DHS WI

Dhruv Mehrotra filed this request with the Department of Health Services of Wisconsin.
Status
Completed

Communications

From: Dhruv Mehrotra

To Whom It May Concern:

Pursuant to the Wisconsin Open Records Act, I hereby request the following records:

According to the USDA, in 2022, DHS was awarded $741,751 by the USDA through their SNAP Fraud Framework Implementation Grant to develop a data analysis program that will "quickly identify and analyze fraudulent SNAP transactions, identify fraud trends, and allow data and data analysis to be readily accessible to data analysts and investigators in all stages of the investigation."

I am seeking:

1) Contracts, memorandums of understanding, and statements of work between the department 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 pursuant to this grant or 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 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.

Sincerely,

Dhruv Mehrotra

From: Department of Health Services

Hello,
And apologies for the delay. Let us check with the records custodian.
Best,
Elizabeth

[You Stop the Spread logo]Elizabeth Goodsitt
Communications Specialist - Advanced
Wisconsin Department of Health Services
608-267-3810 | Media Line: 608-266-1683

[cid:image003.png@01D95665.2354B5A0]<https://www.facebook.com/DHSWI/> [cid:image004.png@01D95665.2354B5A0] <https://twitter.com/DHSWI> [cid:image005.png@01D95665.2354B5A0] <https://www.instagram.com/dhs.wi/> [cid:image006.png@01D95665.2354B5A0] <https://www.linkedin.com/company/wisconsin-department-of-health-services>
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NOTICE: This email and any attachments may contain confidential information. Use and further disclosure of the information by the recipient must be consistent with applicable laws, regulations, and agreements. If you receive this email in error, please notify the sender; delete the email; and do not use, disclose or store the information it contains.

From: Department of Health Services

This email is to acknowledge your request to the Department of Health Services (DHS) regarding the SNAP Fraud Framework Implementation Grant. As the custodian of this record, DHS has asked the Office of the Inspector General (OIG) to respond. We are in the process of analyzing the request.

OIG gives public records requests high priority and provides requested records as soon as practicable and without delay. A reasonable time for response to a specific public record request depends on the nature of the request, the staff and other resources available to process the request, the extent of the request, and whether confidential material contained in the responsive records must be redacted.

According to Wis. Stat. § 19.35(3), the Department may charge for locating records if the cost is $50 or more, as well as the costs of copies or scanning and mailing/shipping the records responsive to the request. We will prepare an estimate for the cost of the requested documents, if any, and will submit an invoice to you before compiling the records. Also, under Wis. Stat. § 19.35(3)(f), OIG will require prepayment of the estimated cost of providing a copy of the records to you if the total cost exceeds $5.

You may direct any questions concerning this request to dhsoigopenrecordsrequest@wi.gov<mailto:dhsoigopenrecordsrequest@wi.gov>.

Sincerely,

Anthony J. Baize
Inspector General
Wisconsin Department of Health Services
Phone: 608.266.2521
Fax: 608.267.3380

NOTICE: This email and any attachments may contain confidential information. Use and further disclosure of the information by the recipient must be consistent with applicable laws, regulations and agreements. If you received this email in error, please notify the sender, delete the email and do not use, disclose or store the information it contains.

From:

The Office of the Inspector General has received your email regarding an open records request. A staff member will review and respond to your request as soon as possible.

From:

The Department of Health Services Office of the Inspector General has received your open records request. We always strive to respond to open records requests as soon as possible. However, due to the magnitude of our workload during the COVID-19 response, we may not be able to provide a response as promptly as we otherwise would. Your patience is appreciated and we hope that you stay well.

From: Department of Health Services

We continue to gather the records for your request and anticipate that they will be ready next week.

Please direct any questions concerning this request to dhsoigopenrecordsrequest@wi.gov<mailto:dhsoigopenrecordsrequest@wi.gov>.

Sincerely,

Anthony J. Baize

Inspector General

Wisconsin Department of Health Services

Phone: 608.266.2521

Fax: 608.267.3380

NOTICE: This email and any attachments may contain confidential information. Use and further disclosure of the information by the recipient must be consistent with applicable laws, regulations and agreements. If you received this email in error, please notify the sender, delete the email and do not use, disclose or store the information it contains.

From:

The Office of the Inspector General has received your email regarding an open records request. A staff member will review and respond to your request as soon as possible.

From:

The Department of Health Services Office of the Inspector General has received your open records request. We always strive to respond to open records requests as soon as possible. However, due to the magnitude of our workload during the COVID-19 response, we may not be able to provide a response as promptly as we otherwise would. Your patience is appreciated and we hope that you stay well.

From: Department of Health Services

This email is to follow-up on your request to the Department of Health Services (DHS) Office of the Inspector General (OIG) regarding the SNAP Fraud Framework Implementation Grant. You have requested:

1) Contracts, memorandums of understanding, and statements of work between the department and any outside party regarding the implementation of any service to detect or predict fraud Responsive records are attached. "ebtINSIGHT Amendment" & "IVR-Common Pin Amendment"
2) Documentation of all decision-making algorithms, fraud detection,, or predictive models pursuant to this grant or 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. We are working to identify and redact trade secrets and will provide a redacted copy as soon as practicable.
3) A data dictionary/library for each predictive or detection model or algorithm identified in response to items 1 and 2 of this requests. There are no responsive records.
4) Copies of any internal or independent audits of the identified models or algorithms. There are no responsive records.
5) Aggregate or disaggregated data, if any exists, breaking down the risk scores or outputs of the fraud model. There are no responsive records.

