USDA Framework for State, Local, Tribal, and Territorial Use of Artificial Intelligence for Public Benefit Administration

• Authority: Department of Agriculture
• Parent authority: Federal government
• Jurisdiction: United States
• Collections: U.S. regulations, executive orders, and agency policies
• Most recent activity: Enacted
• Most recent activity date: 2024-04-29

Risk subdomain coverage

Good coverage — Comprehensive governance measures or mitigations with clear procedures relating to the risk subdomain are explicitly described.

• Unfair discrimination and misrepresentation
• Unequal performance across groups
• Overreliance and unsafe use
• Loss of human agency and autonomy
• Governance failure
• Lack of capability or robustness
• Lack of transparency or interpretability

Minimal coverage — Brief mention but no specific mitigations, recommendations or governance measures relating to the risk subdomain are described.

• Compromise of privacy
• AI system security vulnerabilities
• False or misleading information
• Fraud, scams, and targeted manipulation

All other risk subdomains had no coverage in this document.

Risk Coverage Summary

The document has good coverage of approximately 10-12 subdomains, with strong focus on discrimination and bias (1.1, 1.3), privacy concerns (2.1), misinformation risks (3.1), system safety and robustness (7.3, 7.4), and governance structures (6.5). Coverage is concentrated in fairness, transparency, and AI system reliability domains, with particular emphasis on protecting vulnerable populations in public benefits administration.

Sector coverage

Good coverage — Comprehensive governance measures or mitigations with clear procedures relating to the sector are explicitly described.

• Health Care & Social Assistance
• Public Administration (excl. National Security)

Minimal coverage — Brief mention but no specific mitigations, recommendations or governance measures relating to the sector are described.

• Educational Services

All other sectors had no coverage in this document.

Sectors Summary

This document primarily governs AI use in Public Administration (excluding National Security), specifically focusing on government agencies administering federal nutrition assistance programs. It does not regulate private sector activities but rather provides guidance for state, local, tribal, and territorial government entities in their delivery of public benefits.

Legislative Status

Soft Law

Legislative Status Summary

This is a guidance framework issued by USDA in response to an Executive Order, using predominantly voluntary language ('should', 'encouraged') with limited mandatory requirements ('must') primarily referencing existing legal obligations. While it establishes governance principles and recommendations, it relies on future program-specific regulations for binding enforcement.

Actors

Proposer

• Entity Types: AI_Governance_Actor
• Entities: United States Department of Agriculture (USDA); Food and Nutrition Service (FNS)
• Summary: The document is issued by USDA's Food and Nutrition Service in response to Executive Order 14110, Section 7.2(b)(ii), which directed the Secretary of Agriculture to issue guidance within 180 days.

Target

• Entity Types: AI_Governance_Actor, AI_Deployer
• Entities: State agencies; Local agencies; Tribal nations and indian tribal organizations; Territorial agencies; SLTT (state, local, tribal, and territorial) government agencies
• Summary: The framework explicitly applies to state, local, tribal, and territorial government agencies that administer USDA's 16 federal nutrition programs. These agencies are both governance actors (government entities) and AI deployers (implementing AI systems for benefit administration).

Enforcer

• Entity Types: AI_Governance_Actor
• Entities: Food and Nutrition Service (FNS); USDA; FNS civil rights and civil liberties offices; FNS Regional Operations and Support
• Summary: FNS is designated as the oversight and enforcement body, with authority to require notifications, approvals, monitoring, and reporting from SLTT agencies. The document establishes FNS's role in reviewing and governing AI use in nutrition programs.

Monitor

• Entity Types: AI_Governance_Actor
• Entities: Food and Nutrition Service (FNS); FNS Regional Operations and Support; Civil Rights Division; Office of Management and Technology; Independent third parties (for evaluations)
• Summary: FNS is responsible for monitoring SLTT agency compliance through annual reporting requirements, ongoing evaluation, and review of AI systems. The document also mentions potential independent third-party evaluations.

AI Lifecycle Stages

Lifecycle stages covered by the documents, as defined in the OECD Framework for the Classification of AI Systems

• Plan and Design
• Collect and Process Data
• Build and Use Model
• Verify and Validate
• Deploy
• Operate and Monitor

AI Lifecycle Summary

The document comprehensively covers all stages of the AI lifecycle, with particularly strong emphasis on Verify and Validate, Deploy, and Operate and Monitor stages. It addresses planning requirements, data quality considerations, model development suitability, extensive validation and testing requirements, deployment notification and approval processes, and ongoing monitoring and evaluation obligations.

Technical Scope

Terms relating to technical scope that are mentioned or implicitly referenced in the document

• AI Models
• AI Systems
• Generative AI
• Open Weight / Open Source

Technical Scope Summary

The document explicitly mentions AI systems and AI models, with detailed definitions provided. It references generative AI specifically and discusses various AI technologies including machine learning. The document does not explicitly mention frontier AI, general purpose AI, task-specific AI, foundation models, predictive AI, open-weight models, or compute thresholds. The focus is on AI applications in public benefits administration rather than specific model architectures or capabilities.