A National Guidance Platform for AI Acquisition
Streamlining the procurement process for more equitable, safe, and innovative government use of AI
The federal government’s approach to procuring AI systems serves two critical purposes: it not only shapes industry and academic standards but also determines how effectively AI can enhance public services. By leveraging its substantial purchasing power responsibly, the government can encourage high-quality, inclusive AI solutions that address diverse citizen needs while setting a strong precedent for innovation and accountability. Guidance issued in October 2024 by the White House’s Office of Management and Budget (OMB) gives recommendations on how agencies should use AI systems, focusing on public trust and data transparency. However, it is unclear how these guidelines align with general procurement regulations like the Federal Acquisition Regulation (FAR).
To reduce bureaucratic hurdles and encourage safe government innovation, the General Services Administration (GSA) should develop a digital platform that guides federal agencies through an “acquisition journey” for AI procurement. This recommendation is for streamlining guidance for procuring AI systems and should not be confused with the use of AI to simplify the procurement process. The platform should be intuitive and easy to navigate by clearly outlining the necessary information, requirements, and resources at each process stage, helping users understand what they need at any point in the procurement lifecycle. Such a platform would help agencies safely procure and implement AI technologies while staying informed on the latest guidelines and adhering to existing federal procurement rules. GSA should take inspiration from Brazil’s well-regarded Public Procurement Platform for Innovation (CPIN). CPIN helps public servants navigate the procurement process by offering best practices, risk assessments, and contract guidance, ensuring transparency and fairness at each stage of the procurement process.
Challenges and Opportunities
The federal government’s approach to AI systems is a crucial societal benchmark, shaping standards that ripple through industries, academia, and public discourse. Along with shaping the market, the government also faces a delicate balancing act when it comes to its own use of AI: it must harness AI’s potential to dramatically enhance efficiency and effectiveness in public service delivery while simultaneously adhering to the highest AI safety and equity standards. As such, the government’s handling of AI technologies carries immense responsibility and opportunity.
The U.S. federal government procures AI for numerous different tasks—from analyzing weather hazards and expediting benefits claims to processing veteran feedback. Positive impacts could potentially include faster and more accurate public services, cost savings, better resource allocation, improved decision-making based on data insights, and enhanced safety and security for citizens. However, risks can include privacy breaches, algorithmic bias leading to unfair treatment of certain groups, over-reliance on AI for critical decisions, lack of transparency in AI-driven processes, and cybersecurity vulnerabilities. These issues could erode public trust, inhibit the adoption of beneficial AI, and exacerbate existing social inequalities.
The federal government has recently published several guidelines on the acquisition and use of AI systems within the federal government, specifically how to identify and mitigate systems that may impact public trust in these systems. For example:
- OMB Memo M-24-10 (2024): Guides federal agencies on the use of artificial intelligence. It emphasizes responsible AI development and deployment, focusing on key principles such as safety, security, fairness, and transparency. The memo outlines requirements for AI governance, risk management, and public transparency in federal AI applications.
- OMB Memo M-24-18 (2024): Provides Guidance on AI acquisitions, such as transparency, continued guidance for incident reporting on rights and safety impacting AI, data management, and specific advice for AI-based biometrics.
- Agency Memos (2024): Per M-24-10, many U.S. agencies have published their internal strategies for AI use.
- AI Use Case Inventory (2024): Requires agencies to perform an annual inventory of AI systems with information on Procurement Instrument Identifiers and potential for rights or safety impacts.
- Executive Order on the Safe, Secure, and Trustworthy Development and Use of Artificial Intelligence (2023) This requires agencies to adopt trustworthy and responsible AI practices. It mandates using AI safety standards, including rigorous testing, auditing, and privacy protections across federal systems.
- Executive Order 13960 (2020) promotes the use of trustworthy artificial intelligence in government and outlines the responsibilities of agencies to ensure their AI use is ethical, transparent, and accountable. It includes the need for agencies to consider risks, fairness, and bias in AI systems.
