91proÊÓƵ

WASHINGTON – Today, global tech trade association 91proÊÓƵ responded to the White House Office of Management and Budget (OMB)’s request for information on the draft memorandum “Advancing Governance, Innovation, and Risk Management for Agency Use of Artificial Intelligence.” , 91proÊÓƵ urged OMB to leverage AI’s transformative capabilities to improve government processes and services, rely on the National Institute of Standards and Technology (NIST) AI Risk Management Framework (RMF) for evaluating and mitigating AI risk, and promote innovation and competition by ensuring U.S. government agencies have the authority to procure AI services.

“[We] support the government’s vision of safely and responsibly developing and deploying AI and we commend President Biden for his leadership [….]. At the same time, it is important that OMB’s guidance strikes a balance that fosters accountability without hindering innovation,” 91proÊÓƵ wrote in its comments. “To ensure U.S. competitiveness, the federal government must rely on the cutting-edge commercial AI technologies developed by the private sector pursuant to commercial best practices, including widely accepted commercial practices for managing risk. We believe that the risk-based approach outlined in this memorandum is an important step in realizing this vision, but we urge OMB to consider our suggestions for how to fully realize a risk-based approach.”

91proÊÓƵ outlined recommendations for the federal government in key areas including:

• Promoting innovation by prioritizing the use of commercial AI solutions to the maximum extent practicable, rather than developing government-unique requirements and solutions;

• Protecting vendors’ intellectual property and proprietary data by ensuring that government-required reporting focuses on the minimum amount of information required to address risk;

• Evaluating AI models’ capabilities and risks through testing and by focusing on outputs, rather than through inputs such as training data;

• Adopting the National Institute of Standards and Technology (NIST) AI Risk Management Framework (RMF) as a common standard for evaluating and mitigating AI risk;

• Advancing competition by ensuring government requirements prioritize interoperable commercial AI solutions, including related technologies, in line with existing best practices and commitments;

• Ensuring the U.S. government prioritizes automation and modernizing its internal systems and practices to appropriately facilitate risk assessments and continuous monitoring of AI solutions; and

• Using all available avenues and authorities to attract, retain, and develop the skilled, diverse AI workforce needed to accomplish the responsibilities described in the memo.

Read 91proÊÓƵ’s full submission.