Supplementary Table - User Fees Reporting

User Fees and Regulatory Charges (User Fees Act)

User Fee: Aviation Safety Regulatory Fees

Fee Type: Regulatory Service (R)

Fee-setting Authority:

Date Last Modified: July 15, 2000
Subsequent amendments to regulations and/or fee reductions, if any, did not trigger the User Fees Act.

Performance Standards:

Performance Results:

Civil Aviation now has capacity to provide service performance results for four regions (Pacific, Prairie and Northern, Ontario & Atlantic). By the end of FY 2013–14, Civil Aviation will have completed national implementation by having capacity to report on performance levels for the two remaining groups (Quebec Region & National Operations Branch).

2012–13 Performance results for Services with fees are available for Pacific, Prairie and Northern, Ontario and Atlantic Regions.

2012-13 ($ thousands)
Fiscal Year Forecast revenue Actual revenue Full Cost Estimated full cost

2012-13

8,202

7,604

71,686

 

Planning Years

2013-14

8,202

 

 

60,060

2014-15

8,202

 

 

60,060

2015-16

8,202

 

 

60,060

Other Information:

A communications and engagement strategy has been developed to support the department in increasing awareness and understanding amongst stakeholders and Transport Canada Civil Aviation employees.

The Communications Centre is comprised of Civil Aviation representatives who are available to address telephone and email enquiries from the general public, such as providing information on the Civil Aviation Program, services and regulations.

The Civil Aviation Issues Reporting System [CAIRS] is a web application that provides stakeholders, including clients and the public, with a means to raise issues (concerns, complaints, compliments, and suggestions for improvement) to the Civil Aviation Program of Transport Canada, including service standards related to the Canadian Aviation Regulations CAR 104 Charges.

Consistent with public consultations conducted in the past, full or partial costs of services such as monitoring compliance, enforcing safety operational standards, establishing legislation, regulations and standards, etc., were considered to benefit the general taxpayer. Only the costs associated with issuing Transport Canada safety documents (certificate, license, permit, etc.) were considered a private benefit attributable to the document recipient.

User Fee: Marine Safety Regulatory Fees (inspections, surveys, services, etc.)

Fee Type: Regulatory Service (R)

Fee-setting Authority:

Date Last Modified: May 1, 2002
Subsequent amendments to regulations and/or fee reductions did not trigger the User Fees Act.

Performance Standards: Marine Safety is undergoing a consultation and review process to revise Service Standards for its Fees. Details are provided at the following link: Service Standards for Marine Safety’s Fees

Performance Results:

  1. Large Ship Registry Tariff: 2012–13 Performance results are available for the Vessels Registry Fees Tariff. Performance for each of the 10 large vessel standards is over 90 percent.
  2. Other performance results are under development:
    The Marine Safety Dispatch and Tracking System (MSDTS) has been developed. The release of the system was delayed and was released as planned in April 2013.
2012-13 ($ thousands)
Fiscal Year Forecast revenue Actual revenue Full Cost Estimated full cost

2012-13

6,662

10,200

75,526

 

Planning Years

2013-14

6,566

 

 

69,831

2014-15

6,464

 

 

69,682

2015-16

6,464

 

 

69,682

Other Information:

A complaint mechanism policy, "Handling of complaints related to Marine Safety User Fees and applicable service standards" is available on Transport Canada’s website.

Consistent with public consultations conducted in the past, full or partial costs of services such as monitoring compliance, enforcing safety operational standards, establishing legislation, regulations and standards, pollution prevention, etc. were considered to benefit the general taxpayer.

User Fee: Marine Safety — Ship Radio Inspection Program

Fee Type: Regulatory Service (R)

Fee-setting Authority:

Date Last Modified: 1978
Subsequent amendments to regulations and/or fee reductions did not trigger the User Fees Act.

Performance Standards: Consistent with the Fisheries and Oceans Canada publication, Part IV of Radio Aids to Marine Navigation, a ship radio inspection service will be provided within three working days following a request from a client.

Performance Results: In 2012–13, Radio inspection services were provided more than 90 percent of the time within three working days following such a request. As some clients’ ships operate on a fixed schedule, such a request may be made a week or more in advance of the requested inspection date.

