, Acting Section Chief and Tammy Campbell, Section Chief, O&M Examination Administration, and team

Patrick Kan, Technology Service Analyst, O&M

Arayeh Rahimitabar, Section Chief, Admissions Administration

Kecia Johnson, Admissions Analyst II, Admissions Administration

Regina Serafino, Grading Section Chief

Shikenna Derbigny, Admissions Coordinator

Saida Salfiti, Sr. Administrative Assistant, Moral Character (responsible for motions)

Linda toured work processing areas collected and reviewed written procedures and samples of

forms. She also reviewed materials from previous analyses, including process flow diagrams and use

cases created by Diagonal Consulting and process flows developed internally.

Linda developed process flow diagrams and written process descriptions. She then evaluated

processes by asking the following questions:

Are steps performed in a logical or natural order?

Does every step add value?

Are there any unnecessary administrative tasks, approvals, paperwork?

Do employees make decisions at the task level?

Do processes have multiple versions to fit specific situations?

Are there redundant or unnecessary checks and controls?

Is there a single point of customer contact?

Are as few people as possible involved in performance of the process?

Are reconciliation activities minimized?

Is work performed where it makes the most sense?

Is there clear ownership of each task?

Are tasks performed consistently by different individuals? Is performance of tasks determined by the individuals performing them?

Is it efficient? Are tasks performed using an acceptable level of resources?


Is it effective? Is it doing what it was intended to do?

Are process results delivered on time?

Are there ways to reduce cycle time without compromising results?

Are there ways to make the process “error proof” (difficult to do incorrectly)

Can the process be standardized or automated?

Are there ways to improve feedback about this process?

State Bar of California Process Improvement Analysis Page 1 of 13 Discussion Draft of Findings & Opportunities 6/20/2013 Framework LLC

I. Moral Character

A. Overview

To obtain a license to practice law in the State of California an applicant must possess good moral

character as mandated by the Business and Professions Code and outlined in the Rules of The State

Bar of California, Title 4, Admissions and Educational Standards. Each applicant has the burden of

establishing his or her current good moral character and must file a moral character application and

supporting materials to initiate the screening and review process.

The Moral Character function is executed by Operations &Management’s (O&M’s) Application Pre‐

Processing Section in Los Angeles and the Moral Character Section in San Francisco. Application Pre‐

Processing is responsible for receiving moral character applications, assigning an initial review level,

ensuring applications are complete, and managing critical file support information including letters of

reference, fingerprints and criminal records, and driving records. Application Pre‐Processing may also

clear Level M and Level 0 applications (positive applications with few or no issues). The O&M file

room in Los Angeles is responsible for managing the imaging, indexing, storage and transfer of all

hard copy files. The Moral Character Section in San Francisco is responsible for evaluation and

determination of Level 1, 2, 3 and 4 applications, obtaining additional support for determinations as

needed, and for organizing and staffing hearings before the Committee of Bar Examiners and its

Subcommittee.

The Moral Character function was reorganized and its work processes modified in the latter part of

2012. Moral Character Analysts based in Los Angeles were reclassified as “Records Coordinators” and

began reporting to the Application Pre‐Processing Section Chief. Complexity level ratings were

assigned to moral character applications earlier in the application review process, and authority to

clear Level 0 applications was delegated to Records Coordinators in Los Angeles.

The remainder of this section identifies review findings and opportunities for improving process

timeliness, efficiency, security and technology. Exhibit A summarizes opportunities that have

been/are being addressed by O&M as a direct result of this review.


B. Application Processing Timeliness

According to published instructions to applicants, the Office of Admissions’ goal is to complete the

processing of moral character applications “as quickly and as efficiently as possible.”1 Applicants are

instructed to expect that a moral character determination will take a minimum of 180 days to

complete. O&M monitors the timeliness of moral character processing against this 180 performance

target.