Wisconsin open records statutes specifically exclude from release "any record or portion of a record containing information qualifying as a trade secret". (Wis. Stat. § 19.36 (5)).

If you believe that the Department has improperly determined that materials should not be provided to you, please do not hesitate to contact me. Further, if you do so believe, you have a right under Wis. Stat. § 19.37(1) to have the determination reviewed by mandamus or upon application to the attorney general or appropriate district attorney.

If you should have any questions, you may contact me at dhsoigopenrecordsrequest@wi.gov.

Sincerely,

Anthony J. Baize
Anthony J. Baize
Inspector General
Wisconsin Department of Health Services
Phone: 608.266.2521
Fax: 608.267.3380

NOTICE: This email and any attachments may contain confidential information. Use and further disclosure of the information by the recipient must be consistent with applicable laws, regulations and agreements. If you received this email in error, please notify the sender, delete the email and do not use, disclose or store the information it contains.

From: Department of Health Services

I am emailing you to provide you with an update on your open records requests regarding the SNAP Fraud Framework Implementation Grant. We continue to work with FIS on identifying and redacting trade secrets. We anticipate that this will be complete during the first week of June.

Please direct any questions concerning this request to dhsoigopenrecordsrequest@wi.gov<mailto:dhsoigopenrecordsrequest@wi.gov>.

Sincerely,

Anthony J. Baize

Inspector General

Wisconsin Department of Health Services

Phone: 608.266.2521

Fax: 608.267.3380

NOTICE: This email and any attachments may contain confidential information. Use and further disclosure of the information by the recipient must be consistent with applicable laws, regulations and agreements. If you received this email in error, please notify the sender, delete the email and do not use, disclose or store the information it contains.

From: Dhruv Mehrotra

Thanks so much for your help, don't hesitate to let me know if you need something else from me.

From:

The Department of Health Services Office of the Inspector General has received your open records request. We always strive to respond to open records requests as soon as possible. However, due to the magnitude of our workload during the COVID-19 response, we may not be able to provide a response as promptly as we otherwise would. Your patience is appreciated and we hope that you stay well.

From:

The Office of the Inspector General has received your email regarding an open records request. A staff member will review and respond to your request as soon as possible.

From: Department of Health Services

Please see the attached email update.

Thanks.
Michelle

NOTICE: This email and any attachments may contain confidential information. Use and further disclosure of the information by the recipient must be consistent with applicable laws, regulations and agreements. If you received this email in error, please notify the sender, delete the email and do not use, disclose or store the information it contains.

From: Department of Health Services

This email is to follow-up on your request to the Department of Health Services (DHS) Office of the Inspector General (OIG) regarding the SNAP Fraud Framework Implementation Grant. You have requested:

1) Contracts, memorandums of understanding, and statements of work between the department and any outside party regarding the implementation of any service to detect or predict fraud. Previously provided.
2) Documentation of all decision-making algorithms, fraud detection,, or predictive models pursuant to this grant or 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. Responsive records are attached.
3) A data dictionary/library for each predictive or detection model or algorithm identified in response to items 1 and 2 of this requests. There are no responsive records.
4) Copies of any internal or independent audits of the identified models or algorithms. There are no responsive records.
5) Aggregate or disaggregated data, if any exists, breaking down the risk scores or outputs of the fraud model. There are no responsive records.

The "ebtEDGE ebtINSIGHT User Guide"contains confidential and proprietary trade secrets which FIS wishes to protect. Consistent with the Wisconsin trade secret statutes (Wis. Stat. § 134.90(1)(c)), the information in the requested document is not generally known or available outside of FIS, and is not shared externally except under designations of confidentiality with FIS clients.

Wisconsin open records statutes specifically exclude from release "any record or portion of a record containing information qualifying as a trade secret". (Wis. Stat. § 19.36 (5)) FIS has examined the requested document and has identified those portions that may be disclosed without revealing FIS' trade secrets or proprietary commercial and financial information.

Information that either constitutes a trade secret or that is confidential and proprietary such that release of the information could place the contractor at a competitive disadvantage or otherwise cause economic harm to the contractor has been redacted under the public policy balancing test. I find the public interest in access to the confidential business information is outweighed by the public interest in attracting and maintaining contractors who perform highly specialized work for DHS.

Names and contact information for specific employees of the contractor have been redacted to protect the privacy of individuals who work for private employers and to prevent competitors from trying to poach highly skilled employees. I find the public interest in access to the names of employees for a private company is outweighed by the public interest in attracting and maintaining contractors who perform highly specialized work for DHS.

Upon balancing the confidentiality and trade secret provisions and the interests of the public in open government we are providing in compliance with §19.36 (6) the enclosed redacted copy of the requested document.

If you believe that the Department has improperly determined that materials should not be provided to you, please do not hesitate to contact me. Further, if you do so believe, you have a right under Wis. Stat. § 19.37(1) to have the determination reviewed by mandamus or upon application to the attorney general or appropriate district attorney.

This fulfills your open records request and we will consider your request closed. If you should have any questions, you may contact me at dhsoigopenrecordsrequest@wi.gov<mailto:dhsoigopenrecordsrequest@wi.gov>.

Sincerely,

Anthony J. Baize
Anthony J. Baize
Inspector General
Wisconsin Department of Health Services
Phone: 608.266.2521
Fax: 608.267.3380

NOTICE: This email and any attachments may contain confidential information. Use and further disclosure of the information by the recipient must be consistent with applicable laws, regulations and agreements. If you received this email in error, please notify the sender, delete the email and do not use, disclose or store the information it contains.

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