A19 Attachment 1 AI Use Compliance and Risk Management Plan.pdf
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- 75D301-26-Q-79319
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This document is an Artificial Intelligence (AI) Use Compliance and Risk Management Plan template designed for federal contractors who plan to use AI tools during contract performance when the primary deliverable is not AI system development or delivery. The template is intended for CDC/HHS contracts and requires contractors to disclose and document all AI usage comprehensively.
The template contains nine primary sections requiring detailed information: Background (AI tool name, contractor information, contract task support, AI classification, and government information impact); Ownership and Support (identifying contractor AI owner, technical contacts, privacy/security contacts, and expected users); Tool Background (product name, developer, technology type—open-source, proprietary, government-furnished, or contractor-developed—and LLM/foundation model details if applicable); Hosting and Authorization (hosting environment, FedRAMP authorization status, and system location); Data Usage (types of data processed, storage and retention policies, sharing restrictions, and model training restrictions); High-Impact Assessment (evaluating whether AI output materially affects individual rights, benefits, or safety); Safeguards (verification procedures, human review requirements, and protective measures); Monitoring and Misuse Protection (monitoring parameters, access to audit logs, incident procedures); and Required Contractor Affirmation (eight mandatory certifications regarding AI use approval, disclosure, data protection, discrimination prevention, and compliance with applicable requirements). The template requires contractors to maintain and update the plan throughout contract performance and notify contracting officers before any changes or expansions to AI use.
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| File | Type | Posted |
|---|---|---|
| A19 75D301-26-Q-79319 Amendment 0001.pdf | ||
| A19 75D301-26-Q-79319.pdf |
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Artificial Intelligence (AI) Use Compliance and Risk Management Plan
Purpose: Use this when a contractor plans to use, may use, or later proposes to use AI in contract performance, but the primary deliverable is not the development or delivery of an AI system.
1. Background
Name of AI tool/system:
Contractor using the AI:
Subcontractor or service provider, if any:
Contract task/function supported:
Describe how AI will be used in contract performance:
Is AI use required to perform the work, or optional?
Required Optional Unknown
AI classification:
Generative AI
Agentic AI Classical/Predictive Machine Learning Computer Vision
Natural Language Processing
Reinforcement Learning Other: [Insert]
Is this use limited to contractor internal operations?
Yes No
Will the AI touch Government information, systems, identities, networks, or operations?
Unknown
Was the AI system procured to support this particular contract per requirements in the Statement of Work?
2. Who owns and supports this use?
Contractor AI owner:
Contractor technical support contact:
Contractor privacy/security contact:
CDC/HHS program office using or receiving outputs:
Expected users:
Contractor staff only
CDC/HHS staff Public users Beneficiaries, patients, applicants, regulated entities, or other external parties Other: [Insert]
3. Tool background
Tool or product name:
[Insert]
Developer/vendor:
[Insert]
Is the AI technology open-source, proprietary, Government-furnished, or other?
☐ Open-source ☐ Proprietary/commercial ☐ Government-furnished ☐ Contractor-developed ☐ Subcontractor-provided ☐ Other: [Insert]
If the system uses an LLM or foundation model, what is the primary model?
[Insert]
Who provides the LLM/foundation model?
[Insert]
What model options are available?
[Insert]
Does it require an API key?
☐ Yes ☐ No ☐ Unknown
Attach or link, if available:
☐ Model card ☐ System card ☐ Data card ☐ Vendor security documentation ☐ Evaluation summary ☐ Terms of service ☐ Privacy/data retention policy ☐ Audit-log documentation
4. Where is it hosted and authorized?
Hosting environment:
☐ Contractor environment ☐ Commercial SaaS ☐ FedRAMP-authorized cloud ☐ CDC/HHS environment
☐ Local/offline environment ☐ Other: [Insert]
Where is the system hosted?
[Insert country/region/cloud/provider]
Is the product directly FedRAMP authorized or available through a FedRAMP-authorized instance?
☐ Yes ☐ No ☐ Not applicable ☐ Unknown
If no, is it undergoing FedRAMP authorization?
☐ Yes ☐ No ☐ Unknown
5. What data will be used?
Will the AI process, store, transmit, summarize, analyze, or generate Government information?
Unknown
Types of data involved:
Public information Government nonpublic information
PII
PHI
Procurement-sensitive information Proprietary/business confidential information ☐ Other: [Insert]
What information will be entered into the AI tool?
What outputs will the AI generate?
Will prompts, uploads, outputs, logs, or user interactions be stored?
☐ Yes ☐ No ☐ Unknown
Retention period:
[Insert]
Will Government data, prompts, outputs, or logs be used to train, fine-tune, improve, or benchmark any model?
Yes
No
Unknown
Will any data, prompts, outputs, or logs be shared with other users, tenants, vendors, subcontractors, or third parties?
Yes No Unknown
Explain storage, use, retention, deletion, and sharing:
6. Is this high-impact?
Could the AI output materially affect an individual’s or organization’s rights, benefits, services, health, safety, access, eligibility, enforcement status, or other significant interests?
Yes No Unknown
Could CDC/HHS personnel rely on the AI output as a principal basis for a decision or action?
Yes
Unknown
Is the AI used only for internal drafting, summarization, or administrative support with human review before use?
Yes No
High-impact rationale:
7. What safeguards are in place?
How will contractor personnel verify AI outputs before relying on them?
What human review is required before AI-generated content is submitted to CDC/HHS?
How will the contractor prevent unauthorized disclosure of Government information?
How will the contractor prevent misuse, unauthorized use, or corruption of the AI system?
How will the contractor protect privacy, civil rights, and civil liberties?
What internal policies govern this AI use?
8. Monitoring and misuse protection
What is monitored?
Accuracy/performance Performance degradation or drift Data leakage signals Abuse/misuse Prompt injection Unauthorized access Other: [Insert]
Does CDC/HHS have access to monitoring information, audit logs, or summary reports?
Upon request Not applicable
How are issues detected, escalated, and corrected?
When will CDC/HHS be informed?
What is the standard operating procedure for incidents or unacceptable outputs?
9. Required contractor affirmation
The contractor affirms that:
AI will not be used unless approved by the Contracting Officer.
The contractor has disclosed all planned or potential AI use.
The contractor will not enter Government information into unapproved AI tools.
The contractor will not use Government data to train, fine-tune, or improve an AI model unless expressly authorized.
The contractor will maintain and update this AI Use Card throughout contract performance.
The contractor will notify the Contracting Officer and COR before changed, expanded, or new AI use.
The contractor will prevent unlawful discriminatory use or outputs.
The contractor will comply with applicable privacy, security, data rights, records, civil rights, and AI requirements.
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