An analysis of on‐line moral character applications submitted in 20122 revealed the following:

The average elapsed time from the date that each application was complete (placed in filed, or

“F” status) until abandonment or determination (cleared, denied, put in abeyance, sent to the

subcommittee or administratively withheld) was 130 days.3 Days from filed status to final

determination ranged from 1 to 478.

Using O&M’s definitions, 1,361 or 19.9% of 2012 applications were “late” in that they were

determined after the 180 day performance target.4

Moral character applications submitted in 2012 that had reached a final resolution by 6/4/2013

were “in house” an average of 129 days.5 The majority of these (80%) reached final resolution

within 180 days. A small percentage of applications (4%) were “in house” over 270 days.

1 “Steps Following Submission of a Moral Character Application”, document MC Following Submission 0312‐R, available

through the Office of Admissions’ web portal.

2 We examined 7,687 on‐line applications submitted at any time during 2012. Data were provided by O&M. While some

applications are paper‐only, the majority are initiated on‐line.

3 On‐line applications received complete (“filed”) in 2012 and for which a status of “A” (Abandoned), “B” (Abeyance), “C”

(Cleared), “D” (Denied), “H”(Administrative Withdraw), or “N” (Sub‐Committee) had been recorded as of 6/4/2013.

4 A “late” application was any application that had been “in house” for at least 181‐days and had an Application Status of

“F” (filed) or “I” (information hold). Includes the mean days from date the application was placed in “F” or “I” status to the

date the application was placed in one of the following: “A” (Abandoned), “B” (Abeyance), “C” (Cleared), “H”(Administrative

Withdraw), “N” (Sub‐Committee) or “W”(Withdrawn by Applicant).


As of 6/4/2013, 259 applications in “I” status (information hold) had been “in‐house” over 120

days. Of these, 108 had been “in‐house” over 180 days.

A small proportion of applications take a long time to reach final resolution. Level 3 and 4

applications averaged 241 days from “Filed” status to final resolution but represented only 5% of

all applications resolved. Most applications (52%) were rated Level M or Level 0; these averaged

90 days to final resolution in 2012. Level 1 and 2 applications (43% of applications) averaged 164

days to final resolution.

Appendix A identifies critical path processes for moral character application pre‐processing and

determination. Each process includes a minimum, maximum and average duration, derived from the

2012 application data and staff estimates. The critical path highlights processes that must be

completed before applications can be resolved. Analysis of the critical path reveals that the following

have the greatest potential to contribute to overall process delay:

Delays in application pre‐processing review. Process 14.4 Review Application for Completeness,

executed by Application Pre‐Processing in Los Angeles, is critical to overall resolution time. This is

the first opportunity for an application to receive a “Filed” status, indicating that it may be

evaluated for clearance. Live Scan review and manual fingerprint processing cannot begin until

this process is complete. In 2012, the average duration of this process was 10 days.6 However,

backlogs can form here. The process took more than 20 days for 377 applications and in one

instance took 129 days.

5 On‐line applications received complete (“filed”) in 2012 for which a status of “A” (Abandoned), “C” (Cleared), “D”

(Denied), “H” (Administrative Withdraw), or “W” (Withdrawn by Applicant) had been recorded as of 6/4/2013, indicating

resolution of the applicant’s moral character determination.

6 Includes the mean days from date the application was placed in “P” or paper received status to the date the application

was first assigned a level rating of P,M or 0.


Multiple requests for references. Responses to Confidential Questionnaires (CQs), or requests

for references, are integral to the moral character determination process. CQs are not mailed to

prospective references until the signed copy of the printed application is received and it is clear

that the applicant intends to follow through with the application. Application Pre‐Processing

estimates that it takes 34 days, on average, from the time that CQs are sent to references until

the time they are received and recorded but that waits of 60 days are not uncommon.

If CQs are undeliverable, are not returned or are inadequate, O&M may send out additional

requests.7 The need for additional references is identified during routine monitoring (Process

14.9) which can only commence once the application has been reviewed for completeness

(Process 14.4.) Any backlogs in Process 14.4 will compromise additional reference requests.

