EAB financial aid optimization documents
It is a clone of this request.
| Submitted | Dec. 9, 2021 |
| Est. Completion | None |
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Communications
From: Todd Feathers
To Whom It May Concern:
Pursuant to the Texas Public Information Act, I hereby request the following records:
1) All financial aid descriptive analyses performed by EAB and provided to the university as described on page 46 of the attached contract for EAB's financial aid optimization services.
2) All aggregated data analysis reports or documents provided to the university by EAB as described on page 49 of the attached contract.
3) Documentation of the financial aid optimization statistical model built for the university by EAB, described on page 46 of the attached contract. This should include any documents describing the variables incorporated into the model(s) and how those variables are weighted, the model(s)' accuracy metrics (such as AUC), the model(s)' parameters, the machine learning techniques employed, and any validation or disparate impact analyses performed.
4) A de-identified copy of the admissions and financial aid data the university provided to EAB in order for EAB to design its financial aid optimization model, as described on page 46 of the attached contract. Please note, I am not asking for any personally identifiable information about students. Rather, I'm asking for a copy of the dataset that excludes identifiable information such as student names and street addresses. This can easily be done by removing those columns from the spreadsheet.
5) All other contract documents, including memorandums of understanding and statements of work, between the university and EAB regarding financial aid optimization services and/or enrollment optimization services.
I ask that all fees be waived as I am a journalist and intend to use the requested records to publish articles in the public interest. In the event you choose to impose fees, I request a detailed breakdown of the fees, including the hourly wage of each employee involved and an explanation justifying the employee hours required to fulfill the request.
Should you choose to reject this request or redact portions of it, I ask that you provide a detailed breakdown of the statutory exemptions and associated case law underlying your decision to withhold each/any portions from public review.
The requested documents will be made available to the general public, and this request is not being made for commercial purposes.
In the event that there are fees, I would be grateful if you would inform me of the total charges in advance of fulfilling my request. I would prefer the request filled electronically, by e-mail attachment if available or CD-ROM if not.
Thank you in advance for your anticipated cooperation in this matter. I look forward to receiving your response to this request within 10 business days, as the statute requires.
Sincerely,
Todd Feathers
From: Muckrock Staff
To Whom It May Concern:
I wanted to follow up on the following Texas Public Information Act request, copied below, and originally submitted on Dec. 9, 2021. Please let me know when I can expect to receive a response.
Thanks for your help, and let me know if further clarification is needed.
From: University Of Houston
This e-mail is in response to your Texas Public Information Act request below.
In accordance with Texas Government Code § 552.222, the University seeks to discuss with you how your request might be narrowed. The University would like to see if you would be willing to narrow the scope of your request to exclude documents and information that are confidential and/or privileged (i.e. attorney client privilege, deliberative process privilege, and FERPA). The University seeks to narrow the request to exclude these documents and information.
Please note, that if you decide you do not want to narrow to exclude these documents and information then the University will likely file a request for an Attorney General Opinion. Under the Texas Public Information Act, the Office of the Attorney General has 45 working days in which to issue a decision regarding the University of Houston’s request to protect documents.
Please simply respond to this e-mail and let me know if you are willing to narrow the scope of your request in the manner suggested. The University is required to inform you that if you fail to respond to this e-mail seeking to narrow the scope of your request within 61 days, your request will be considered withdrawn.
Should you have any questions, please do not hesitate to contact me.
Thanks
Jeff
Jeffrey D. Palmer
Deputy General Counsel
University of Houston System/University of Houston
4302 University Drive (Suite 311 E. Cullen Building)
Houston, Texas 77204-2028
Direct: 713-743-0836
Fax: 713-743-9179
E-mail: jdpalmer@uh.edu<mailto:jdpalmer@uh.edu>
Notice: Unless otherwise specifically indicated, the information contained in this e-mail message is an attorney-client communication and/or attorney work product and is, therefore, intended only for the review and use of the above-named person(s). If the reader of this message is not the intended recipient, you are hereby notified that the sender does not waive any privilege accorded to this information, and that the recipient is strictly prohibited from any use, storage, dissemination, distribution, or copying of this communication. If you have received this e-mail message in error, please immediately notify sender by telephone at the number above and return the original message to sender at the address above. Thank you.
From: Todd Feathers
Hello,
Could you please describe which documents you would like to withhold as confidential or attorney client privelege?
Todd
From: University Of Houston
The only items that possibly would not be confidential and/or privileged would be the contract with EAB and the de-identified data provided to EAB. However, EAB may argue that those items are exempt from disclosure.
Based on the foregoing, please let me know if you would be willing to narrow the scope of your request to exclude documents and information that are confidential and/or privileged (i.e. attorney client privilege, deliberative process privilege, and FERPA).
