EAB financial aid optimization documents
| Submitted | Dec. 9, 2021 |
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Communications
From: Todd Feathers
To Whom It May Concern:
Pursuant to the Pennsylvania Right to Know 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 5 business days, as the statute requires.
Sincerely,
Todd Feathers
From: Mansfield University Of Pennsylvania
Dear Mr. Feathers:
Your request refers to an attached contract in items 1, 2, and 3, though no contract was included with the email you sent.
Most Sincerely,
John Cosgrove, Ph.D.
Director of Institutional Research
Campus Right to Know Officer
State Authorizations Coordinator
Mansfield University
5 Swan Street
511 North Hall
Mansfield, PA 16933
From: Todd Feathers
My apologies, please find the document attached.
From: Mansfield University Of Pennsylvania
Dear Mr. Feathers:
This reply is to acknowledge I received your public records request sent to me yesterday, December 9, 2021. I am bound by legislation to provide an acknowledgement of your request within five business days after receiving it, or in the instance of your request, no later than by December 16, 20201. Pursuant to § 67.902 of the Right-to-Know legislation, I have the legislative right to invoke an extension up to 30 calendar days to complete your request, with this extension beginning on December 16, 2021. I am invoking my right for this extension because the extent of your request precludes a response within the initial time frame. As such, Mansfield University will complete your public records request on or before January 15, 2022.
Sincerely,
John Cosgrove, Ph.D.
Director of Institutional Research
Right-to-Know Law Officer
State Authorizations Coordinator
From: Mansfield University Of Pennsylvania
Dear Mr. Feathers:
Because of the holiday break and vacation schedules surrounding it, may I have a voluntary extension to January 25, 2022 to complete your request?
Thank you.
Sincerely,
John Cosgrove, Ph.D.
Director of Institutional Research
Right-to-Know Law Officer
State Authorizations Coordinator
From: Todd Feathers
Yes that's fine!
Thanks very much for the help!
Todd
From: Mansfield University Of Pennsylvania
Mr. Feathers,
Thanks!
John
From: Muckrock Staff
To Whom It May Concern:
I'm following up on the following Pennsylvania Right to Know Act request, copied below, and originally submitted on Dec. 9, 2021. You previously indicated that it would be completed on Jan. 25, 2022. I wanted to let you know that I am still interested in the following documents, and to see if that date was still accurate.
Thanks for your help, and let me know if further clarification is needed.
From: Mansfield University Of Pennsylvania
Dear Mr. Feathers,
Yes, you'll have the information by tomorrow, and possibly by day's end today.
Most Sinercerly,
John
From: Mansfield University Of Pennsylvania
Dear Mr. Feathers:
You made a public records request to Mansfield University that had five parts. I previously notified you I was invoking my right to an extension to complete your request and would have a response to you by or before January 15, 2022. In response to a later request to do so, you graciously and voluntarily extended the January 15 deadline until January 25, 2022.
Item 1 of your request asked for, "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." Your request is granted and is attached as the four documents in the Zip file called "EAB Item 1 Four Documents."
Item 2 of your request asked for, "All aggregated data analysis reports or documents provided to the university by EAB as described on page 49 of the attached contract." Your request is granted and is attached as the five documents in the Zip file called "EAB Item 2 Five Documents."
Item 3 of your request asked for, "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." Your request for this information is denied. The reason for the denial is EAB asserts the models used to provide Mansfield University its services rely upon proprietary intellectual property that are not delivered to the University in any tangible form. Accordingly, EAB does not believe it has any responsive materials to provide for this category of documents. Based upon EAB's submission, § 67.708(b)(11) shields business records where it constitutes or reveals a trade secret or confidential proprietary information. Furthermore, pursuant to Section 705 of the RTKL, 65 P.S. §67.705, the agency is not required to create a record that does not exist, or to compile, maintain, format or organize records in a manner in which it does not currently do so. Also, pursuant to the Office of Open Records' final decision in Jenkins vs. Pennsylvania Department of State, OOR Dkt. AP 2009-065, it should be noted that: "It is not a denial of access when an agency does not possess records and [there is no] legal obligation to obtain them (see, e.g. §67506 (d)(1))".
Item 4 of your request asked for, "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." Your request for this information is denied. Whether de-identified or not, the information being sought is personal financial information and Mansfield University specifically denies your request based upon 65 Pa.C.S. § 67.708(b)(6)(i)(A), which notes personal financial information is exempt from public records requests. Furthermore, such information constitutes an educational record subject to The Family Educational Rights and Privacy Act (FERPA) (20 U.S.C. § 1232g; 34 CFR Part 99). Disclosure of this information may result in a loss of federal funding thus denied under § 67.708(b)(6)(1)(i).
Item 5 of your request asked for, "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." Your request for this information is granted and is attached as "EAB Item 5 Contract," subject to allowable redactions for signatures and other protected information.
You have a right to appeal the denial of information in writing to:
Office of Open Records
333 Market Street
16th Floor
Harrisburg, PA 17126-0333
If you choose to file an appeal you must do so within 15 business days of the mailing date of the agency's response. Please note that a copy of your original Right-to-Know request and this denial letter must be included when filing an appeal. The law also requires that you state the reasons why the record is a public record and address the reasons the Agency denied your request. Visit the Office of Open records website at http://openrecords.pa.gov<http://openrecords.pa.gov/> for further information on filing an appeal.
Please be advised this correspondence will serve to close this record with my office as permitted by law, though also feel free to contact me if you have any questions or concerns about this correspondence.
Most Sincerely,
John Cosgrove, Ph.D.
Director of Institutional Research
Campus Right to Know Officer
State Authorizations Coordinator
Mansfield University
5 Swan Street
G04-C Belknap Hall
Mansfield, PA 16933
570-662-4586
jcosgrov@mansfield.edu<mailto:jcosgrov@mansfield.edu>
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