IDHS

Dear Dhruv Mehrotra:

The Illinois Department of Human Services received your request for records pursuant to the Freedom of Information Act (FOIA) on February 10, 2023. Your request seeks the following:

1. Contracts, memorandums of understanding, and statements of work between the SNAP Fraud Unit and any outside party regarding the implementation of any service to detect or predict fraud.
2. Documentation of all decision-making algorithms, fraud detection,, or predictive models that the agency currently uses (including those used as aids to human decision making). This documentation should include, where available: executive summaries of the algorithm/model's purpose, lists of the data sources, breakdowns of how the model weights various input data, descriptions of the statistical or machine learning techniques employed, the results of validation and accuracy testing, disparate impact studies, and algorithmic impact reports.
3. A data dictionary/library for each predictive or detection model or algorithm identified in response to items 1 and 2 of this requests.
4. Copies of any internal or independent audits of the identified models or algorithms.
5. Aggregate or disaggregated data, if any exists, breaking down the risk scores or outputs of the fraud model.

The Department is still processing your request. Under the Freedom of Information Act, a public body may extend the time to respond to a FOIA request by up to five business days. 5 ILCS 140/3(e). As such, the Department is extending the time to respond to your request by five business days on one or more of the following bases:

* The requested records are stored in whole or in part at other locations than the office having charge of the requested records;
* The request requires the collection of a substantial number of specified records;
* The requested records have not been located in the course of a routine search and additional efforts are being made to locate them;
* The requested records require examination and evaluation by personnel having the necessary competence and discretion to determine if they are exempt from disclosure or should be revealed only with appropriate deletions; and
* The request for records cannot be complied with by the public body within the time limits prescribed by FOIA without unduly burdening or interfering with the operation of the public body.

State offices were closed on Monday, February 13th (Lincoln's Birthday), and they will be closed again on Monday, February 20th (President's Day). As a result, the Department will respond to your request on or before February 28, 2023. Thank you for your continued patience and interest in the Illinois Department of Human Services.

Sincerely,

Thomas D. Mulcrone
Associate General Counsel
Illinois Department of Human Services
DHS.FOIAOfficer@illinois.gov<mailto:DHS.FOIAOfficer@illinois.gov>

CONFIDENTIALITY NOTICE:
This electronic mail transmission, including any attachments, contains information that belongs to the sender and may be confidential or protected by attorney-client or attorney work product privilege. The information is only for the intended recipient. If you are not the named or intended recipient, please do not disclose, copy, distribute or use this information. If you have received this information in error, please promptly notify the sender of receipt of the e-mail and then destroy all copies of it. Receipt by unintended recipient does not waive any privilege or any exemption from disclosure. Any prohibited or unintended disclosure is not binding on the sender or IDHS. Thank you.

State of Illinois - CONFIDENTIALITY NOTICE: The information contained in this communication is confidential, may be attorney-client privileged or attorney work product, may constitute inside information or internal deliberative staff communication, and is intended only for the use of the addressee. Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify the sender immediately by return e-mail and destroy this communication and all copies thereof, including all attachments. Receipt by an unintended recipient does not waive attorney-client privilege, attorney work product privilege, or any other exemption from disclosure.

Dear Dhruv Mehrotra:

This correspondence is in response to your request for public records pursuant to the Freedom of Information Act (FOIA), which the Illinois Department of Human Services (IDHS) received on February 10, 2023. Your request seeks the following:

1. Contracts, memorandums of understanding, and statements of work between the SNAP Fraud Unit and any outside party regarding the implementation of any service to detect or predict fraud.
2. Documentation of all decision-making algorithms, fraud detection,, or predictive models that the agency currently uses (including those used as aids to human decision making). This documentation should include, where available: executive summaries of the algorithm/model's purpose, lists of the data sources, breakdowns of how the model weights various input data, descriptions of the statistical or machine learning techniques employed, the results of validation and accuracy testing, disparate impact studies, and algorithmic impact reports.
3. A data dictionary/library for each predictive or detection model or algorithm identified in response to items 1 and 2 of this requests.
4. Copies of any internal or independent audits of the identified models or algorithms.
5. Aggregate or disaggregated data, if any exists, breaking down the risk scores or outputs of the fraud model.

Attached you will find records responsive to Item 1 of your request. The Department redacted signatures pursuant to Section 7(1)(b), which provides an exemption for private information. 5 ILCS 140/7(1)(b); 5 ILCS 140/2(c-5). Please note, IDHS procured case management and fraud analytics solutions and the related implementation services from West Publishing Corporation though a Master Contract with the Illinois Department of Central Management Services (CMS). Accordingly, the attached files are limited to Purchase Orders and the Statement of Work between West Publishing Corporation and IDHS. For information on how to request public records from CMS, please direct your inquiry to CMS.FOIA@illinois.gov<mailto:CMS.FOIA@illinois.gov>.

According to the IDHS Division of Family & Community Services, disclosure of the information sought in Items 2 - 5 of your request would severely undermine the operations of the SNAP Fraud Unit. Sharing information about fraud detection and predictive models, including audits of the models or algorithms, would allow individuals to identify potential weaknesses in the system. As a result, IDHS is denying Items 2 - 5 of your request pursuant to Section 7(1)(o) of FOIA, which provides an exemption for the following:

(o) Administrative or technical information associated with automated data processing operations, including, but not limited to, software, operating protocols, computer program abstracts, file layouts, source listings, object modules, load modules, user guides, documentation pertaining to all logical and physical design of computerized systems, employee manuals, and any other information that, if disclosed, would jeopardize the security of the system or its data or the security of materials exempt under this Section. 5 ILCS 140/7(1)(o)

To the extent you consider any portion of this response to be an improper denial of your FOIA request, you have a right to seek review by writing to the Public Access Counselor (PAC) at the following address:

Public Access Counselor
Office of the Attorney General
500 South 2nd Street
Springfield, Illinois 62706
Fax: 217-782-1396
E-Mail: Public.Access@ilag.gov<mailto:Public.Access@ilag.gov>

If you choose to file a Request for Review with the PAC, you must do so within 60 calendar days of the date of this letter. 5 ILCS 140/9.5(a). Please note that you must include a copy of your original FOIA request and this response when filing a Request for Review with the PAC. You also have the right to seek judicial review of this response. 5 ILCS 140/11.

Thank you for your interest in the Illinois Department of Human Services.

Sincerely,

Thomas D. Mulcrone
Associate General Counsel
Illinois Department of Human Services
DHS.FOIAOfficer@illinois.gov<mailto:DHS.FOIAOfficer@illinois.gov>

CONFIDENTIALITY NOTICE:
This electronic mail transmission, including any attachments, contains information that belongs to the sender and may be confidential or protected by attorney-client or attorney work product privilege. The information is only for the intended recipient. If you are not the named or intended recipient, please do not disclose, copy, distribute or use this information. If you have received this information in error, please promptly notify the sender of receipt of the e-mail and then destroy all copies of it. Receipt by unintended recipient does not waive any privilege or any exemption from disclosure. Any prohibited or unintended disclosure is not binding on the sender or IDHS. Thank you.

State of Illinois - CONFIDENTIALITY NOTICE: The information contained in this communication is confidential, may be attorney-client privileged or attorney work product, may constitute inside information or internal deliberative staff communication, and is intended only for the use of the addressee. Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify the sender immediately by return e-mail and destroy this communication and all copies thereof, including all attachments. Receipt by an unintended recipient does not waive attorney-client privilege, attorney work product privilege, or any other exemption from disclosure.