On October 3, 2024, the Office of Management and Budget (OMB) issued Memorandum M-24-18, titled “Advancing the Responsible Acquisition of Artificial Intelligence in Government,” in direct response to President Biden’s Executive Order 14110, “Safe, Secure, and Trustworthy Development and Use of Artificial Intelligence,” enacted on October 30, 2023. This directive builds upon the foundations laid by previous legislation such as the Advancing American AI Act, signed on December 23, 2022, and OMB Memorandum M-24-10, creating a cohesive framework for federal AI deployment that emphasizes safety, security, innovation, and equity.
The memorandum outlines clear guidelines aimed at enhancing the AI acquisition processes across federal agencies. It ensures that these technologies are implemented to safeguard civil liberties, foster public sector innovation, and enhance economic competitiveness. By focusing on key areas, M-24-18 seeks to equip federal agencies with tools to procure and utilize AI responsibly. Additionally, it aligns with federal standards and strategic goals to ensure effective and responsible AI implementation. Let’s explore the implications of these guidelines for the future of AI integration within federal agencies.
Understanding OMB’s M-24-18 Guidance
OMB Memorandum M-24-18 builds on President Biden’s Executive Order 14110. It integrates its core principles—safety, security, and trustworthiness—into directives for federal agencies. The memorandum mandates specific actions, such as enhanced risk assessment protocols and clear governance structures, for responsible AI acquisition and development. Moreover, these actions ensure alignment with ethical standards and public accountability in AI deployment:
- Managing AI Risks and Performance: There are specific requirements for continuous monitoring and evaluation of AI systems used within federal agencies. Furthermore, these requirements emphasize adapting risk management strategies over time. As AI technologies evolve, so too do the measures to safeguard against potential ethical and security risks.
- Promoting a Competitive AI Market: To reduce dependency on single vendors and foster a healthy competitive environment, M-24-18 encourages agencies to engage with a broader range of technology providers. This is facilitated through the adoption of open standards and interoperability requirements. Additionally, these standards are designed to level the playing field and stimulate innovation across the AI technology sector.
- Ensuring Federal Collaboration: The memorandum explicitly calls for the creation of interagency task forces and the appointment of Chief AI Officers to oversee AI strategy and implementation. Such collaboration ensures that AI initiatives are not developed in isolation. Moreover, they are synchronized across government entities to maximize efficiency and impact.
Responsible AI Acquisition for Federal Agencies
1. Strengthening Risk Management and AI Performance
A 2023 Government Accountability Office (GAO) report indicates that out of 23 federal agencies, 10 have fully implemented all AI-specific requirements, twelve have partially implemented these requirements, and one was exempt. This disparity highlights the need for robust AI risk management strategies across federal agencies to ensure responsible AI deployment. Additionally, these requirements are essential for maintaining an inventory of AI use, updating inventory, and establishing regulatory authorities for AI.
To meet the requirements, federal agencies must engage privacy officials at the outset of AI projects. Furthermore, this ensures compliance with privacy laws and mitigates risks of bias and discrimination. Integrating privacy safeguards during the design phase is essential for aligning AI systems with federal standards.
Additionally, detailed rights and safety impact assessments are critical for evaluating AI systems’ potential effects on civil liberties and public safety. Federal agencies must establish frameworks for continuous risk evaluation, adapting these strategies as technologies evolve. Implementing these proactive measures ensures that agencies can effectively mitigate risks while maintaining public trust in AI-enabled government services.
According to the previous OMB policy, agencies are also mandated to implement thorough measures to assess, test, and monitor the impacts of AI on the public. These measures aim to reduce the risks of algorithmic discrimination and enhance the transparency of AI use within the government. Moreover, this is vital for maintaining public trust and ensuring that AI technologies are used responsibly and equitably.
The same policy mentions that federal employee unions can provide consultation to federal agencies on AI deployment principles. In addition, these consultations focus on mitigating potential harm to employees resulting from the implementation of AI technologies. These steps help ensure the federal workforce is protected and AI implementations are carried out with consideration for the well-being of all stakeholders involved.
2. Enhancing the AI Marketplace Through Innovative Strategies
The adoption of innovative procurement practices can address the underutilization of AI technologies in federal operations. Outcomes-based AI acquisition techniques provide a strategic shift by focusing on measurable results rather than prescriptive methods. This flexibility allows vendors to propose creative solutions. As a result, it optimizes efficiency and encourages innovation in government projects.
