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.
PLEASE NOTE (February 2025): Since publication several government websites have been taken offline. We apologize for any broken links to once accessible public data.
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.
Adapting the Nation to Future Temperatures through Heat-Resilient Procurement
Extreme chronic and acute heat exposes millions of American lives to dangerous health risks and threatens our infrastructure. Yet there are many physical solutions available to mitigate the risk of heat to people and systems in our built environments. Despite clear evidence that heat exposure is a substantial challenge to human health, economic vitality, and the goals of the Justice40 initiative, very little has been done to galvanize viable markets for materials and technologies that can improve heat resilience.
In order to spur demand and send a strong signal for beneficial private sector innovation and scale, the federal government can lead by example to drive the market for products and services that build heat resilience. The General Services Administration (GSA) should require new and existing public structures (e.g. buildings and parking lots), products, supplies, and service procurement to meet minimum requirements for heat adaptation. These requirements could be adapted from existing green codes (e.g., ASHRAE 189.1 and IEA’s Annex 80) that recognize some of the non-energy benefits of heat-resilient materials and products, recognized supply chain vulnerabilities due to extreme heat (e.g. specialty crops, commodity crops, livestock, pharmaceutical precursors, etc.), and best practices for workplace protections (e.g. Fair Food Program).
Challenge and Opportunity
The federal government’s market-making potential is substantial – purchasing more than $630 billion in goods and services in FY2021 alone. The GSA owns and leases over 363 million square feet of space in 8,397 buildings in more than 2,200 communities nationwide. Updating procurement requirements and solicitations to promote passive cooling and heat resilience is relatively straightforward since GSA already maintains a database for green and sustainable building materials, systems, and services that could be amended, rather than creating a new parallel standard. Further, procurement standard changes are within the purview of a relatively small number of policy actors, compared to policies that incentivize voluntary uptake or require broad enforcement to be effective.
Even small increases in market demand, driven by policy, can significantly reduce first costs, product availability, and innovation. For example, requirements for solar reflective shingles on residential homes in Los Angeles City and County (a market of roughly 10 million people) reduced costs for high-end shingle products by two-thirds and saw the introduction of mid- and low-cost product lines throughout the country. Similarly, joint innovation around a commitment to incorporating cool pavements into Los Angeles and Phoenix road maintenance and preservation programs has driven global product innovation, improved durability and aesthetics, and more efficient application processes that benefit communities nationwide. GSA action on procurement would send a much stronger market signal to many more communities.
Heat-resilient procurement will also benefit rapidly developing federal policy to promote reduced heat risk. In January 2024, the Federal Emergency Management Agency announced that it would fund investments in net-zero energy reconstruction in areas under a federal disaster declaration. The provisions, which explicitly highlight investments in passive cooling, apply to Public Assistance, the agency’s largest grant program; the Hazard Mitigation Grant Program; and the Building Resilient Infrastructure and Communities grant program. Heat-resilient interventions can be a net benefit to net-zero priorities, keeping buildings cooler as temperatures rise without driving up energy consumption. Further, heat-resilience procurement standards aligns with the Office of Management and Budget’s climate-smart infrastructure investments memorandum (M-24-03), which calls for incorporation of current and future climate change risk in infrastructure investments and maximizing sustainability over the system’s service life.
The regulatory groundwork and technical language required for these recommendations are already in place. Several state and model codes already have requirements that could easily be adopted or referenced by a procurement standard. For example, California’s Title 24 includes requirements for cool roofs, green roofs, and other heat-adaptive interventions for a variety of climate zones. Similarly, ASHRAE Standard 189.1, the International Energy Conservation Code, ASHRAE Standard 90.1, and the LEED voluntary program include prescriptive urban heat island mitigation or passive cooling requirements for U.S. climate zones.
In November 2022, the Biden-Harris Administration proposed the Federal Supplier Climate Risks and Resilience Rule, which would require federal contractors receiving more than $7.5 million in annual contracts to publicly disclose their greenhouse gas emissions and climate-related financial risks and set science-based emissions reduction targets. Requiring heat resilience would further push markets toward adaptation.
Executive Order 14057 on catalyzing American clean energy industries and jobs through federal sustainability and the accompanying Federal Sustainability Plan would, in part, create a mandate and mechanism to update federal policies for sustainability, climate action, and resilience. The order includes “buy clean” provisions for low-carbon materials, with a goal of net-zero procurement by 2050, and a Net-Zero Emissions Procurement Federal Working Group and Buy Clean Task Force that is required to report semiannually on progress toward clean procurement. As heat-resilience interventions like cool surfaces can drive down energy consumption, they are aligned with net-zero priorities.