2012-13 ($ thousands)
Fiscal Year Forecast revenue Actual revenue Full Cost Estimated full cost

2012-13

48

75

993

 

Planning Years

2013-14

48

 

 

993

2014-15

48

 

 

993

2015-16

48

 

 

993

Other Information:

A complaint mechanism policy, "Handling of complaints related to Marine Safety User Fees and applicable service standards" is available on Transport Canada’s website.

Funding of the Ship Radio Inspection Program is covered by a memorandum of understanding between Transport Canada, and Fisheries and Oceans Canada. Revenues from user fees represent the full cost recovery of overtime and travel costs. Full Costs include also the costs for the program manager, a share of internal services costs and amortization costs of the ship radio inspection equipment.

User Fee: Airport Fees — Air Services Charges Regulations

(General Terminal Fees, Landing Fees, Aircraft Parking Charges, Emergency Response Services Charges)

Fee Type: Other Products and Services (O)

Fee-setting Authority:

Date Last Modified: January 1, 2003
Subsequent amendments to regulations and/or fee reductions, if any, did not trigger the User Fees Act.

Performance Standards: Airports National Service Standards are available on the Transport Canada website.

Performance Results: Performance met the standards more than 90 percent of the time.

2012-13 ($ thousands)
Fiscal Year Forecast revenue Actual revenue Full Cost Estimated full cost

2012-13

5,850

7,984

16,313

 

Planning Years

2013-14

5,908

 

 

16,313

2014-15

5,968

 

 

16,313

2015-16

6,029

 

 

16,313

Other Information:

Data includes TC-owned and operated airports only.  Full Costs reported do not reflect annualized capital costs in recognition of the fact that these remaining smaller airports may not have the necessary critical mass of traffic to fully pay for these large infrastructure costs.

Complaint mechanisms enabling feedback from members of the public and stakeholders have been established. Mechanisms are incorporated into each service standard, and are included on the Transport Canada website for service standards related to airports operated by Transport Canada or on its behalf.

User Fee: Airport Fees — Annual Registration of Mobile Equipment

Fee Type: Other Products and Services (O)

Fee-setting Authority:

Date Last Modified: February 24, 2004
Subsequent amendments to regulations and/or fee reductions, if any, did not trigger the User Fees Act.

Performance Standards: Airports National Service Standards are available on the Transport Canada website.

Performance Results: Performance met the standards more than 90 percent of the time.

2012-13 ($ thousands)
Fiscal Year Forecast revenue Actual revenue Full Cost Estimated full cost

2012-13

2

3

6

 

Planning Years

2013-14

2

 

 

6

2014-15

2

 

 

6

2015-16

2

 

 

6

Other Information:

Complaint mechanisms enabling feedback from members of the public and stakeholders have been established. Mechanisms are incorporated into each service standard, and are included on the Transport Canada website for service standards related to airports operated by Transport Canada or on its behalf.

As of 2011-12, revised costing and reporting approaches were developed based on the costing of services provided at the Wabush airport. There is a low demand and small revenues for this service since most airports have been divested. Program to be reviewed.

User Fee: Airport Vehicle Parking Charges

Fee Type: Other Products and Services (O)

Fee-setting Authority:

Date Last Modified: June 6, 2012
Subsequent amendments to regulations and/or fee reductions, if any, did not trigger the User Fees Act.

Performance Standards: Airports National Service Standards are available on the Transport Canada website.

Performance Results: Performance met the standards more than 90 percent of the time.

2012-13 ($ thousands)
Fiscal Year Forecast revenue Actual revenue Full Cost Estimated full cost

2012-13

365

368

1,674

 

Planning Years

2013-14

375

 

 

1,674

2014-15

386

 

 

1,674

2015-16

396

 

 

1,674

Other Information:

Data includes TC owned and operated airports only.  Full Costs reported do not reflect annualized capital costs in recognition of the fact that smaller airports may not have the necessary critical mass of traffic to fully pay for up-front infrastructure costs.

Complaint mechanisms enabling feedback from members of the public and stakeholders have been established. Mechanisms are incorporated into each service standard and are included on the Transport Canada website for service standards related to airports operated by Transport Canada or on its behalf.

User Fee: Public Port Fees (Wharfage & Transfers, Berthage, Storage, Harbour Dues, Utilities and Other Services)

Fee Type: Other Products and Services (O)

Fee-setting Authority:

Date Last Modified: January 1, 2004

Performance Standards: Public Ports and Public Port Facilities National Service Standards are posted on Transport Canada’s website

Performance Results: Performance met the standards more than 90 percent of the time.

