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MITRE’s Response to the OMB RFI on AI Acquisition

MITRE’s data-driven responses to an Office of Management and Budget (OMB) inquiry requesting input to ensure the responsible procurement of AI by federal agencies.

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What’s the issue? Executive Order 14110, Safe, Secure, and Trustworthy Development and Use of Artificial Intelligence, directed OMB within 180 days of the issuance of the AI M-memo to develop an initial means to ensure agency contracts for the acquisition of AI systems and services align with the guidance provided in the AI M-memo and advance the other aims identified in the Advancing American AI Act (“AI Act”).

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? Based on our extensive experience with AI and federal acquisition, we believe the federal government can significantly enhance the procurement and implementation of AI systems. Our top recommendations include:

  • Adapt standard procurement practices to accommodate the unique challenges of AI acquisition. Treating AI procurement like any other could lead to unnecessary roadblocks. Instead, consider standard practices as starting points that can be modified to meet the specific requirements of AI procurement.
  • Expand the use of Other Transaction authority for AI procurements. This could attract and partner with Non-Traditional Vendors and ensure maximum competition.
  • Develop a specialized training and certification program for AI procurements. This would provide uniform, documented certifications for Acquisition Workforce Professionals, supporting their education for current and future AI procurement success.

In summary, a flexible, innovative, and data-driven approach to AI procurement, coupled with enhanced training and certification programs, can significantly improve the federal government's ability to acquire and implement effective and trustworthy AI systems.