Last month, the Office of Management and Budget (“OMB”) issued a memorandum directing federal agencies to deploy and advance the use of artificial intelligence (“AI”) to inform and implement agency actions. did. OMB's new policy addresses three key areas that it believes are necessary to responsibly introduce AI into agency decision-making. (1) Strengthening AI governance. (2) Promote AI innovation. (3) Managing risk through the use of AI. As OMB encourages the use of AI to streamline agency activities as much as possible, government contractors can also expect to see increased use of AI in their procurement processes.
AI governance
OMB directed agencies to appoint chief AI officers. Its responsibilities include coordinating the agency's use of AI, developing talent with the skill sets needed to implement AI, and “encouraging appropriate uses of AI that advance both the agency's mission and equitable outcomes.” This includes identifying and prioritizing. ”
The Chief AI Officer is also tasked with ensuring that AI code and data used to develop and test AI is stored in a data repository and shared. The individual must also create and annually submit to OMB an “AI Use Case Inventory” that documents instances in which AI is used by him to address specific needs. For example, the Department of State's (“DOS”) AI Inventory includes bots developed to “automate data entry into the Federal Acquisition Data System,” thereby reducing the burden on the Department's procurement staff. , the State Department reports that compliance has improved. About DATA Act reporting.
AI innovation
OMB believes that AI has the potential to improve efficiency across the federal government by improving access to government services, addressing the climate crisis, protecting democracy, improving public health, and economic competition. We envision using AI to augment our powers.
To this end, OMB has directed agencies to remove barriers to the responsible use of AI with the goal of achieving “AI maturity.” Each agency must propose a development plan for the IT infrastructure needed to build, test, and maintain AI applications. Government agencies must also develop the infrastructure needed to share and manage internal and external data used to train and operate AI. OMB also directed agencies to evaluate the potential beneficial uses of generative AI for their missions.
OMB views AI as a tool that must be open, shared, and reused. Agencies must “actively share custom-developed” AI code for “actively used AI applications” and maintain that code in public repositories as open source software. . Government agencies will also be required to publicly share data used to develop and test AI.
Managing risk
OMB acknowledges the risks associated with AI and calls it “safety-impacting” (for exampleimpacts on human life, the climate, critical infrastructure, etc.) or “impacts on rights” (for example, civil rights, equal opportunity, access to critical government resources/services, etc.). OMB has established minimum risk management practices that agencies must follow before using AI. This includes completing an AI impact assessment that documents the intended purpose of the AI. Expected benefits (for example, cost reduction); potential risks of using AI, including implications for fairness and equity; Assessing the quality of data used in AI development and testing. Government agencies must also test AI to ensure it works in “intended real-world situations,” and to ensure that the benefits outweigh the risks (by oversight committees or other government agencies). (through) an independent evaluation of the AI.
When it comes to federal AI procurement, OMB has directed agencies to promote competition and interoperability to avoid inappropriate lock-in of incumbents. Similarly, OBM directed government agencies to ensure sufficient government data rights to avoid vendor lock-in and allow the government to continue designing, developing, testing, and operating AI. OMB also filed a request for information seeking information about federal AI procurements, including proposed contract terms to address data rights issues.
Use of AI in government contracts
OMB directs agencies to remove barriers to the use of AI to improve service and operational efficiencies, making government contractors more likely to implement AI in acquisition and contract management. It is expected that this number will increase. Some agencies have already begun to do so. for example:
- The General Services Administration (“GSA”) developed CALI, an automated machine learning tool that evaluates vendor proposals against solicitation requirements, to support the supplier selection process. GSA's AI Inventory explains that CALI analyzes proposals in her four “key” areas: “Format Compliance, Form Validation, Personnel and Certificate Compliance, and Requirements Compliance.”
- DOS uses a bot developed to automate expiry reminders for federal grants that are nearing the end of their implementation period.
- In fiscal year 2023, the Department of Homeland Security (“DHS”) conducted a pilot program to evaluate an AI market research tool to identify potential contractors who can perform requirements. Without AI tools, DHS's acquisition staff spent more than 10 hours working to identify vendors who could execute the requirements, according to the DHS report. Using AI tools, that time has been reduced to 2.5 hours for him.
- Several other AI tools are used to detect fraud, such as a fraud prevention system model that captures Medicare administrative and claims data to identify potential cases for future investigation by the Centers for Medicare and Medicaid Services. The purpose is DOS is also developing a “Supply Chain Fraud and Risk Model” to identify anomalous activity within integrated logistics management systems that may indicate potential fraud or fraud.
Contractors may be able to use AI to their benefit, for example, to verify compliance with regulatory requirements, determine which contracts are eligible to bid, and assist in proposal writing. Simplifying the contracting process and reducing associated costs could encourage more companies, especially small and medium-sized enterprises, to actively bid for contracts, fostering competition and innovation.
