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MITRE’s Response to the OMB RFI on Advancing Governance, Innovation, and Risk Management for Agency Use of Artificial Intelligence Draft Memorandum

MITRE’s data-driven responses to an OMB inquiry requesting input on a draft memorandum on AI governance.

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What’s the issue? The Office of Management and Budget (OMB) is seeking public comment on a draft memorandum titled Advancing Governance, Innovation, and Risk Management for Agency Use of Artificial Intelligence (AI). As proposed, the memorandum would establish new agency requirements in areas of AI governance, innovation, and risk management, and would direct agencies to adopt specific minimum risk management practices for uses of AI that impact the rights and safety of the public.

What did we do? The Center for Data-Driven Policy led a cross-MITRE analysis of OMB’s posed questions, seeking to uncover data and evidence from our work in the public interest that would help them understand opportunities and develop plans that are evidence-based, actionable, and effective.

What did we find? MITRE reviewed with interest the recent Executive Order (EO) on the Safe, Secure, and Trustworthy Development and Use of Artificial Intelligence, and OMB’s draft implementation memorandum. The federal government can serve as a catalyst to accelerate the development of tools to mitigate risks and enhance the trustworthiness and security of AI systems, and the approaches outlined in the EO will help advance that outcome considerably. Our overall recommendations include:

  • Undertake efforts to bridge the gap between Executive Office of the President policymakers and agency implementation, as well as between the federal government and industry.
  • Strike a better balance between overcoming negative aspects of AI and ensuring agencies feel encouraged to leverage AI to enhance their missions.
  • Foster a culture of collaboration and coordination between agencies, as well as with external stakeholders and subject matter experts.
  • Ensure flexibility and adaptability in AI governance.
  • Clarify governance inputs and processes, as well as differences in requirements for CFO Act Agencies and others.