The critical path analysis suggests that applications requiring a second request for references

may not be clearable until Day 97, on average (which roughly translates to Day 67 as measured

by the “180 day clock”.)8 In a worst case scenario (all prior processes take the maximum amount

of time) applications requiring a second request for references may not be clearable until Day

192 (or Day 162 as measured by the “180 day clock”.)

Moral Character Analysts may also request additional references at any time.

Fingerprint processing delays. Rejected Live Scan fingerprints can add an estimated 31‐62 days

to the time to application resolution. The critical path analysis suggests that applications with

rejected prints may not be clearable until Day 76, on average (which roughly translates to Day 36

as measured by the “180 day clock”. In a worst case scenario applications requiring extra Live

Scan processing may not be clearable until Day 314 (or Day 284 as measured by the “180 day

clock”.)

Subcommittee‐driven evaluation and follow‐up. An estimated 250 applications per year are

referred to the Subcommittee for Moral Character for review. Preparation of applications for

Subcommittee evaluation is time‐consuming, and review must be scheduled for one or more of

the Subcommittee’s seven annual meetings. After initial consideration the Subcommittee may

request additional investigation (adding up to 30 days), place the applicant in abeyance for 6‐18

months, or postpone action for up to 90 days. The Subcommittee may also request an informal

conference. Any final determination will be deferred to a later meeting.

7 According to interviews, an estimated one of every eight moral character applications (about 1,000 per year) includes

reference addresses resulting in undeliverable mail.

8 The critical path analysis assumes that Day 1 is the day that on‐line applications are uploaded to the AS/400. The “180 day

clock” does not begin until an application is placed in complete or “filed” status. This occurs somewhere near Day 30 for

most applications.


The 2012 data did not include enough information to fully evaluate the time that Subcommittee

actions and related activities added to an application’s total processing time. However, 31

applications filed in 2012 and referred to the Subcommittee as of 6/4/2013 had been in process

an average of 305 days since the filing date, and 6 applications placed in abeyance as of 6/4/2013

had been in process an average of 385 days. Each of these applications will require additional

review and evaluation in 2013 before they can be determined.

Other factors contributing to the length of moral character determinations include:

Re‐assignment of applications older than 120 days. Level M or 0 applications not cleared by

Application Pre‐Processing within 120 days are automatically re‐assigned to a Moral Character

Analyst in San Francisco. Applications are then subject to additional triage, review, and

evaluation that extends overall processing time. This is true even if the application is not

particularly complex.9 In 2012, 791 Level M and 0 applications were not cleared within 120 days

and would likely have been transferred to Moral Character.

The impact of processing differences is apparent when comparing timeliness of Level 0

applications (reviewed by Moral Character Analysts in 2012) and Level M applications (reviewed

by Application Pre‐Processing in 2012). Level 0 applications required 142 days on average to

reach determination, while Level M applications required 65 days, on average. By April of 2013

Application Pre‐Processing estimated that it was clearing Level M and 0 applications in five

weeks, on average.10 The Director of O&M indicated during interviews that he would like to see

clearances completed within 30 days. (O&M is reconsidering this 120 day deadline; see Exhibit

A.)

Data collection and investigation for complex Level 3 and Level 4 applications. Investigations

(both internal and external) and extra evaluation add to the duration of processing time for

complex Level 3 and Level 4 applications. These impacted a small number of applications. In 2012

only 5% of applications were Level 3 or 4 at final determination.

Fingerprint processing delays. All Live Scan prints are forwarded to the Department of Justice,

but applicants using Live Scan must indicate that fingerprints also be sent to the FBI. If an

applicant fails to make this designation at the time prints are taken, his or her Moral Character

Application may be considered to be incomplete.

Manual fingerprint processing. Prior to April of 2013, fingerprint cards were not sent for

processing until an application was deemed to be complete (placed in “Filed” status). This

delayed the determination of any application requiring Department of Justice (DOJ) or FBI

9 See Process 14.11 Evaluate Moral Character.

10 Responsibility for reviewing/clearing Level 0 applications was assigned to Application Pre‐Processing near the end of

2012.


clearance using physical fingerprint cards by an estimated 10 to 20 days. (O&M has changed this

process; see Exhibit A.)

