In determining whether fees or rates charged by retained legal counsel are reasonable, the Department may consider:
(a)
Whether the lowest reasonably achievable fees or rates (including any currently available or negotiable discounts) were obtained from retained legal counsel;
(b)
Whether lower rates from other firms providing comparable services were available;
(c)
Whether alternative rate structures such as flat, contingent, and other innovative proposals, were considered;
(d)
The complexity of the legal matter and the expertise of the law firm in this area; and