Plan of Action
A number of existing policy pathways and fora could be leveraged to develop, standardize, and include heat-resilience standards in procurement. To start, the GSA could amend its Facilities Standards for the Public Building Service (P100) for public facilities and infrastructure projects to incorporate heat resilience by adopting ASHRAE 189.1 and resilient cooling practices articulated in the International Energy Agency’s Annex 80. Supportive engagement with the Net-Zero Emissions Procurement Federal Working Group would leverage internal reporting requirements to advance heat adaptation. Further, the Environmental Protection Agency (EPA) could incorporate ASHRAE 189.1 performance requirements for highly solar-reflective and vegetated materials into Energy Star, allowing those products to be included in Green Procurement Compilation.
To ensure heat-resilient supplies and services, the Federal Acquisition Register (FAR) could be updated to include disclosures on how those products and services improve or reduce resilience to heat. Relevant disclosures include, but are not limited to, extreme heat’s risk to: service provision, such as unsafe working conditions; 2) supply chains and key commodity provisions; and 3) infrastructure operations, such as adequate cooling of data center facilities. The FAR already recognizes the risk of climate change in its proposed implementation of section 5(b)(i) of Executive Order 14030, Climate-Related Financial Risk, to require major federal suppliers to publicly disclose greenhouse gas emissions and climate-related financial risk and to set science-based reduction targets. GSA could also increase the use of life-cycle cost assessments over the lowest first-cost procurement to recognize the broader economic and societal benefits gained from investments in sustainable and resilient products and services.
Interagency efforts, stewarded by the Interagency Working Group on Extreme Heat, could accelerate standards for heat-resilient building codes as well as product and services procurement. For example, the National Institute of Standards and Technology (NIST) works on other climate-related building standards through the National Windstorm Impact Reduction Program (NWIRP) and the National Construction Safety Team (NCST) Act, which authorizes NIST to investigate extreme weather events on buildings and inform the improvement of codes for the built environment. Further, the U.S. Department of Housing and Urban Development (HUD) establishes construction and safety standards, and the Department of Energy (DOE) proposes energy-efficiency standards for manufactured homes, which account for approximately 10% of single-family houses constructed in the U.S. annually and could include heat-resilient technologies. The U.S. Department of Agriculture’s federal public food procurement system (including the National School Lunch Program, Emergency Food Assistance Program, and Commodity Supplemental Food Program) could take better stock of extreme heat’s risks to the federal government’s ability to affordably procure essential food products. Finally, in alignment with the Occupational Health and Safety Administration’s National Emphasis Program on Extreme Heat, agencies that contract with high-risk industries (e.g. agriculture, construction, manufacturing, firefighters, etc.) should ask for the latest data on workplace injuries and deaths during heat season (April to October) before awarding contracts and rate contractors on heat safety upon contract completion.
Federally supported construction standards and procurement requirements can also be applied at any level of government: national, state, tribal, local, or even school districts and incentivized through federal financing of these subnational efforts.
Non-Federal Stakeholders
This effort would greatly benefit from robust engagement with organizations outside of the public sector. National laboratories such as Lawrence Berkeley National Lab, Oak Ridge National Lab, National Renewable Energy Lab, and Pacific Northwest National Lab have deep technical experience to identify heat-resilient technologies. Organizations such as the Cool Roof Rating Council (which rates roofing and wall material surface properties) and the National Fenestration Rating Council are entry points to technical support from its industry members. Code experts such as the New Buildings Institute and Regulatory Assistance Project could identify and modify existing code language to match the needs of federal procurement. The American Public Health Association, Smart Surfaces Coalition, Institute for Policy Integrity, and others can support a broader social cost benefit to determine what performance levels to require in procurement standards.
This idea of merit originated from our Extreme Heat Ideas Challenge. Scientific and technical experts across disciplines worked with FAS to develop potential solutions in various realms: infrastructure and the built environment, workforce safety and development, public health, food security and resilience, emergency planning and response, and data indices. Review ideas to combat extreme heat here.
Cool surfaces are not a monolithic product category. They encompass a huge variety of roofing, wall, and building attachment products spanning commercial, residential, multi-family, institutional, and industrial use cases. In nearly all of those contexts, there is an available, economically viable first-cost option that would promote heat resilience rather than exacerbate heat exposure.
Heat-resilient or passive-cooling procurement standards may generate net positive impacts on the budget. Looking at life-cycle costs and benefits, studies have found that $1 invested in passive cooling measures returns between $1.50 and $15.20.
Beyond the federal budget, mandatory heat-resilience policies also yield substantial social and market benefits. When procurement and codes require heat resilience at a municipal level (as they have in Los Angeles, for example), the budget impact has been negligible but has resulted in dramatically lower first costs for heat-resilient options like advanced cool roof shingles. Similarly, adding questions about heat resilience to the required responses for service procurement is not an undue or onerous burden on potential federal contractors. Heat costs American workers and businesses over $100 billion per year in lost productivity and wages. Investments in the built environment may substantially reduce that existing burden, yielding more equitable outcomes in line with Justice40 (the wage impact is felt most acutely by outdoor, agricultural, and warehouse workers) and potentially more tax revenue.