Manual DMV requests. If automated requests for DMV records fail to produce a result O&M

must manually request information from the DMV. This request begins once results from the

automated requests are received and require an additional 15‐43 days.

Delayed file opening. According to statistics prepared by the Application Pre‐Processing Section

Chief, it took Moral Character Analysts an average of 113 days to open (begin work on) new

applications during January through July 2012. Interviewees suggested that Moral Character

Analysts may not be requesting applications to work until they are reasonably assured that the

applications include CQs, results from fingerprint processing, and a DMV record. Work backlogs

may also be an issue (see below.) According to the critical path analysis, Moral Character

Analysts should expect applications to be complete and ready to evaluate on Day 67, on average

(“180 day clock”). In a worst case scenario, applications would not be available until Day 228.

Work backlogs/workload. Moral character workload is seasonal. In 2012 the number of

applications received was greatest in January through April and peaked in March. Interviewees

suggested that work intensifies in after results from examinations are received as work is

internally “triaged” to make sure examinees are cleared if possible. Records Coordinators have

assigned duties in addition to application processing, including DMV duties, fingerprint

processing, and undeliverable CQs, for example. Moral Character Analysts are assigned on a

rotating basis to answer telephone calls from applicants wishing to check application status,

references, and other parties offering unsolicited information about applicants. These activities

are necessary but can be disruptive to regular work.


Opportunities:

Accept an electronic signature in place of or in addition to a signed affidavit. Initiate requests for

references as soon as the on‐line application is submitted and electronically signed. This could

reduce average total processing time by 19 days, or more in instances where paper applications

are not returned timely.

Eliminate automated re‐assignment to Moral Character of Level M or 0 applications not cleared

within 120 days. (O&M is evaluating this change.)

Evaluate whether Moral Character Analyst specialization by application level could improve

processing duration for less complex Level 1 and 2 applications.

Conduct further analysis on reasons for delays in the opening of files by Moral Character

Analysts. Collect recent data and determine if better information about the readiness status of

each file is needed.


C. Process Efficiency

Moral character processing efficiency is compromised by the following:

Undeliverable Confidential Questionnaires (CQs). Undeliverable CQs add to workload and

increase processing duration and cost. Application Pre‐Processing estimates that one of every

eight moral character applications (about 1,000 per year) includes reference addresses that

result in undeliverable mail. Some incorrect addresses are obvious during visual inspection; many

are not. Prior to April 2013 a designated Records Coordinator scanned the bar code of each

returned piece of mail three times; once to record receipt, once to direct the mail to an assigned

Records Coordinator or Moral Character Analyst, and a final time to create a transmittal cover

sheet for the Director of Moral Character in San Francisco. (O&M has since eliminated the final

scan.) The Records Coordinator estimated that she spent two hours to scan/wand, sort and batch

undeliverable letters three days per week, for a total of six hours per week. During this time she

was unavailable to work her assigned files. The State Bar incurs cost to mail letters that are

undeliverable, and replacement references must be identified and contacted, extending

application processing time.

Opportunities:

Minimize processing of undeliverable CQs. Record, batch and preserve undeliverable letters in

case of rare legal challenge, but do not attempt to distribute undeliverable mail to a Records

Coordinator or a specific application file. (O&M has implemented a process change; see Exhibit

A.)

Explore tools or technologies that could help to identify incomplete or incorrect addresses before

letters are mailed. Evaluate cost‐effectiveness of technologies.

Redundant payment reconciliation processes. At the time of this review, O&M’s “lockbox

deposit” bank did not appear to be using a data file that O&M created and supplied to assign

payments to specific accounts. This created a situation where two employees recorded the same

information. An Admissions Analyst researched and assigned each payment to an account and

recorded this information in the Microsoft Access‐based Deposit Log. These data were uploaded

to the bank as part of the lockbox deposit service, but the bank did not include them in reports

back to the Bar. The Accounting Technician researched and re‐entered the account assignment

as part of the check reconciliation process post‐deposit.