This guidance, coupled with the already extensive set of general procurement regulations such as the Federal Acquisition Regulation (FAR ), can be overwhelming for public servants. In conversations with the author of this memo, stakeholders, including agency personnel and vendors, frequently noted that they needed clarification about when impact and risk assessments should occur in the FAR process.
How can government agencies adequately follow their mandate to provide safe and trustworthy AI for public services while reducing the bureaucratic burden that can result in an aversion to government innovation? A compelling example comes from Brazil. The Public Procurement Platform for Innovation (CPIN), managed by the Brazilian Ministry of Development, Industry, Commerce, and Services (MDIC), is an open resource designed to share knowledge and best practices on public procurement for innovation. In 2023, the platform was recognized by the Federal Court of Auditors (TCU—the agency that oversees federal procurement) as an essential new asset in facilitating public service. The CPIN helps public servants navigate the procurement process by diagnosing needs and selecting suitable contracting methods through questionnaires. Then, it orients agencies through a procurement journey, identifying what procurement process should be used, what kinds of dialogue the agency should have with potential vendors and other stakeholders, guidance for risk assessments, and contract language. The platform is meant to guide public servants through each stage of the procurement process, ensuring they know their obligations for transparency, fairness, and risk mitigation at any given time. CPIN is open to the public and is meant to be a resource, not new requirements that supplant existing mandates by Brazilian authorities.
Here in the U.S., the Office of Federal Procurement (OFFP) within the Office of Management and Budget (OMB) in partnership with the General Services Administration (GSA) and the Council of Chief AI Officers (CAIO), should develop a similar centralized resource to help federal agencies procure AI technologies safely and effectively. This platform would ensure agencies have up-to-date guidelines on AI acquisition integrated with existing procurement frameworks.
This approach is beneficial because:
- Public-facing access reduces information gaps between government entities, vendors, and stakeholders, fostering transparency and leveling the playing field for mid- and small-sized vendors.
- Streamlined processes alleviate complexity, making it easier for agencies to procure AI technologies.
- Clear guidance for agencies throughout each step of the procurement process ensures that they complete essential tasks such as impact evaluations and risk assessments within the appropriate time frame.
GSA has created similar tools before. For example, the Generative AI Acquisition Resource Guide assists federal buyers in procuring and implementing generative AI technologies by describing key considerations, best practices, and potential challenges associated with acquiring generative AI solutions. However, this digital platform would go one step further and align best practices, recommendations, and other AI considerations within the processes outlined in the FAR and other procurement methods.
Plan of Action
Recommendation 1. Establish a Working Group led by the OMB OFPP, with participation from GSA, OSTP, and the CAIO Council, tasked with systematically mapping all processes and policies influencing public sector AI procurement.
This includes direct AI-related guidance and tangential policies such as IT, data management, and cybersecurity regulations. The primary objective is identifying and addressing existing AI procurement guidance gaps, ensuring that the forthcoming platform can provide clear, actionable information to federal agencies. To achieve this, the working group should:
Conduct a thorough review of current mandates (see the FAQ for a non-exhaustive list of current mandates), executive orders, OMB guidance, and federal guidelines that pertain to AI procurement. This includes mapping out the requirements and obligations agencies must meet during acquisition. Evaluate if these mandates come with explicit deadlines or milestones that need to be integrated into the procurement timeline (e.g., AI risk assessments, ethics reviews, security checks)
Conduct a gap analysis to identify areas where existing AI procurement guidance needs to be clarified, completed, or updated. Prioritize gaps that can be addressed by clarifying existing rules or providing additional resources like best practices rather than creating new mandates to avoid unnecessary regulatory burdens. For example, guidance on handling personally identifiable information within commercially available information, guidance on data ownership between government and vendors, and the level of detail required for risk assessments.