Thanks
Jeff
Jeffrey D. Palmer
Deputy General Counsel
University of Houston System/University of Houston
4302 University Drive (Suite 311 E. Cullen Building)
Houston, Texas 77204-2028
Direct: 713-743-0836
Fax: 713-743-9179
E-mail: jdpalmer@uh.edu<mailto:jdpalmer@uh.edu>
Notice: Unless otherwise specifically indicated, the information contained in this e-mail message is an attorney-client communication and/or attorney work product and is, therefore, intended only for the review and use of the above-named person(s). If the reader of this message is not the intended recipient, you are hereby notified that the sender does not waive any privilege accorded to this information, and that the recipient is strictly prohibited from any use, storage, dissemination, distribution, or copying of this communication. If you have received this e-mail message in error, please immediately notify sender by telephone at the number above and return the original message to sender at the address above. Thank you.
From: Todd Feathers
Hello,
Thank you very much for your help with this and I'm sorry for the delayed response.
Given the nature of these documents, I don't agree that any should be withheld or would fall under attorney client privilege or any other exemption. If the issue is with potentially FERPA-protected material, I'm happy to discuss ways the records can be redacted/limited to avoid the disclosure of personally identifiable information.
Should you seek an attorney general opinion, I ask that you also provide me a copy of your request, including descriptions of any documents you claim are exempt and citations for the specific exemptions.
Thank you,
Todd
Sincerely,
Todd
From: University Of Houston
The Texas Public Information Act (“TPIA”) allows a governmental entity to charge requestors for the cost of providing copies of public information. The Office of the Attorney General Cost Rules Administration administers the rules promulgated by the Attorney General to determine charges and methods of charging for copies of public information. Unless the request is for 50 or fewer pages of readily available information, current rules allow for certain charges, including, but not limited to, personnel charges of $15.00 per hour, programming personnel charges of $28.50 per hour, overhead charges of 20% of personnel charges, and standard copy charges of $.10 per page. See 1 TAC §70.10.
We have determined that complying with your request for public information will result in the imposition of a charge that exceeds $100. Therefore, the following statement is provided pursuant to Sections 552.2615 and 552.263 of the Texas Government Code.
1. Itemized statement of estimated charges:
Charge Type
Charge
Amount
Amount
Subtotal
Labor
$15/hr
31 hours
$465
Overhead
20%
93
$94
Total
$558
ESTIMATED TOTAL = $558.00
2. Pursuant to §552.2615 of the Government Code, there is not an alternative, less expensive method of obtaining the requested information, unless you choose to exclude any privileged and/or confidential documents and information. If you choose that alternative, please contact me at (713) 743-0836.
3. Your request will be considered automatically withdrawn if you do not notify us in writing and within 10 (ten) business days from the date of this statement that you:
a. Accept the charges and will pay them. Because your request is over $100, we require a deposit of $279.00 (50% of the estimated charges). Please note that pursuant to section 552.263(e), your request will be considered received when we receive your payment. Additionally, if you fail to pay within 10 business days, your request will be considered withdrawn pursuant to section 552.263(f);
b. Modify your request. Please note the modified request is considered a separate request for the purposes of this chapter and is considered received on the date the University receives the written modified request ; or
c. Have sent a complaint to the Office of the Attorney General of Texas (OAG) alleging that you have been overcharged for being provided with a copy of the public information.
4. You may choose to respond by e-mail, fax, regular mail, or delivering your written response in person to our offices.
5. Your check or money order must be made payable to: The University of Houston
6. Mailing address: 311 Ezekiel Cullen Building; Houston, TX 77204-2028. You may also pay in cash at our offices.
Because the above total is only an estimate, after the University of Houston (the “University”) compiles the information that is responsive to your request, the University will send you a written notification of the actual costs associated with your request. Please note that the total charge must be paid prior to the University releasing the requested information to you. Additionally, please note that the University believes that the information you requested is subject to various exemptions under the TPIA, and anticipates filing a request for any Attorney General Opinion once the information has been compiled.
Please let me know if you have any questions.
Thanks
Jeff
Jeffrey D. Palmer
Deputy General Counsel
University of Houston System/University of Houston
4302 University Drive (Suite 311 E. Cullen Building)
Houston, Texas 77204-2028
Direct: 713-743-0836
Fax: 713-743-9179
E-mail: jdpalmer@uh.edu<mailto:jdpalmer@uh.edu>
Notice: Unless otherwise specifically indicated, the information contained in this e-mail message is an attorney-client communication and/or attorney work product and is, therefore, intended only for the review and use of the above-named person(s). If the reader of this message is not the intended recipient, you are hereby notified that the sender does not waive any privilege accorded to this information, and that the recipient is strictly prohibited from any use, storage, dissemination, distribution, or copying of this communication. If you have received this e-mail message in error, please immediately notify sender by telephone at the number above and return the original message to sender at the address above. Thank you.
From: Todd Feathers
Hello,
Thank you very much for your response.
I think it would be appropriate for the University of Houston to provide at least some explanation of what material it considers confidential and why prior to request an exorbitant fee to produce the material. Furthermore, the university must obtain an attorney general's opinion declaring records exempt from disclosure prior to charging me for redacting those records.
Please initiate your request for an attorney general's opinion and send me a copy of the request.
