POPVOX Foundation Submits Response to the OSTP’s RFI on National Priorities for AI
Re: OSTP-TECH-2023-0007
POPVOX Foundation is honored to submit this response to the Office of Science and Technology Policy (OSTP) Request for Information (“the AI RFI”) on “National Priorities for Artificial Intelligence.”
This submission focuses on questions related to “bolstering democracy and civic participation” and “innovating in public services.”
III. Bolstering democracy and civic participation:
14. How can AI be used to strengthen civic engagement and improve interactions between people and their government?
Automated technologies present new challenges and opportunities in the way that individuals interact with, access services from, and get information about their government. In our work with Congress, we note that correspondence volumes are expected to increase significantly over the coming months with much of that input generated by large language models (LLMs) or similar technologies. We expect similar volume increases for public comments on rulemakings in federal agencies. Of course, these same automated technologies could be incorporated into government workflows to help overwhelmed offices and agencies better process, understand, and respond to these public messages — but government should proceed with caution.
Without intentional design of new systems, optimizing workflows through automation may introduce a “machines talking to machines” dynamic that further degrades or depersonalizes the constituent engagement process. Furthermore, it is not yet clear how agency use of automated processing technologies for comments submitted through a notice and comment rulemaking process could impact judicial review of compliance with the Administrative Procedures Act.
In order to maximize the benefit of these new technologies in the public engagement process and preserve and enhance the civic experience, we suggest the following:
OMB / DoJ should issue guidance on the legal status of comment review conducted with the assistance of automated technologies.
AI can help agencies process and analyze large volumes of comments more quickly and efficiently, helping to identify patterns, trends, and significant issues in the comments, potentially providing insights that human reviewers might miss. In this way, AI-assisted review can enhance the democratic process and help agencies make better-informed decisions.
However, agencies must ensure that any process augmented by assistive technologies still complies with the Administrative Procedures Act. This includes the requirement to review all comments, provide a "concise general statement" explaining the basis and purpose of the final rule, addressing novel issues of law raised in public comment, and ensuring that the decision-making process is transparent and understandable to the public.
Agencies should explore ways to deploy chatbots and other automated services to handle basic service questions and OMB should issue general guidance for their responsible use. These should address:
Data Privacy and Security: OMB should issue guidelines on data protection, including how data is collected, stored, and used by chatbots.
Transparency: Agencies should be required to clearly inform users that they are interacting with a chatbot, not a human; and inform users about how their data will be used.
Accessibility: OMB should require agencies to make their chatbots accessible to all people, including those with disabilities.
Accuracy: OMB should establish standards for regular review and updating of the knowledge base used by chatbots to engage with the public.
Accountability: Guidelines should require clear designation of the office charged with maintaining correct information and addressing any data breach or system failures.
Bias and Fairness: Guidelines should require agencies to test automated systems for bias and ensure that they treat all users fairly.
User Experience: Guidelines should encourage agencies to design chatbots that are user-friendly and intuitive with clear language, helpful responses, and clear instructions for reaching a human, if needed.
Continuous Improvement: Rather than specifying technology to be used for these services, OMB should encourage agencies to maintain modern standards
The Administration should engage in a broad public campaign to receive feedback on how individuals currently interact and *want* to interact with their government.
POPVOX Foundation and The GovLab at Northeastern University have encouraged a broad public engagement exercise that invites diverse stakeholders, individuals, and experts to share their input on how the government should engage, resulting in recommendations that incorporate examples from international and state and local projects. Results could include reports, videos, and prototypes — with actionable insights into improving current practices for communication, suggestions of new formats, methods, and tools for both better communication and improved public understanding of the workings of government.
This could include:Service Blueprint: A comprehensive review of current practices
Data Analysis: Analysis of current engagement patterns and participants
Broad Public Engagement Survey: A large-scale online survey to gain insights into how the American public wishes to engage. The survey could be designed to elicit a rank ordered list of priorities by allowing people to choose from pre-existing answer choices, and also to add their own contributions.
