Over the past year, federal agencies have started inserting a new, critical question into solicitations: Did you use AI to develop any part of this proposal?. Driven by guidance from two key Office of Management and Budget (OMB) memos (M-25-22 and M-26-04), the government is pushing for mandatory disclosure requirements for vendors regarding their use of artificial intelligence.

However, as recent analysis highlights, this transparency requirement currently only runs in one direction. While contractors are expected to fully disclose their AI utilization, agencies are currently under no obligation to disclose if they will use AI to read, score, summarize, or evaluate your proposal submission. This leaves small businesses in the dark regarding whether human eyes or an algorithm will be judging their highly technical solutions.

Fortunately, ultimate accountability has not shifted. Under FAR 1.602-1, the federal contracting officer (the warrant holder) remains entirely responsible for all decisions and award signatures, not an artificial intelligence system. Because of this, industry experts are urging contractors to push back professionally during the solicitation phase to ensure a transparent evaluation process.

STRATEGIC ACTION PLAN FOR YOUR BUSINESS

As your advisor, I highly recommend establishing firm internal policies around AI use and aggressively seeking clarity from agencies before submitting your bids. Here is your game plan:

• Submit a Reciprocal AI Question: Do not let the agency operate in a black box. During the solicitation's Q&A or clarification period, submit a professional question asking if the agency will use AI or machine learning tools to analyze or evaluate your submission. Ask them to identify the specific tools being used and formally request clarification on how a human evaluator will review the system's outputs.
• Build an Internal AI Traceability Log: You can still use AI to streamline your proposal drafting, but you must be able to prove that the final solution belongs to you, not the tool. Create a traceability log that tracks which proposal sections utilized AI assistance (for research, formatting, or drafting) and strictly document which named human subject-matter expert reviewed, validated, and owns the final content.
• Safeguard Source-Selection Data: This cannot be overstated: never paste proprietary or source-selection-sensitive information into a public AI tool. Ensure your entire proposal team understands the boundaries of FAR 3.104 and your Non-Disclosure Agreements (NDAs) to avoid a catastrophic data spill.

Credits & Further Reading: This analysis is based on insights shared by Jaime Gracia in a recent LinkedIn article, referencing guidance from Shauna Weatherly and current OMB memos.

• • Read the full article and copy the suggested AI prompts here: The AI Disclosure Question Every Proposal Needs.