Complainant alleged that the RICDHH violated the APRA when it failed to respond to two oral and one written request for documents. Complainant also alleged that the RICDHH failed to maintain written APRA procedures. The undisputed evidence indicated that although the two oral requests were arguably not proper requests pursuant to the APRA, the RICDHH did not have any formal APRA procedures and we therefore treated the oral requests as APRA requests. We also found that the written request was clearly an APRA request as it was labeled as such. The RICDHH's failure to respond to any of these requests violated the APRA. We also found that the RICDHH's failure to maintain written APRA procedures violated the APRA. As such, this Department directed the RICDHH to provide a supplemental response addressing why the violations we found should not be considered "knowing and willful" or "reckless" violations.