Categorize federal guidance into two main buckets: general federal procurement guidance (e.g., Federal Acquisition Regulation [FAR]) and agency-specific guidelines (e.g., individual AI policies from agencies such as DoD’s AI Memos or NASA’s Other Transaction Authorities [OTAs]). Ensure that agency-specific rules are clearly distinguished on the platform, allowing agencies to understand when general AI acquisition rules apply and when specialized guidance takes precedence. Since the FAR may take years to update to reflect agency best practices, this could help give visibility to potential gaps.
Recommendation 2. The OMB OFPP-GSA-CAIO Council Working Group should convene a series of structured engagements with government and external stakeholders to co-create non-binding, practical guidance addressing gaps in AI procurement to be included in the platform.
These stakeholders should include government agency departments (e.g., project leads, procurement officers, IT departments) and external partners (vendors, academics, civil society organizations). The working group’s recommendations should focus on providing agencies with the tools, content, and resources they need to navigate AI procurement efficiently. Key focus areas would include risk management, ethical considerations, and compliance with cybersecurity policies throughout the procurement process. The guidance should also highlight areas where more frequent updates will be required, particularly in response to rapid developments in AI technologies and federal policies.
Topics that these stakeholder convenings could cover include:
Procurement Process
- Acquisition Pathways: What acquisition methods (e.g., FAR, Other Transaction Authorities [OTA], and joint acquisition programs) can be leveraged for procuring AI? Identify the most appropriate mechanisms for different AI use cases. For example, agencies looking to develop an advanced AI system with the help of external researchers may want to consider OTA if that is available to them.
- Integrating New Guidance: How can recent AI-related guidance from OMB memos (like M-24-10 and M-24-18) be incorporated into existing procurement frameworks, especially within the FAR?
- Stakeholder Responsibilities: Clearly define the roles and obligations of each party in the AI procurement process, from agency departments (such as project teams, procurement offices, and IT) to vendors and contractors. Determine who manages AI-related risks, evaluates AI systems, and ensures compliance with relevant policies.
- NIST AI Risk Management Framework (RMF): Explore how the NIST AI RMF can be integrated into the acquisition process and ensure agencies are equipped to assess AI risks effectively within procurement.
Transparency
- Public Disclosure: Define what information must be shared with the public at various stages of the AI acquisition process. Ensure there is a balance between transparency and protecting sensitive information.
- Data Sharing and Protection: Identify resources to help agencies understand their obligations regarding data sharing and protection under OMB Memo M-24-18 or forthcoming memos from the new administration to ensure compliance with any data security and privacy requirements.
- Risk Communication: Establish when and how to communicate to relevant stakeholders (e.g., the public and civil society) that a potential AI acquisition could impact public trust in AI technologies. Outline the types of transparency that should accompany AI systems that carry such risks.
Resources:
- External Best Practices: Gather and share civil society toolkits, industry best practices, and academic evaluations that can help agencies ensure the trustworthy use of AI. This would provide agencies with access to external expertise to complement federal guidelines and standards. The stakeholder convening should deliberate on whether these best practices will just be linked to the platform or if they need some kind of endorsement from government agencies.
Recommendation 3. The OPPF, in collaboration with GSA and the United States Digital Service (USDS) should then develop an intuitive, easy-to-navigate digital platform that guides federal agencies through an “acquisition journey” for AI procurement.
While the focus of this memo is on the broader procurement of AI systems, this digital platform could also benefit from the incorporation of AI, for example, by using a chatbot that is able to refer government users to the specific regulations governing their use cases. At each process stage, the platform should clearly outline the necessary information collected during the previous phases of this project to help users understand exactly what is needed at any given point in the procurement lifecycle.
The platform should serve as a central repository that unites all relevant AI procurement requirements, guidance from federal regulations (e.g., FAR, OMB memos), and insights from stakeholder convenings (e.g., vendors, academics, civil society). Each procurement stage should feature the most up-to-date guidance, ensuring a comprehensive and organized resource for federal employees.