Online Focus Group: A representative sample of individuals could be invited to participate in a real-time online focus group to discuss their experiences and suggest improvements.
Expert Input: Academics and other public engagement experts could be invited to share ideas for how to improve and reinvent the public engagement process. This could be complemented by a research paper on what other governments are doing.
Youth Engagement: A targeted effort could be made to understand the communication preferences of younger individuals, potentially involving an online survey or a school/college competition.
Public Redesign Initiative: The project could include a broad call for input from all Americans, potentially through a televised town hall and survey aimed at redesigning the engagement process.
We would welcome the opportunity to further discuss how the American public could be broadly consulted to co-design the future of public engagement.
16. What steps can the United States take to ensure that all individuals are equipped to interact with AI systems in their professional, personal, and civic lives?
One area that federal agencies must address is the increased proliferation of spoofing and phishing attacks that mimic legitimate government communications. These cyber threats exploit the trust that citizens place in their government, tricking them into revealing sensitive information or performing actions that compromise their security. As the deployment of AI and automated technologies advances, the sophistication of these attacks is also expected to increase. Consequently, agencies must implement rigorous cybersecurity protocols and enhance public awareness about these threats. They should develop systems for constituents to easily verify the authenticity of government communications, thereby mitigating the risk of falling victim to such scams. In addressing these challenges, the goal should be to create an information ecosystem through which individuals can interact with their government with confidence.
V. Innovating in public services:
25. How can Federal agencies use shared pools of resources, expertise, and lessons learned to better leverage AI in government?
Federal agencies should engage Congressional caseworkers to help inform and guide the deployment of AI for public services. Caseworkers often provide the customer service of last resort, after an individual has encountered some problem accessing government services through the agency’s process.Casework issues generally fall into three categories: excessive administrative burden, inefficient processing, and “edge” or unusual cases where standard customer service channels fail.
Congressional caseworkers have unique cross-agency problem-solving insight. They are the only federal government employees that regularly interact with multiple agencies on behalf of constituents, with the ability to observe common problems or potential solutions that could be broadly applied.
Experienced caseworkers are experts in government change management. They understand how constituents react to changes, how to effectively message changes for diverse audiences, which changes are most likely to lead to confusion and distrust vs. trust. This national perspective may be helpful in identifying and prioritizing the most urgent and cost-effective places for AI-powered intervention.
There is precedent for tapping into caseworker expertise in the Executive Branch: In 1977, an OMB study team under Richard Pettigrew, working on a Carter commission to OMB to study agency performance, surveyed Congressional offices for their casework-based judgements on which agencies were administered the least efficiently. Results were sent to agencies, along with a related study of agency liaison input.
POPVOX Foundation is in regular contact with Congressional caseworkers through our “Casework Navigator” program, which includes regular webinars, convenings and the “Case Notes” newsletter. We would welcome the opportunity to facilitate conversations between executive branch agencies and relevant caseworkers to help surface issues or vet proposed solutions.
About POPVOX Foundation
POPVOX Foundation is a 501(c)3 nonprofit organization, founded in February 2021, with a mission “to inform and empower people and make government work better for everyone.”
POPVOX Foundation works with governments to address the challenges presented by the constantly evolving landscape of technology and society, known as "pacing problems." Through collaborations with researchers, government officials, and other stakeholders, the foundation aims to advance innovative solutions that facilitate effective oversight, transparency, accountability, and accessibility, ensuring efficient and effective governance.
Information-sharing and best practices for automated technologies in government
POPVOX Foundation is working to facilitate information-sharing and best practices for the testing, deployment and oversight of automated technologies including Large Language Models (LLMs) in the legislative branch. This includes hosting briefings and staff roundtables on Capitol Hill, publishing articles and white papers to aid institutional decision-making, consulting with counterparts in other countries to share information and lessons learned.