2012-13 ($ thousands)
Fiscal Year Forecast revenue Actual revenue Full Cost Estimated full cost

2012-13

8,183

7,736

27,892

 

Planning Years

2013-14

8,213

 

 

19,353

2014-15

8,243

 

 

19,383

2015-16

8,242

 

 

19,383

Other Information:

A complaint mechanism has been implemented through feedback on Transport Canada’s website for service standards related to public ports and public port facilities. Other dispute mechanisms are in place and built into each service standard.

User Fee: Fees charged for the processing of access requests filed under the Access to Information Act

Fee Type: Other Products and Services (O)

Fee-setting Authority: Access to Information Act

Date Last Modified: 1992
Subsequent amendments to the Act and regulations did not trigger the User Fees Act.

Performance Standards: Service Standards are included in the Access to information Act, section 7. Response provided within 30 days following receipt of request; the response time may be extended pursuant to section 9 of the Act. Notice of extension is to be sent within 30 days after receipt of request.

Performance Results: Statutory deadlines have been met for 88 percent of requests. One hundred percent of extension notices were sent within 30 days following the receipt of the request

2012-13 ($ thousands)
Fiscal Year Forecast revenue Actual revenue Full Cost Estimated full cost

2012-13

9

9

3,756

 

Planning Years

2013-14

9

 

 

3,019

2014-15

9

 

 

3,019

2015-16

9

 

 

2,861

Other Information:

The Estimated Full Cost for Fiscal Year 2013–14 and 2014–15 includes an estimated potential cost of $158K for managing increased Access to Information (ATI) demands associated with the Lac Mégantic tragedy.

Cost information is based on the Statistical Reports on the Access to Information Act. User Fee financial information includes adjustments to a full cost base in accordance with the Treasury Board Secretariat’s Guide to Costing.

User Fees Totals 1 5

Subtotal Regulatory (R)

2012-13 ($ thousands)
Fiscal Year Forecast revenue
3 4
Actual revenue
3
Full Cost
2
Estimated full cost
2

2012-13

14,912

17,879

148,205

 

Planning Years

2013-14

14,816

 

 

130,884

2014-15

14,714

 

 

130,735

2015-16

14,714

 

 

130,735

Subtotal Other Products and Services (O)

2012-13 ($ thousands)
Fiscal Year Forecast revenue
3 4
Actual revenue
3
Full Cost
2
Estimated full cost
2

2012-13

14,409

16,100

48,477

 

Planning Years

2013-14

14,507

 

 

40,365

2014-15

14,608

 

 

40,395

2015-16

14,678

 

 

40,237

Total

2012-13 ($ thousands)
Fiscal Year Forecast revenue
3 4
Actual revenue
3
Full Cost
2
Estimated full cost
2

2012-13

29,321

33,979

196,682

 

Planning Years

2013-14

29,323

 

 

171,249

2014-15

29,322

 

 

171,130

2015-16

29,392

 

 

170,972

Due to rounding, columns may not add to totals shown.

External Fees
 

(Policy on Service Standards for External Fees)
External fee Service standard 1 Performance results 2 Stakeholder consultation 2012-13 or prior

Aviation Safety — Regulatory Fees

Civil Aviation’s Service Standards

Service Charter

Civil Aviation now has capacity to provide service performance results for four regions (Pacific, Prairie and Northern, Ontario & Atlantic). By the end of FY 2013–14, Civil Aviation will have completed national implementation by having capacity to report on performance levels for the two remaining groups (Quebec Region & National Operations Branch).

2012–13 Performance results for Services with fees are available for Pacific, Prairie and Northern, Ontario and Atlantic Regions.

Documentation on Services Standards was published in April 2010. A communication and engagement strategy has been activated to raise awareness and understanding of stakeholders through Canadian Aviation Regulation Advisory Council meetings and Transport Canada Civil Aviation employees through training sessions and other communication channels. Ongoing feedback (and consultations as required) is done through the Council meetings and Transport Canada’s website for service standards related to the Canadian Aviation Regulations CAR 104 charges using the Civil Aviation Issues Reporting System feedback application. Review of the 2011–12 feedback through this Reporting System and the Council is satisfactory and the new service charter is supported. The new service charter was published in 2010 and performance tracking has not been implemented in all regions yet.

