CDT, DGS to Begin Requiring Vendors to Report Generative AI

State IT and procurement officials Tuesday walked vendors through some of the upcoming changes to how agencies will buy products with generative AI components.

Among the key takeaways from the online session hosted by the California Department of Technology (CDT) was a new requirement that vendors complete a Form 1000 for each piece of technology they are trying to sell or resell to a state agency. Officials clarified that this form is only required on a per-solicitation basis and will not require companies to disclose every piece of technology in their catalog at one time.

CDT Deputy Director of Statewide Technology Procurement Tiffany Angulo said the form would be a requirement for all IT, non-IT and telecom solicitations and should be completed like any other contract document by an authorized signatory.

In addition, technology resellers are being asked to work with original manufacturers to identify the products that might contain GenAI technology, noted Department of General Services Procurement Division Deputy Director Angela Shell.

Angulo and Shell said despite concern that the Form 1000 would be used as a tool to disqualify products using GenAI, its purpose is to identify where GenAI is or will be in use throughout state agencies. State Chief Technology Officer Jonathan Porat also reassured attendees that the form would not be a punitive tool for the state to use against vendors.

Many products use some form of the technology without an obvious indication, and new iterations may include the technology, officials noted. Exemptions are being considered for tangible goods and services.

New guidance and an updated form will be issued July 1, Shell said.

Agencies will also see some new requirements in the form of risk self-assessments for the GenAI systems as well as consultations from CDT staff for moderate- and high-risk use cases. That process will begin next week, said CDT Chief Enterprise Architect Renoir Pope.

CDT Cybersecurity Risk and Governance Chief Payam Hojjat explained that six focus areas will be evaluated throughout this process: technical, ethical, societal, operational, regulatory and compliance and environmental considerations. Evaluating the potential impacts of the technology on diversity, equity and inclusion will also be a major priority, Hojjat said.

Another area of note in the session was the ongoing update to the DGS procurement terms and conditions, which kicked off earlier this year and is not related to AI procurements. Shell said that document will likely be available within the next 30 days.

Questions asked during the session will be answered within two weeks, officials said, and new technical and policy questions can be submitted via email to CDTGenAIIntakeRequest@state.ca.gov.