The system should be designed for ease of navigation, potentially modeled after Brazil’s CPIN, which is organized like a city subway map. Users can begin with a simple questionnaire recommending a specific “subway line” or procurement process. Each “stop” along the line would represent a key stage in the procurement journey, offering relevant guidance, requirements, and best practices for that phase.
OPPF and GSA must regularly update the platform to reflect the latest federal AI and procurement policies and evolving best practices from government, civil society, and industry sources. Regular updates ensure that agencies use the most current information, especially as AI technologies and policies evolve rapidly.
The Federal Acquisition Institute within OFPP should create robust training programs to familiarize public servants with the new platform and how to use it effectively. These programs should explain how the platform supports AI acquisition and links to broader agency AI strategies.
- Roll out the platform gradually through agency-specific capacity-building sessions, demonstrating its utility for different departments. These sessions should show how the resource can help public servants meet their AI procurement needs and align with their agency’s strategic AI goals.
- Develop specialized training modules for different government stakeholders. For example, project teams might focus on aligning AI systems with mission objectives, procurement specialists on contract compliance, and IT departments on technical evaluations and cybersecurity.
- To ensure broad understanding and transparency, host public briefings for external stakeholders such as vendors, civil society organizations, and researchers. These sessions would clarify AI procurement requirements, fostering trust and collaboration between the public and private sectors.
Conclusion
The proposed centralized platform would represent a significant step forward in streamlining and standardizing the acquisition of AI technologies across federal agencies. By consolidating guidance, resources, and best practices into a user-friendly digital interface, this initiative would address gaps in the current AI acquisition landscape without increasing bureaucracy. This initiative supports individual agencies in their AI adoption efforts. It promotes a cohesive, government-wide approach to responsible AI implementation, ultimately benefiting both public servants and the citizens they serve.
This action-ready policy memo is part of Day One 2025 — our effort to bring forward bold policy ideas, grounded in science and evidence, that can tackle the country’s biggest challenges and bring us closer to the prosperous, equitable and safe future that we all hope for whoever takes office in 2025 and beyond.
There are so many considerations based on a particular agency’s many needs. A non-exhaustive list of legislation, executive orders, standards and other guidance relating to innovation procurement and agency use of AI can be found here. One approach to top-level simplification and communication is to create something similar to Brazil’s city subway map, discussed above.
The original Brazilian CPIN is designed for general innovation procurement and is agnostic to specific technologies or services. However, this memo focuses on artificial intelligence (AI) in light of recent guidance from the Office of Management and Budget (OMB) and the growing interest in AI from both the Biden Administration and the incoming Trump Administration. Establishing a platform specifically for AI system procurement could serve as a pilot for developing a broader innovation procurement platform.
The platform seeks to ensure responsible public sector AI by mitigating information asymmetries between government agencies and vendors, specifically by:
- Incorporating the latest OMB guidelines on AI system usage, focusing on human rights, safety, and data transparency. These guidelines are seamlessly integrated into each step of the procurement process.
- Throughout the “acquisition journey,” the platform should include clarifying checkpoints where agencies can demonstrate how their procurement plans align with established safety, equity, and ethical standards.
- Prompting agencies to consider how procured AI systems will address context-specific risks by integrating agency-specific guidance (e.g., the Department of Labor’s AI Principles) into the existing AI procurement frameworks.
To encourage greater adoption of generic drugs in clinical practice the FDA should implement a dedicated regulatory pathway for non-manufacturers to seek approval of new indications for repurposed generic drugs.
By leveraging its substantial purchasing power responsibly, the government can encourage high-quality, inclusive AI solutions that address diverse citizen needs while setting a strong precedent for innovation and accountability.
The federal government should expand the FDA’s priority review voucher program and provide market exclusivity advantages to encourage the development of medications for addiction.
Declining U.S. manufacturing has sharply curtailed a key path to the middle class for those with high school educations or less, thereby exacerbating income inequality nationwide. The United States can address many of these problems through concerted efforts in advanced manufacturing.