Opportunity:

Contact the bank to determine why deposit details submitted by O&M are not incorporated in

reports. (O&M indicated that it planned to investigate.)

Work handoffs related to derogatory references. Handoffs in Process 14.5 (Receive references)

increase processing time. Records Coordinators are required to forward all derogatory references


received on “M” level files to the Administrative Assistant (AA) II for review and approval. If the

AA II is unable to approve the reference, she forwards the application and reference to the Sr.

Administrative Assistant for review. The Sr. AA does not record the action taken on the

reference, but instead forwards the application and reference back to the AA II for data entry.

These handoffs can add several days to an application’s processing time, depending on the

workloads of the AA II and Sr. AA.

Opportunities:

Revise policy and processes for processing derogatory references. Grant authority to Records

Coordinators to approve derogatory employment references in very limited, defined

circumstances. Authorize the person approving a derogatory reference (Records Coordinator, AA

II or Sr. AA) to update the applicant’s record in the AS/400 and change the status of the reference

and/or application as necessary. (See process 14.5.)

Work handoffs related to application clearance. There are two unnecessary handoffs in Process

14.10 (Clear Moral Character Application Level 0 and M). The first occurs after the Senior

Administrative Assistant (Senior AA) reviews any application that a Records Coordinator cannot

clear. The Sr. AA does not record the action taken as a result of his review, but instead forwards

the application and instructions back to the AA II for data entry. A second handoff occurs when

the AA II returns the file to the assigned Records Coordinator so that he/she can forward it to the

file room.

Opportunities:

Authorize the Senior AA to make any necessary changes to the Application record and to forward

the file directly to the assigned Analyst. Use e‐mail or other means as necessary to communicate

that file changes have been made.

Revise policy and processes for clearance of Level M and O applications. Change the process to

require Sr. AA to update the applicant’s record in the AS/400 and clear the application as

necessary. Eliminate the AA II’s involvement in data entry for Level M files. Forward any

applications cleared by the Sr. AA directly to the file room. Notify the assigned Records

Coordinator via e‐mail that the file has been cleared. (See process 14.10.)

Extra review of incomplete moral character applications. Prior to April 2013, applications

that a Record’s Coordinator determined to be incomplete were subject to a second review by

the Administrative Assistant II before the file status could be changed. This extra review

added to the AA II’s workload and potentially delayed actions needed to make the file

complete. Since Records Coordinators used a structured checklist and had access to written

policies & procedures to guide decision‐making, they should be held accountable for their

own decisions. (O&M has changed this practice.)


Inability to clear without physical file. At the time of this review, the automated system

prevented Records Coordinators from clearing a moral character application until its physical file

had been created and recorded. This resulted in re‐work of applications that had been found to

be ready to clear during the initial review of the application. (O&M has implemented a software

change to address this problem.)

Inability to clear without DMV. The Application Pre‐Processing Section Chief has the authority to

clear otherwise clean Level “M” (minimal processing) applications that are awaiting a DMV

record only. Records Coordinators in Los Angeles do not have this authority.

Opportunity:

Develop a protocol that would allow Records Coordinators to clear these applications.

Manual fingerprint evaluation. Live Scan fingerprints are not processed by the DOJ and/or FBI

until Records Coordinators review an application to determine if fingerprint processing is

required. This decision occurs in Process 14.4 Review Application for Completeness

(approximately process day 15.) This decision is performed using specific criteria identified on a

paper checklist, using information that is captured in the applicant’s AS/400 record. Completion

of this checklist and update of the AS/400 adds a small amount of time to each application’s

processing. More importantly, the manual process delays the initiation of Live Scan fingerprint

processing until day 15 or later.

