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CDT Comments on OMB Draft Guidance for Agency Use of AI

Comments also authored by Dan Bateyko, CDT consultant and former Fellow

The Center for Democracy & Technology (CDT) respectfully submits these comments in response to the Office of Management and Budget (OMB) Request for Comments regarding the draft memorandum for agency use of Artificial Intelligence (hereinafter “draft Memo”). CDT is a nonprofit 501(c)(3) organization that works to advance civil rights and civil liberties in the digital age. Among our priorities, CDT advocates for the responsible and equitable use of technology by government agencies, and promotes the adoption of robust, technically-informed solutions for the effective regulation and governance of AI systems.

We commend OMB for its leadership in setting AI accountability policy. The draft Memo shows a continued commitment to advancing equity, civil rights, and innovation, and recognizes the importance of providing implementing guidance to ensure that commitment is carried out effectively and consistently across the federal government. CDT welcomes OMB’s incorporation of key elements from the Administration’s Blueprint for an AI Bill of Rights in the draft Memo’s required minimum practices, such as requiring AI impact assessments, human consideration and accountability, and notice and plain language documentation, as well as heightened requirements for uses impacting people’s rights such as disparate impact assessments, opt-outs, and consultation with affected groups. These requirements are essential to effectuating the Administration’s guiding principles for AI as set forth in the Executive Order on Safe, Secure & Trustworthy Development and Use of Artificial Intelligence.

Despite the strength of the Memo’s guidance, there are several places where it should be bolstered to increase transparency to help agencies and the public better understand federal uses of AI systems, and to improve consistency and ease agencies’ burden in interpreting the Memo. In addition, OMB must act quickly to issue further guidance on the key work streams needed to achieve the Memo’s goals, including more detailed guidance on AI use case inventories, disparate impact testing, and the waiver process, as well as necessary updates to federal procurement processes and guidance.

Read the full comments here.