RNL enrollment and financial aid models

Todd Feathers filed this request with the Kutztown University of Kutztown, PA.

It is a clone of this request.

Tracking #

2022-05
Submitted Jan. 28, 2022
Status
Rejected

Communications

From: Todd Feathers

Subject: Pennsylvania Right to Know Act Request: RNL enrollment and financial aid models

Email

To Whom It May Concern:

Pursuant to the Pennsylvania Right to Know Act, I hereby request the following records:

1) All contracts with Ruffalo, Noel, Levitz (RNL) since Jan. 1, 2018 for enrollment management and financial aid optimization services.

2) All reports provided to the university by RNL since Jan. 1, 2018 regarding the following RNL services:
- Historical Research & Competitor Benchmarking
- Econometric Modeling
- Annual Financial Aid Plan Development
- RNL Smart View Dashboards & Reporting for Insight-Driven Response
- Retention Analysis
- Revenue Optimization & Simulation
- Four-Year Enrollment & Net Revenue Projection Model
- Enrollment Likelihood and FinAid Receptivity Scoring

3) All validation studies, differential impact studies, or comparable studies supplied by RNL or done by the university or a third party on the university's behalf regarding the accuracy of RNL's predictive models.

4) De-identified copies of all enrollment and financial aid model training datasets supplied to/received from RNL for 2021-2022 school year applicants, containing:
- All non-identifiable variables for each applicant that the university supplies to RNL for the purpose of building and training its predictive models
AND
- All output data fields (i.e., receptivity scores, lead categories, etc.) generated by RNL's predictive models for each applicant.

With regards to item 4 of my request, please note that I am asking for a de-identified data set that does not include fields that could be used to identify an individual applicant (e.g., name, address, SSN). These fields can easily be redacted by deleting those columns from the responsive spreadsheet.

I ask that all fees be waived as intend to use the requested records to further public understanding of public agencies and not for any commercial purpose. 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 responsive documents, 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 5 business days, as the statute requires.

Sincerely,

Todd Feathers

From: Kutztown University

Subject: RE: Pennsylvania Right to Know Act Request: RNL enrollment and financial aid models

Email

Good Morning,

Attached, please find a response to your RTKL request.

Sincerely,

[/Users/demarco/Desktop/KU GRAPHICS/KU logos NEW/one color/Coated (452, 195, 123)/JPEG/RGB/KUwLines-195_RGB_C.jpg]
Right to Know Law Office
Kutztown University of Pennsylvania
Old Main, A Wing, Room 2 | PO Box 730 | Kutztown, PA 19530
Phone: 610-683-4700| Fax: 610-683-4798 | www.kutztown.edu<http://www.kutztown.edu/>

From: Kutztown University

Subject: RE: Pennsylvania Right to Know Act Request: RNL enrollment and financial aid models

Email

Good Morning,

I have reattached the letter I sent you dated February 1, 2022. Please note, an initial response was due within five (5) business days, or by February 4, 2022, which was satisfied by the February 1st letter. In the last paragraph of the February 1st letter, I noted a final response was due and would be sent on or before March 6, 2022 as permitted by law.

Sincerely,

[/Users/demarco/Desktop/KU GRAPHICS/KU logos NEW/one color/Coated (452, 195, 123)/JPEG/RGB/KUwLines-195_RGB_C.jpg]
Right to Know Law Office
Kutztown University of Pennsylvania
Old Main, A Wing, Room 2 | PO Box 730 | Kutztown, PA 19530
Phone: 610-683-4700| Fax: 610-683-4798 | www.kutztown.edu<http://www.kutztown.edu/>

From: Kutztown University

Subject: RE: Pennsylvania Right to Know Act Request: RNL enrollment and financial aid models

Email

Good Afternoon,

Attached, please find a final response to your RTKL request. Please note, given the size of the attachments, additional responsive documents will be sent via a second e-mail.

Sincerely,

[/Users/demarco/Desktop/KU GRAPHICS/KU logos NEW/one color/Coated (452, 195, 123)/JPEG/RGB/KUwLines-195_RGB_C.jpg]
Right to Know Law Office
Kutztown University of Pennsylvania
Old Main, A Wing, Room 2 | PO Box 730 | Kutztown, PA 19530
Phone: 610-683-4700| Fax: 610-683-4798 | www.kutztown.edu<http://www.kutztown.edu/>

From: Kutztown University

Subject: RE: Pennsylvania Right to Know Act Request: RNL enrollment and financial aid models

Email

Attached, please find additional responsive documents related to the RTKL request submitted to Kutztown University, as outlined below.

