National Fair Housing Alliance Responds to OMB’s RFI on AI Procurement in Government
FOR IMMEDIATE RELEASE
April 29, 2024
Contact: Janelle Brevard | jbrevard@nationalfairhousing.org
National Fair Housing Alliance Responds to OMB’s RFI on AI Procurement in Government
Washington, D.C. – Today, The National Fair Housing Alliance (NFHA) submitted a response to the Office of Management and Budget’s (OMB) Request for Information (RFI) on Responsible Procurement of Artificial Intelligence in Government. The request seeks input from various stakeholders on how to strengthen and incentivize market competition in the AI procurement process to combat monopolization, and how to incorporate risk management requirements to enforce the responsible acquisition and use of AI systems in the federal government. The request follows the finalized OMB memorandum directing agency executives to implement and comply with the minimum risk management requirements for AI, ensuring safety and safeguarding rights impacts.
NFHA’s response addresses the following issue areas:
1.The respective responsibilities of the vendor and the adopting agency in testing, evaluation, and impact assessments.
2. Establishing accountability through a clear and standardized set of transparency requirements.
3. Considering existing tensions and incentives within the public-private actors that may challenge the integral process of implementing responsible AI solutions.
4. The importance of developing standardized reporting tools and assessment templates to ensure compliance.
5. Emphasizing the need for detailed and accessible transparency in AI development and testing, rather than imposing restrictive benchmarks that may not be domain applicable or appropriate.
6. Building AI expertise within the agency to ensure vendor compliance.
7. Designing procurement actions to ensure that AI systems in the government protect privacy, civil rights, and civil liberties.
NFHA applauds OMB’s diligent efforts in engaging a wide array of stakeholders to procure AI systems responsibly for government use. “Their focus on addressing major procurement challenges, particularly market competition and risk management, is crucial for responsibly mitigating, managing or avoiding risks of adverse consumer outcomes and unstable marketplaces that come with the procurement of third-party AI solutions and data,” says Michael Akinwumi, NFHA’s chief responsible AI officer.
The questions posed in the OMB’s RFI effectively highlight essential considerations for creating detailed procurement guidelines. These guidelines are designed to foster market participation and implement stringent risk management measures in alignment with the latest OMB directives on AI governance, which emphasize the minimum requirements for safety and rights-impacting AI within federal agencies. “OMB’s initiative to require precise testing and evaluation protocols for both vendors and agencies sets a standard of accountability for developers and deployers. This emphasis is essential in ensuring that AI technologies are safe, secure and trustworthy,” says Lusine Petrosyan, AI policy researcher at NFHA. We support the ongoing initiatives to mitigate risks and enhance the benefits of AI, highlighting the importance of equity and civil rights in the OMB’s guidance to promote safe and fair AI systems that prevent algorithmic bias.
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The National Fair Housing Alliance (NFHA) is the country’s only national civil rights organization dedicated solely to eliminating all forms of housing and lending discrimination and ensuring equal opportunities for all people. Through its homeownership, credit access, tech equity, education, member services, public policy, community development, and enforcement initiatives, NFHA works to dismantle longstanding barriers to equity and build diverse, inclusive, well-resourced communities.