Search arXiv⌕ Search
Home/Archive/arXiv

arXiv · 2505.08133

One Bad NOFO? AI Governance in Federal Grantmaking

Dan Bateyko·Karen Levy
View original source ↗Read source document ↗Export metadata ↓

Abstract

Much scholarship considers how U.S. federal agencies govern artificial intelligence (AI) through rulemaking and their own internal use policies. But agencies have an overlooked AI governance role: setting discretionary grant policy when directing billions of dollars in federal financial assistance. These dollars enable state and local entities to study, create, and use AI. This funding not only goes to dedicated AI programs, but also to grantees using AI in the course of meeting their routine grant objectives. As discretionary grantmakers, agencies guide and restrict what grant winners do -- a hidden lever for AI governance. Agencies pull this lever by setting program objectives, judging criteria, and restrictions for AI use. Using a novel dataset of over 40,000 non-defense federal grant notices of funding opportunity (NOFOs) posted to the U.S. federal grants website between 2009 and 2024, we analyze how agencies regulate the use of AI by grantees. We select records mentioning AI and review their stated goals and requirements. We find agencies promoting AI in notice narratives, shaping adoption in ways other records of grant policy might fail to capture. Of the grant opportunities that mention AI, we find only a handful of AI-specific judging criteria or restrictions. This silence holds even when agencies fund AI uses in contexts affecting people's rights and which, under an analogous federal procurement regime, would result in extra oversight. These findings recast grant notices as a site of AI policymaking -- albeit one that is developing out of step with other regulatory efforts and incomplete in its consideration of transparency, accountability, and privacy protections. The paper concludes by drawing lessons from AI procurement scholarship, while identifying distinct challenges in grantmaking that invite further study.

Explore related subjects

cs.CYcs.AI

Keep this discovery

Explore connections, maps & timelines

BibTeXRIS

Dan Bateyko, Karen Levy. 2025-05-21. One Bad NOFO? AI Governance in Federal Grantmaking. https://doi.org/10.1145/3715275.3732109

Cite the original work for its findings. Save a collection to share your selection of sources.

KEEP EXPLORING

Related papers

arXiv2026

An Investigation Into Secondary School Students' Debugging Behaviour in Python

Background and context: Debugging is a significant and often frustrating challenge for beginner programmers. Understanding students' debugging behaviours and strategies can help to identify common difficulties and inform approaches for alleviating these. Currently, there are limited studies of school students' debugging behaviour in a text-based programming language, a medium through which millions are learning to program. Objectives: In this paper, we investigate the debugging behaviour of 12-14-year-old students learning Python through a lesson-long classroom study. Method: We collected program snapshots from 73 students' attempts at a set of Python debugging exercises in an online code editor. Through qualitative content analysis of these snapshots, we developed a granular categorisation of the changes students made when debugging. Findings: A range of debugging behaviours were exhibited by students, many of which were ineffective. Students added errors through small-scale changes, reverted corrective changes, and repeatedly ran identical programs in quick succession. From the results, we identify four barriers to successful and reliable debugging for students learning a text-based programming language: fragile knowledge, a lack of systematicity and reflection, the syntax barrier, and dynamics of emotions and attitudes. Implications: This paper highlights some of the difficulties that secondary school students have when debugging in Python and the challenges of analysing program snapshots through manual inspection. We recommend that school teachers explicitly teach a systematic approach to debugging and discourage the use of ineffective debugging behaviours, and that programming environments should contain features that facilitate successful debugging.

cs.CY↗
arXiv2026

Printed but not benchmarkable: most building-decarbonisation disclosure cannot be matched to the pathways that stranding regulation assumes

Cities are beginning to enforce carbon limits on existing buildings. Science-based decarbonisation pathways set those limits one asset type and one jurisdiction at a time. Owners, however, report for the whole firm. We measure what that mismatch costs on two sets of public corporate reports: a census of 502 reports from the 119 listed built-environment firms with a collected report inside a 2,246-firm panel (2003-2023), and 519 real-estate reports from 101 firms (2007-2024). BeDA, a multimodal language-model tool whose reliability we test first, read them. Running the pathway frameworks' own entry tests over published disclosure: 16.5% of census reports (43.7% of real-estate reports) print an operational carbon intensity per square metre; 6.6% (25.0%) can be matched to a pathway for their property type in a covered jurisdiction; and only 5.0% (16.4%) disclose the floor area they divided by. Of the failures at the pathway test, 82-84% follow from reports lumping the portfolio together and 16-18% from a missing curve in the pathway library. The obstacle is the reporting unit, not missing data. The rate is roughly twice as high for European as for US listings (65-71% versus 35% in listed real estate). We also show that a US portfolio's carbon verdict cannot be worked out from disclosure at all. Within one climate zone, the pathway's carbon limit varies by up to 2.79-fold with the electricity subregion, which no report names; its energy limit does not move. Extraction is checked against the source PDFs (97.3% of extracted intensities appear verbatim) and repeats on a second extractor (kappa = 0.97). Recall of the non-disclosing class was 95.1% in a blinded hand audit of 122 reports. The fix follows from the measurement: split intensity by asset type and jurisdiction, and report floor area.

cs.CY↗
arXiv2026

Incipit: Axiom-Grounded Scaffolding for Human-AI Literary Creation

Large language models can produce fluent prose from short prompts, but a direct interaction gives writers little access to the assumptions that shape a long narrative. We present Incipit, an implemented research prototype that inserts an explicit planning layer between writer intent and generated prose. The layer is grounded in literary axioms, which are curated and reusable propositions about human experience and narrative craft. The prototype connects a knowledge base of 1455 axioms and 472 typed relationships to a five round direction dialogue, a retrieval and selection pipeline, and a three level blueprint covering creative premises, story beats, character arcs, and chapter outlines. Writers can inspect and edit the resulting structures before using them as context for scene generation. Additional modules support real event abstraction and five dimensional diagnostic feedback. We describe the design rationale, data flow, implementation boundaries, and a worked design example. Because no controlled user study or independently rated output study has yet been completed, we do not claim that the system improves literary quality. Instead, we outline a future preregistered comparison designed to distinguish the contribution of axiom grounding from that of hierarchical planning. The paper contributes a concrete architecture for making literary knowledge an inspectable coordination object in human AI writing.

cs.CY↗