EPIC Recommends ACUS Consider Administrative Burdens Exacerbated By Scoring and Screening Tools, Recommend Transparency

In comments submitted to the Administrative Conference of the United States regarding Identifying and Reducing Administrative Burdens, EPIC recommended the agency consider how automated decision making systems are often adopted to reduce barriers on their face, but ends up inflicting additional harms. These harms are the privacy of benefit recipients when data-hungry systems are adopted, the perpetuation of discriminatory impact, and increased time to work with glitchy or nonoperational third-party websites.

EPIC urged the agency to consider and recommend transparency and accountability mechanisms in order to facilitate more trustworthy delivery of government services.

In November 2022, EPIC released Screened & Scored in the District of Columbia, is the result of a 14-month investigation into the automated systems used by D.C. government agencies and combines extensive legal research with qualitative research methods, interviews, and Freedom of Information Act (FOIA) requests. It includes four case studies, a first-of-its-kind table highlighting 29 automated tools used by D.C. agencies, and two vignettes—a technique common in qualitative research—to capture what it feels like to experience automated screening and scoring first-hand.

Screened & Scored in the District of Columbia is part of EPIC’s Scoring and Screening project, which works to protect the public from the algorithmic harms that automated systems may produce. For more information on this report and the research that supports it, visit EPIC’s dedicated webpage.