Opportunity:

Automate the decisions to forward Live Scan fingerprints to the FBI for processing and to process

Live Scan fingerprints. Consider automating the decision to process fingerprints, based on

applicant responses and/or other file entries.

Automate both the decision send Live Scan fingerprints to the FBI and to process Live Scan

fingerprints, and begin to process prints as soon as on‐line applications are uploaded. (This may

require accepting an electronic signature in place of or in addition to a signed affidavit.) This

could potentially reduce average total processing time by xx or more days and impacts

approximately xx applications.

Live Scan provider errors. According to interviews with O&M personnel, the UPS Store

(California statewide), an authorized Live Scan provider, has been a frequent source of

processing errors. This is a known problem, but it is unclear what (if any) actions the State Bar

can take to reduce applicant use of this provider.

Redundant fingerprint work. According to interviews, individual Records Coordinators and the

assigned Fingerprints Coordinator are regularly checking to see if it has been more than fifty days

since a request to process fingerprints was made.


Opportunity:

Instruct Records Coordinators to contact the assigned fingerprint Records Coordinator regarding

fingerprint issues.

Purged fingerprint results. Unmatched fingerprint results (results for which an application has

not yet been received or reviewed) are purged after 120 days. If purged results are needed at a

later date, the designated Records Coordinator must manually reconstruct records using hard

copies. (How significant is this?)

Application file transfers. Hard copy application files are requested by Moral Character Analysts

and are transferred from Los Angeles to San Francisco. Moral Character Analysts may be

unwilling or unable to use images of application documents, and some supporting documents are

not imaged. It is estimated that file transfers add at least two days to the determination process.

The Los Angeles file room completes a three‐part paper form to manually record the transfer of

each file, even though each file’s bar code is electronically scanned to record transfer date and

location. Part of this physical form is retained and filed; the remainder is immediately recycled.

Opportunity:

Eliminate use of the three‐part file transfer form. Rely instead on electronic records of file

location.

Confusing application mailing instructions. Instructions included with the on‐line application

indicate that the paper copy must be mailed within 60 days of on‐line filing. Other on‐line

sources suggest that the application should be submitted within 10 days or 30 days. This may be

confusing to applicants.

Opportunity:

Clarify instructions.


D. Security/Process Controls

Three findings related to security and/or process controls merit further review:

Unsecured checks. Prior to April 2013, checks received for Moral Character and other

applications were left unsecured on top of a desk or cabinet overnight. Good practice dictates

that checks be secured. (O&M has since secured these checks.)

DMV credentials. The Application Pre‐Processing Section’s AA II is making manual DMV requests

using DMV credentials and privileges granted to the Section Chief during his previous position as

a Moral Character Analyst.

Opportunity:

Obtain appropriate DMV data credentials for the AA II.

Document accountability and tracking. While Application Pre‐Processing bar codes and images

moral character documents it receives in Los Angeles, documents that are sent directly to the

San Francisco Moral Character Section are not bar coded and may not be imaged (verify).

Additionally, San Francisco is not routinely using the Bar Code System to record receipt and

transfers of application files. The Moral Character Section indicated that there are no dedicated

mail room or support resources for this purpose. O&M has provided file management training to

San Francisco staff in the past.

Opportunity:

Identify staff resources in San Francisco that will be responsible for tracking receipt and

movement of bar coded Moral Character files and documents. Develop instructions for file

tracking.

Investigate whether documents received by the Moral Character Section should be bar coded

and/or imaged.

E. Other Technology Opportunities Identified

Update O&M’s Bar Code and scanning (imaging) software/hardware. These are no longer

supported by vendors. The State Bar is unable to make any changes to existing functionality, data

categories or fields. (Verify)

Re‐locate the high‐volume scanner near staff that uses it most frequently. (O&M has relocated

this equipment.)

Enforce registration with the State Bar before applicants may submit an on‐line moral character

application. Use methodologies in place for other on‐line applications.

Use an electronic signature for on‐line moral character applications.


