# PIR #AISD-R873 — Follow-up Reply Draft

## What AISD Said (5/28 follow-up email)

Austin ISD sent a brief follow-up to our 5/22 narrowed portal reply:

- **#9b (intra-district transfers):** Reiterated refusal, citing FERPA. Claims the District does not maintain between-campus transfer records in the requested format (originating campus, receiving campus, school year, count) and that producing them would require sharing student-identifiable information. Offers a time and cost estimate if we want to proceed.
- **#4c (statutory basis):** Claims the cost estimates for #4a and #4b "were directly connected to #4c and answers your question."
- **Closure ultimatum:** Asks whether we want to proceed with a cost estimate for #9b, and if not, confirms we want them to close the request.

## Open Items

| Item | Status |
|------|--------|
| #1 SCE Allocations | Closed via public TEA data (5/22 letter) |
| #4a Per-pupil expenditure | Closed via public TEA data (5/22 letter) |
| #4b Per-pupil expenditure (BOLT) | Closed via public TEA data (5/22 letter) |
| **#4c Statutory basis** | **OPEN — AISD did not answer; claims cost estimates suffice** |
| #5 Instructional vs non-instructional | Closed via public TEA data (5/22 letter) |
| #6 Special education | Closed via public TEA data (5/22 letter) |
| #7 Closure/Right-sizing | On AG ruling track |
| **#9a PEIMS OOD attribution** | Delivered (portal download, 134 rows) |
| **#9b Intra-district transfers** | **OPEN — AISD refuses on FERPA, offers cost estimate** |

## Proposed Reply

See: [correspondence_reply.txt](http://100.118.41.122:8080/api/pir/staging/AISD-R873/correspondence_reply.txt)

Key arguments:
1. **#9b FERPA rebuttal** — aggregated campus-level counts are not SSI; TEA publishes the same data type publicly in PEIMS. Ask for written confirmation if data truly does not exist, or accept the cost estimate.
2. **#4c statutory basis** — cost estimates do not cite the statute; demand direct answer.
3. **Closure challenge** — items cannot be closed while contested or while cost estimates remain unaccepted under 552.2615.

## Precedent Check

- Kevin previously declined cost estimates (4/23 letter).
- Kevin withdrew the OAG cost complaint (5/21) after finding public TEA data — but only on the cost items. #9b and #4c were not part of that complaint.
- The 552.2615(b)(3) deadline requires either acceptance of cost estimate, modification, or an AG overcharge complaint filed within 10 business days of the cost estimate notice.

## Open Decision for Kevin

The FERPA argument for #9b has merit to contest. If you agree with the reply as drafted, approve below. If you prefer to accept the cost estimate for #9b (to get the data faster) while still contesting #4c, I can revise the reply.

Reply **APPROVE** to send this reply, **REVISE <feedback>** to adjust, **REJECT** to cancel.