A periodic review of existing standards in full consultation with stakeholders is expected every 5 years with the next review planned for 2013–14.

Marine Safety — Regulatory Fees for inspections, surveys, services, etc.

Marine Safety’s Service Standards

Large Ship Registry Tariff: 2012–13 performance results are available for the Vessels Registry Fees Tariff. Performance for each of the 10 large vessel standards is over 90 percent.
Other performance results under development:  The Marine Safety Dispatch and Tracking System (MSDTS) has been developed. The release of the system was delayed and is scheduled for release April 2013.

In the Spring 2012 Canadian Marine Advisory Council meetings, Marine Safety continued to consult stakeholders on the administration of existing Board of Steamship Inspection Scale of Fees and Service Standard.

Marine Safety — Ship Radio Inspection Program

Consistent with Fisheries and Oceans Canada publication, Part IV of Radio Aids to Marine Navigation, a ship radio inspection service will be provided within three working daysfollowing a request from a client.
Part 4: General Procedures

For 2012–13, radio inspection services are provided more than 90 percent of the time within three working days following such a request. As some clients’ ships operate on a fixed schedule, such a request may be made a week or more in advance of the requested inspection date.

 

Airports — Air Services Charges Regulations (ASCR) fees: General Terminal Fees, Landing Fees, Aircraft Parking Charges, Emergency Response Services Charges

Airports National Service Standards

Airports Performance Measurement for 2012/13
Performance met standards more than 90 percent of the time.

Consistent with approach used in 2006, when first implementing service standards, ongoing stakeholder consultations and feedback are managed through existing channels (e.g. tenant meetings, comment cards, etc.) at the various sites and on Transport Canada’s web site.
 

Reviews of 2012–13 feedback have been satisfactory and no outstanding issues have been reported. In 2013–14, ongoing feedback will continue to be managed through the existing channels.
 

Service standards were reviewed in 2010 as part of the Departmental Service Implementation Team initiative as a result of the Treasury Board Service Policy and section 20 of the Management Accountability Framework, "Citizen-Focused Service." No changes were required.
 

A periodic review of existing standards in full consultation with stakeholders is expected every five years with the next review planned for 2014–15.
 

Complaint mechanisms enabling feedback from members of the public and stakeholders have been established. Mechanisms are incorporated into each service standard, and are included on the Transport Canada website for service standards related to airports operated by Transport Canada or on its behalf.

Airports — Annual Registration of Mobile Equipment used at Airports

Airports National Service Standards

Airports Performance Measurement for 2012/13
Performance met standards more than 90 percent of the time.

Consistent with approach used in 2006, when first implementing service standards, ongoing stakeholder consultations and feedback are managed through existing channels (e.g. tenant meetings, comment cards, etc.) at the various sites and on Transport Canada’s web site. Stakeholder relationships are important and valued.
 

Reviews of 2012–13 feedback have been satisfactory and no outstanding issues reported. In 2013–14, feedback will continue to be managed through the existing channels
 

Service standards reviewed in 2010 as part of the Departmental Service Implementation Team initiative as a result of Treasury Board Secretariat Service Policy and the Management Accountability Framework on Citizen-Focused Service. No changes were required.
 

A periodic review of existing standards in full consultations with stakeholders is expected every 5 years with the next review planned for 2014–15.
 

Complaint mechanisms enabling feedback from members of the public and stakeholders have been established. Mechanisms are incorporated into each service standard, and are included on the Transport Canada website for service standards related to airports operated by Transport Canada or on its behalf.

Airports — Vehicle Parking Charges

Airports National Service Standards

Airports Performance Measurement for 2012/13
Performance met standards more than 90 percent of the time.

Consistent with approach used in 2006, when first implementing service standards, ongoing stakeholder consultations and feedback are managed through existing channels (e.g. tenant meetings, comment cards, etc.) at the various sites and on Transport Canada’s web site. Stakeholder relationships are important and valued.
 

Reviews of 2012–13 feedback have been satisfactory and no outstanding issues reported. In 2013–14, feedback will continue to be managed through the existing channels.
 

Service standards reviewed in 2010 as part of the Departmental Service Implementation Team initiative as a result of Treasury Board Secretariat Service Policy and the Management Accountability Framework on Citizen-Focused Service. No changes were required.
 