Todd
From: University Of Houston
The University considers all the information and documents you requested, other than the contract with EAB, to be confidential and/or privileged.
The estimate of charges is only for the gathering of the information.
As a result, your choices are as follows:
a. Accept the charges and pay them. Because your request is over $100, we require a deposit of $279.00 (50% of the estimated charges).
b. Modify your request. Please note the modified request is considered a separate request for the purposes of the TPIA and is considered received on the date the University receives the written modified request ; or
c. Send a complaint to the Office of the Attorney General of Texas (OAG) alleging that you have been overcharged for being provided with a copy of the public information.
Thanks
Jeff
Jeffrey D. Palmer
Deputy General Counsel
University of Houston System/University of Houston
4302 University Drive (Suite 311 E. Cullen Building)
Houston, Texas 77204-2028
Direct: 713-743-0836
Fax: 713-743-9179
E-mail: jdpalmer@uh.edu<mailto:jdpalmer@uh.edu>
Notice: Unless otherwise specifically indicated, the information contained in this e-mail message is an attorney-client communication and/or attorney work product and is, therefore, intended only for the review and use of the above-named person(s). If the reader of this message is not the intended recipient, you are hereby notified that the sender does not waive any privilege accorded to this information, and that the recipient is strictly prohibited from any use, storage, dissemination, distribution, or copying of this communication. If you have received this e-mail message in error, please immediately notify sender by telephone at the number above and return the original message to sender at the address above. Thank you.
From: University Of Houston
In accordance with the attached Texas Attorney General letter, dated May 9, 2022, please see the revised statement of estimated charges below:
The Texas Public Information Act ("TPIA") allows a governmental entity to charge requestors for the cost of providing copies of public information. The Office of the Attorney General Cost Rules Administration administers the rules promulgated by the Attorney General to determine charges and methods of charging for copies of public information. Unless the request is for 50 or fewer pages of readily available information, current rules allow for certain charges, including, but not limited to, personnel charges of $15.00 per hour, programming personnel charges of $28.50 per hour, overhead charges of 20% of personnel charges, and standard copy charges of $.10 per page. See 1 TAC §70.10.
We have determined that complying with your request for public information will result in the imposition of a charge that exceeds $100. Therefore, the following statement is provided pursuant to Sections 552.2615 and 552.263 of the Texas Government Code.
1. Itemized statement of estimated charges:
Charge Type
Charge
Amount
Amount
Subtotal
Labor
$15/hr
28 hours
$420
Overhead
20%
84
$84
Total
$504
ESTIMATED TOTAL = $504.00
2. Pursuant to §552.2615 of the Government Code, the alternative, less expensive method of obtaining the requested information is to exclude from your request any privileged and/or confidential documents and information. If you choose that alternative, please contact me at (713) 743-0836.
3. Your request will be considered automatically withdrawn if you do not notify us in writing and within 10 (ten) business days from the date of this statement that you:
a. Accept the charges and will pay them. Because your request is over $100, we require a deposit of $252.00 (50% of the estimated charges). Please note that pursuant to section 552.263(e), your request will be considered received when we receive your payment. Additionally, if you fail to pay within 10 business days, your request will be considered withdrawn pursuant to section 552.263(f);
b. Modify your request. Please note the modified request is considered a separate request for the purposes of this chapter and is considered received on the date the University receives the written modified request ; or
c. Have sent a complaint to the Office of the Attorney General of Texas (OAG) alleging that you have been overcharged for being provided with a copy of the public information.
4. You may choose to respond by e-mail, fax, regular mail, or delivering your written response in person to our offices.
5. Your check or money order must be made payable to: The University of Houston
6. Mailing address: 311 Ezekiel Cullen Building; Houston, TX 77204-2028. You may also pay in cash at our offices.
Because the above total is only an estimate, after the University of Houston (the "University") compiles the information that is responsive to your request, the University will send you a written notification of the actual costs associated with your request. Please note that the total charge must be paid prior to the University releasing the requested information to you. Additionally, please note that the University believes that the information you requested is subject to various exemptions under the TPIA, and anticipates filing a request for any Attorney General Opinion once the information has been compiled.
Please let me know if you have any questions.
Jeff
Jeffrey D. Palmer
Deputy General Counsel
University of Houston System/University of Houston
4302 University Drive (Suite 311 E. Cullen Building)
Houston, Texas 77204-2028
Direct: 713-743-0836
Fax: 713-743-9179
E-mail: jdpalmer@uh.edu<mailto:jdpalmer@uh.edu>
Notice: Unless otherwise specifically indicated, the information contained in this e-mail message is an attorney-client communication and/or attorney work product and is, therefore, intended only for the review and use of the above-named person(s). If the reader of this message is not the intended recipient, you are hereby notified that the sender does not waive any privilege accorded to this information, and that the recipient is strictly prohibited from any use, storage, dissemination, distribution, or copying of this communication. If you have received this e-mail message in error, please immediately notify sender by telephone at the number above and return the original message to sender at the address above. Thank you.
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