To further strengthen the AI marketplace, minimizing vendor lock-in is a key priority. Agencies should prioritize the adoption of open standards and modular architectures to ensure interoperability and facilitate the integration of new technologies. By diversifying their vendor base and fostering competition, federal agencies can ensure cost-effectiveness and reduce risks associated with single-vendor dependencies.
3. Fostering Federal Collaboration and Oversight
Effective collaboration and oversight are essential for maximizing the benefits of AI in government operations. The appointment of Chief AI Officers (CAIOs) across federal agencies represents a critical step toward standardized AI governance. The responsibilities of CAIOs include overseeing AI strategies, ensuring alignment with federal objectives, and fostering interagency cooperation. With centralized leadership, agencies enable consistent implementation of AI policies and facilitate resource sharing. Following Executive Order 14110, some agencies proactively worked on appointing CAIOs, including the Department of Defense, Department of Health and Human Services, and Department of Homeland Security, recognizing the importance of strategic AI governance.
Moreover, human oversight remains integral to the responsible deployment of AI systems. Regular human evaluations ensure that AI-driven decisions are ethical, accountable, and responsive to public needs. Cross-functional teams comprising privacy experts, procurement officers, and technical specialists should be formed to enhance collaboration. Sharing lessons learned and best practices across agencies promotes a unified and efficient approach to AI acquisition.
4. Optimizing Compliance and Procurement Processes
Setting rigorous standards for vendors and contractors is critical to maintaining the integrity of AI projects. Agencies should establish clear criteria for vendor selection, emphasizing transparency, ethical practices, and adherence to federal guidelines. This ensures that all partners contribute to the success of public sector AI initiatives while upholding public trust.
The need for robust compliance systems becomes more apparent considering the dramatic increase in contracting actions. According to Deloitte, while government spending on contracts rose by an average of 4.5% annually over the past decade, the number of contracting actions increased by over 22% each year. By fiscal year 2022, each federal contracting officer was responsible for managing approximately 2,000 contracting actions. This marked a significant rise from just 300 in 2013, highlighting the growing workload for contracting officers. This increase underscores the challenges in managing workload and maintaining compliance without compromising the quality of oversight.
Routine monitoring and periodic reviews of AI projects are necessary to sustain operational effectiveness and compliance. These evaluations enable agencies to identify areas for improvement and adapt to regulatory changes or technological advancements. By embedding continuous improvement practices, agencies can ensure that AI systems remain secure, reliable, and aligned with federal objectives.
Aligning TechSur Solutions’ AI Offerings with OMB’s Guidelines
TechSur Solutions’ AI capabilities, featuring a GenAI platform called OnyxAI and specific offerings including AcquireAI, are strategically designed to align with the OMB guidelines for responsible and innovative AI utilization within federal agencies. These platforms ensure that agencies can meet compliance demands while enhancing operational efficiency and innovation in AI applications.
OnyxAI provides a generative AI environment that simplifies data management and decision-making processes. It leverages advanced algorithms for Retrieval-Augmented Generation (RAG), ensuring data is quickly accessible, contextually relevant, secure, and compliant with federal data standards. This platform integrates smoothly with existing digital tools such as Microsoft Teams and Slack, facilitating ease of use and enhancing user engagement with AI capabilities.
AcquireAI is designed specifically to streamline and improve the federal acquisition process. By incorporating AI, machine learning, and robotic process automation (RPA), AcquireAI automates routine procurement tasks, enforces compliance with regulatory standards, and optimizes operational workflows. This system’s real-time analytics and user-friendly interface significantly reduce errors. Moreover, it improves the efficiency of procurement operations, aligning with OMB’s directives for innovative procurement practices.
Together, these platforms support federal agencies in adopting AI solutions that are not only compliant with current regulations but also poised to adapt to evolving technological landscapes.
Conclusion
The guidelines set forth by OMB Memorandum M-24-18 represent a critical step towards optimizing AI acquisition and implementation across federal agencies. These standards emphasize ethical practices, transparency, and a strategic approach to AI deployment, fostering public sector accountability and innovation. Hence, federal agencies are urged to adopt these standards to enhance AI capabilities, ensuring technologies support public trust and operational excellence.
For agencies looking to meet these robust guidelines, TechSur offers specialized AI solutions and expertise to facilitate compliance and advance operational effectiveness.