A periodic review of existing standards in full consultations with stakeholders is expected every 5 years with the next review planned for 2014–15.
 

Complaint mechanisms enabling feedback from members of the public and stakeholders have been established. Mechanisms are incorporated into each service standard, and are included on the Transport Canada website for service standards related to airports operated by Transport Canada or on its behalf.

Ports — Public Port Revenues: Wharfage & transfers, Berthage, Storage, Harbour Dues, Utilities and Other Services

Public Ports National Service Standards

Public Ports and Public Port Facilities Performance Measurements for 2012/13


Performance met standards more than 90 percent of the time.

Ongoing feedback is possible through on-site representation, by contacting the regional offices and through Transport Canada’s website (Ports section).
 

Reviews of 2012–13 feedback have been satisfactory and there are no outstanding issues reported.  In 2013–14, stakeholder feedback will continue to be managed through the existing channels.
 

Service standards were reviewed in 2010 as part of the Departmental Service Implementation Team initiative as a result of Treasury Board Secretariat Service Policy and the Management Accountability Framework on Citizen-Focused Service. No changes were required.
 

A periodic review of existing standards in full consultations with stakeholders is expected every 5 years with the next review planned for fiscal year 2014–15.
 

A complaint mechanism has been implemented through feedback on Transport Canada’s website for service standards related to public ports and public port facilities. Other dispute mechanisms are in place and built into each service standard.

Fees charged for the processing of access requests filed under the Access to Information Act

Service standards are in the
Access to Information Act, section 7
Response provided within 30 days following receipt of request; the response time may be extended pursuant to section 9 of the Access to Information Act. Notice of extension is to be sent within 30 days after receipt of the request.

Statutory deadlines were met for 80 percent of requests. One hundred percent of extension notices were sent within 30 days following receipt of the request.

The service standard is established by the Access to Information Act and the Access to Information Regulations.
 

Consultations are not carried out by Transport Canada as fees and service standards were not introduced by this department. Consultations with stakeholders were undertaken by the Department of Justice and the Treasury Board.  Secretariat.
 

The Act was last amended on March 16, 2012 and the fee regulation in 2010 but with no impact on service standards or fees.
 

Complaint mechanism is described under section 30 of the Act.

Other Information:

Note: The Internet links for User Fees and External Fees may change following publication of the Departmental Performance Report since the various websites are updated regularly.

As established pursuant to the Policy on Service Standards for External Fees:

  • service standards may not have received parliamentary review; and
  • service standards may not respect all performance standard establishment requirements under the User Fees Act (e.g. international comparison; independent complaint address ); and
  • performance results are not legally subject to section 5.1 of the User Fees Act regarding fee reductions for unachieved performance.

Main achievement in improving service and client satisfaction across the Department to ensure Citizen-Focused Services as assessed under the Management Accountability Framework process:

  • Service standards for services with fees have been developed, performance is tracked and reported annually to comply with the User Fees Act and the Treasury Board of Canada Secretariat’s Policy on Service Standards for External Fees. These instruments do not include any specific requirement for measuring client satisfaction other than the need for service standards to be developed in consultation with paying and non-paying stakeholders, and the reporting of performance.

    To provide more opportunities for stakeholders to provide feedback, recommendations or raise issues, Transport Canada has established ongoing feedback and consultations through the internet for all its user fees and external fees, as reported in the respective tables of the Departmental Performance Report. This initiative ensures that stakeholders’ recommendations, concerns and complaints are considered and handled by the various groups with redress mechanisms undertaken, as appropriate. Efforts are being taken to enhance the level of details and the reporting on stakeholders’ feedback and complaints.
  • Service standards, performance reporting and client satisfaction are also reviewed as part of the departmental Service Improvement Team initiative as a result of the TBS Service Policy and the Management Accountability Framework assessment area on Citizen-Focused Service. In 2008, Transport Canada established a Service Improvement Team composed of senior management from all modes and is responsible for recommending and supporting the implementation of service standards across the department. An external service inventory was produced in 2009.

