Disability benefits algorithm audit

To Whom It May Concern:

Pursuant to the Kentucky Open Records Act, I request the following records regarding algorithmic tools used by your agency to guide decision making for the administration of Social Security Disability Insurance (SSDI), Supplemental Security Income (SSI), and/or supplemental state disability benefits:

For the purposes of this request, the term algorithmic tools refers to computer software or code that employs machine learning techniques (sometimes described as artificial intelligence or predictive analytics). It does not apply to other types of algorithms, such as Excel formulas.

My request applies to all algorithmic tools developed in-house by your agency, purchased for use by your agency, or otherwise used by your agency since Jan. 1, 2018 to help administer Social Security Disability Insurance (SSDI), Supplemental Security Income (SSI), and/or supplemental state disability benefits. Such algorithmic tools include, but are not limited to, models for:

- Fraud detection
- Rate setting
- Benefit use prediction (e.g., models that predict for how long individuals will require benefits or what the total cost will be)
- Enrollment prediction (e.g., models that predict enrollment rates among the larger population)
- Case management (e.g., models that group similar cases together or determine caseloads for adjudicators)
- Investigations (e.g., models that prioritize complaints for investigation or flag claims for additional review)
- Advertising/outreach prioritization (e.g. models used to decide where or to which groups to advertise)

For each algorithmic tool your agency has used since Jan. 1, 2018, I request the following records:

1) Executive summaries, project overviews, or comparable records that describe the scope and purpose of the algorithmic tool.

2) Contracts, statements of work, successful RFP submissions and bid packets, or comparable records that describe the purchase and/or construction of the algorithmic tool.

3) User handbooks, guides, training manuals, agency policies, or comparable records that describe the tool’s functions and its appropriate uses..

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 the lowest-paid employee capable of processing the request and an explanation justifying the employee hours required to complete 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 portion from public review.

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 3 business days, as the statute requires.

Sincerely,

Todd Feathers