Sincerely,

[/Users/demarco/Desktop/KU GRAPHICS/KU logos NEW/one color/Coated (452, 195, 123)/JPEG/RGB/KUwLines-195_RGB_C.jpg]
Jacqueline C. Fox, Esq.
Assistant Vice President for Equity and Compliance
Deputy Title IX Coordinator
Right to Know Law Official
Office of Social Equity
Kutztown University of Pennsylvania
Old Main, A Wing, Room 2 | PO Box 730 | Kutztown, PA 19530
Phone: 610-683-4700| Fax: 610-683-4798 | jfox@kutztown.edu<mailto:jfox@kutztown.edu>

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From: Todd Feathers

Subject: RE: Pennsylvania Right to Know Act Request #2022-05

Email

Thank you very much for your assistance with these request, these documents are very helpful.

After reading through them, I wanted to inquire about several documents that are referenced by name in the RNL enrollment services contract you provided. I believe these documents are responsive to my original request, and I'd like to get copies of them as well. If it's easier for me to submit a new request for these additional documents, I'm happy to do so.

The documents specifically mentioned in the contract that I'd like to request are:

1) The historical analysis and competitor benchmarking report ("a comprehensive investigation of undergraduate student enrollment behaviors related to their needs, academic credentials, population segments, and financial aid offers [approximately 100+ pages]," according to page 45 of the contract).

2) ForecastPlus model reports for the prospect model, inquiry model, and admit model (referenced on page 42 of the contract). I have attached an example of one of these reports from another university, for your reference.

3) Annual econometric modeling reports (referenced on pages 45 and 46 of the contract)

4) The results of the revenue optimization and simulation model (referenced on page 46 of the contract) for each year since Jan. 1, 2018.

Thank you very much for your help, and if you have any questions for me, please don't hesitate to ask!

Todd

From: Kutztown University

Subject: RE: Pennsylvania Right to Know Act Request #2022-05

Email

Good Morning Mr. Feathers,

As stated in the response letter sent to you on March 1, 2022, your request for the reports listed below were denied on the following basis:

Denied pursuant to 65 P. S. §§ 67.708(b)(10)(i)(A). In Shannon v. Pa. Dep’t of Educ., the Office of Open Records (OOR) found that, while communications from an agency’s contractor were not internal, a report generated by the consultant for the agency’s exclusive use that was not shared with anyone outside the agency qualified as internal. OOR Dkt. AP 2021-1351, 2021 PA O.O.R.D. 1797. The OOR noted that this is particularly the case when the records constitute “research, memos or other documents used in the predecisional deliberations.” Id. (quoting 65 P.S. § 67.708(b)(10)(i)(A)); see also Wolfson v. Allegheny County, OOR Dkt. AP 2021-2372, 2021 PA O.O.R.D. 2529 (finding that a master spreadsheet of proposals that was internally compiled but discussed with an outside accounting firm to ensure eligibility qualified as internal). Specifically, in Shannon v. Pa. Dep’t of Educ., the OOR ruled that a report authored by an outside third-party Department of Education contractor, which was used by the Department of Education for the purpose of internally deliberating policy and courses of conduct, was internal to the Department and therefore exempt from disclosure. OOR Dkt. AP 2021-1351, 2021 PA O.O.R.D. 1797.

Therefore, these reports will not be provided.

Sincerely,

Jacqueline Fox, Esq.

[/Users/demarco/Desktop/KU GRAPHICS/KU logos NEW/one color/Coated (452, 195, 123)/JPEG/RGB/KUwLines-195_RGB_C.jpg]
Jacqueline C. Fox, Esq.
Assistant Vice President for Equity and Compliance
Deputy Title IX Coordinator
Right to Know Law Official
Office of Social Equity
Kutztown University of Pennsylvania
Old Main, A Wing, Room 2 | PO Box 730 | Kutztown, PA 19530
Phone: 610-683-4700| Fax: 610-683-4798 | jfox@kutztown.edu<mailto:jfox@kutztown.edu>

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