Develop a means to automatically upload fingerprint data for applicants using an “RR” number

instead of a Social Security Number. Data for these individuals will not automatically upload, and

must be manually entered in the Fingerprint Hold System and re‐uploaded to the AS/400. The

Fingerprint Coordinator estimates that there are 5‐10 of these per day.

Provide Moral Character applicants with more detailed on‐line application status information.

According to interviewees, the current status of “in review” is not particularly informative and

generates telephone calls to the Moral Character Section.

F. Summary of Opportunities Being Implemented or Explored

During interviews with O&M management and the Application Pre‐Processing Section in March and

April of 2013 process improvement opportunities were identified that have been or are being

implemented by O&M. These are summarized in Exhibit A.


Exhibit A: Summary of Application Pre‐Processing Opportunities & Implemented or Planned

Changes

Opportunity Action Taken (or Planned)

Undeliverable Confidential

Questionnaires/reference requests

A designated Records Coordinator spent an

estimated six hours per week scanning

undeliverable mail. Each undeliverable piece

of mail was scanned three times: once to

receive it, once to direct it to the assigned

Records Coordinator or Analyst, and once to

create a transmittal cover sheet.

Changed process. Each piece of undeliverable mail is scanned once to record that it was received, and bundled and filed by date.

Plan to develop a report to take the place of the cover sheet.

Researched tools or technologies that could be used to identify bad addresses before letters are mailed. Preliminary research suggested that these might not be cost‐effective.

Delayed processing of fingerprint cards

Per internal policy, fingerprint cards were not

sent for processing until the Application was

deemed to be complete (placed in “F” or Filed

status). This delayed the determination of any

application requiring DOJ or FBI clearance

using physical fingerprint cards.

Fingerprint cards are now processed as soon as they are removed from the application packet as the application is reviewed for completeness. (See Process 14.4.)

Incomplete moral character applications

Any application determined to be incomplete

by a Records Coordinator was subject to a

second review by the Administrative Assistant

II before the file status could be changed. This

extra review added to the AA II’s workload

and potentially delayed actions needed to

make the file complete.

Changed process to eliminate AA II review of incomplete applications.

Records Coordinators will be accountable for their decisions. Any problems or issues will be addressed with training as needed.

Excessive handling of Confidential

Questionnaires

An assigned Records Coordinator optically

scanned the bar code of each completed

Reference Questionnaire (using a hand‐held

wand) in order to create a cover memo for

the Moral Character Section Chief. (This was

done after optically scanning each document

Will design a report to take the place of the cover sheet. This bar code scanning will be eliminated.



up to two times to update response category

and/or to determine status and level.)

Derogatory References

Records Coordinators forward all derogatory

references on “M” level files to the AA II for

review and approval. A handoff could be

eliminated if Records Coordinators were given

the same authority as the AA II to approve

derogatory employment references in very

limited circumstances.

Will discuss with the Director of Moral Character

Scanner location

The high‐volume scanner was not located

near staff that used it most frequently.

Relocated the equipment (verify).

120 day conversion

Level “M” or “0” applications not cleared by

Application Pre‐Processing within 120 days of

receipt (“P” or paper received status)

automatically converted to Level “P”

applications and are re‐assigned to a Moral

Character Analyst.

Elimination of this deadline is under consideration.

Payment reconciliation process

The State Bar’s “lockbox deposit” bank does

not appear to be using the data file the Bar

supplies to assign payments to specific

accounts.

Under investigation.

Check security

Checks removed from applications may have

been left on top of a desk or file cabinet

overnight.

Any checks not deposited by the end of the business day are now secured in a locked file cabinet.

File transfer

The Bar Code System/optical scanner records

Under investigation.



the transfer of Moral Character files between

Los Angeles and San Francisco. However, the

Los Angeles file room also completes a three‐

part paper form to manually record the

transfer of a file. Part of the physical form is

retained and filed; the remainder is

immediately recycled.

Clearance without physical file

Records Coordinators were not able to clear a

moral character application until its physical

file had been created.

Software has been changed to allow clearance before file creation.