    Specific service standards already exist for services subject to the User Fees Act and the TBS Policy on Service Standards for External Fees. As a next step, a departmental-wide service charter was launched in 2010 as a pledge to the level of service clients can expect from the department. For easy access, all service standard information has been regrouped under one web page as “Services for Canadians”.  To strengthen service delivery and professionalism, a customized Service Excellence in the Regulatory Sector training course is being developed in partnership with the Canada School of Public Service for the inspectorate community.
  • Findings from the recent Red Tape Reduction Commission report are being reviewed and addressed as appropriate, with an increased focus on a department-wide client complaint and feedback system. 

Notes

[1] The department collects two types of fees: Regulatory Services (R) and Other Products and Services (O). (Return to footnote 1 source paragraph)

[2] Full Costs (Actual and Estimates) are reported on an accrual basis. They represent the full cost of providing a service, good, facility or privilege. Full cost is not necessarily the cost attributed to fee-paying clients and a lower cost recovery level may be required based on the economic impact on stakeholders, stakeholders’ ability to pay, the degree to which a price may affect the achievement of public policy objectives, etc.

Consistent with instructions for the Departmental Performance Report, Full Costs are calculated according to costing principles identified in the Treasury Board's Guide to Costing, revised in May 2008.

Full Costs are defined as "The sum of all costs, direct and indirect, incurred by the government in the supply of a good, service, property, or right or privilege, including: services provided without charge by other departments (e.g., accommodation, legal services); costs financed by separate authorities (e.g., some employee benefits); annualized capital costs; and financing costs for revolving funds as relevant to departments. However, since the primary focus of this guide is full costing for cost recovery, transfer payments have not been included."

Three-Year Full Costs Forecasts identified were driven by operating costs provided for the Annual Reference Level Update and the Report on Plans and Priorities for 2012–13. Operating costs were then converted to a Full Cost base. (Return to footnote 2 source paragraph)

[3] Revenues figures reported on a modified cash basis. Three-Year Revenues Forecasts identified were those reported in the Annual Reference Level Update supporting the Report on Plans and Priorities for 2012–13 (Return to footnote 3 source paragraph)

[4] According to prevailing legal opinion, where the corresponding fee introduction or most recent modification occurred prior to March 31, 2004:

  • the performance standard, if provided, may not have received parliamentary review; and
  • the performance standard, if provided, may not respect all established requirements under the User Fees Act (e.g., international comparison; independent complaint address); and
  • the performance result, if provided, is not legally subject to the User Fees Act, section 5.1, regarding fee reductions for failed performance.

(Return to footnote 4 source paragraph)

[5] Main achievement in client satisfaction and improving services across the Department to ensure Citizen-Focused Services as assessed under the Management Accountability Framework process:

  • Service standards for services with fees have been developed, performance is tracked and reported annually to comply with the User Fees Act and the Treasury Board of Canada Secretariat’s Policy on Service Standards for External Fees. These instruments do not include any specific requirement for measuring client satisfaction, other than the need for service standards to be developed in consultation with paying and non-paying stakeholders, and the reporting of performance results. To provide more opportunities for stakeholders to provide feedback, recommendations or raise issues, Transport Canada has established ongoing mechanisms for feedback and consultations through its web site for all services with user fees, as reported in the above User Fee tables. This initiative ensures that stakeholders’ recommendations, concerns and complaints are considered and handled by the various groups with redress mechanisms undertaken, as appropriate. Efforts are being taken to enhance the reporting and level of details and on stakeholders’ feedback and complaints.
  • Service standards, performance reporting and client satisfaction are also reviewed as part of the departmental Service Improvement Team initiative as a result of the TBS Service Policy and the Management Accountability Framework assessment area on Citizen-Focused Service. In 2008, Transport Canada established this team composed of senior management from all modes and is responsible for recommending and supporting the implementation of service standards across the department. An external service inventory was produced in 2009. Specific service standards already exist for services subject to the User Fees Act and the TBS Policy on Service Standards for External Fees. As a next step, a departmental-wide service charter was launched in 2010 as a pledge to the level of service clients can expect from the department. For easy access, all service standard information has been regrouped under one web page as “Services for Canadians”.  To strengthen service delivery and professionalism, a customized Service Excellence in the Regulatory Sector training course is being developed in partnership with the Canada School of Public Service for the inspectorate community.
  • Findings on service delivery identified in the recent Red Tape Reduction Commission report are being reviewed and addressed as appropriate. Possibility for establishing a unique department-wide client complaint management system might be considered and would need further analysis. (Return to footnote 5 source paragraph)
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