OTI Welcomes OMB Guidance on AI, Suggests Improvements

On Tuesday, OTI filed comments in response to the Office of Management and Budget’s (OMB) Draft Memorandum On Advancing Governance, Innovation, and Risk Management for Agency Use of Artificial Intelligence. OTI generally welcomes the substance of the guidance, which establishes important guardrails for federal agencies’ development and use of artificial intelligence (AI). OTI’s comments both support important aspects of the Memorandum and note areas that would benefit from clarification, amendment, or further development.

OTI highlights the memo’s approach to catalyzing federal innovation and protecting rights, its detailed focus on enumerating how agencies protect rights, and the helpful suggestion that the Intelligence Community also follow the draft guidance. It also provides analysis and five recommendations on strengthening the memo’s accountability framework, including its provisions on public transparency, its grants of discretion to Chief Artificial Intelligence Officers, the scope of exemptions, and remedies for adversely affected individuals.