Inside GSA’s Playbook for OMB M-25-21—and Why It Matters to Contractors
GSA’s “Strategies for OMB Memorandum M-25-21” offers one of the clearest agency roadmaps yet for operationalizing the federal government’s new AI policy regime. Dated September 30, 2025 and prepared by Zachary Whitman, the plan translates OMB’s government-wide memo into concrete actions across use cases, infrastructure, governance, workforce, and acquisition—revealing where agencies will spend, what evidence they will demand, and how vendors can align.
At the center is a tiered model of AI adoption. Tier 1 focuses on broad, low-risk enablement via a secure enterprise chatbot to boost drafting, training, and knowledge retrieval. Tier 2 moves into programmatic integrations through APIs that embed models in business workflows for tasks like acquisition document generation, data quality improvement, and agentic “co-pilot” support. Tier 3 embeds AI in higher-impact or rights-sensitive systems (e.g., identity verification), with commensurately stronger testing, monitoring, and human oversight. This sequencing underscores a pragmatic path from productivity wins to mission transformation while dialing up governance as impact rises.
GSA pairs this with enabling infrastructure and shared services. The USAi platform provides a FedRAMP-authorized environment for chatbot and API access, side-by-side model evaluation, and standardized telemetry. The Enterprise Data Solution (EDS) anchors data quality, provenance, and model lineage, while a “20x” FedRAMP initiative aims to accelerate authorizations for generative AI platforms. Together these pieces create a repeatable pipeline from development and testing to deployment and continuous monitoring, with safety metrics, bias checks, and incident response wired in.
Governance is equally prescriptive: a Chief AI Officer chairs an AI Governance Board (EDGE) and an AI Safety Team that review use cases, require AI Impact Statements and test plans, and mandate annual re-registration of production systems. Every operational system must obtain an Authorization to Operate, complete privacy assessments, and appear in a public AI use-case inventory—aligning internal controls with transparency obligations that M-25-21 directs across the executive branch.
For industry, GSA’s strategy signals near-term purchase patterns and compliance artifacts. First, acquisition will favor offerings that “plug into” USAi and can document data lineage, explainability, and safety evaluation evidence out of the box. Second, FedRAMP pathways (including accelerated tracks) become even more decisive for time-to-value. Third, cost telemetry and usage analytics are not extras: vendors should expect to expose consumption, performance, and bias metrics suitable for governance boards and budget planning. Finally, standardized vehicles like “OneGov” point to scaling of proven solutions across agencies—an opportunity for contractors who can meet common requirements once and sell many times.
Stepping back, OMB’s M-25-21 itself sets the government-wide frame: publish strategies and inventories, stand up CAIO-led governance, and accelerate adoption while protecting civil rights, privacy, and security. GSA’s plan shows what compliance looks like in practice and previews the artifacts your proposals will need to present. If you can demonstrate FedRAMP posture, model evaluation discipline, human-in-the-loop controls, and clear data provenance—mapped explicitly to M-25-21—you will be fluent in the language agencies are now using to buy AI.
Credit: U.S. General Services Administration; author Zachary Whitman, “Strategies for OMB Memorandum M-25-21,” Sep. 30, 2025.
Disclaimer: This post summarizes public sources for informational purposes only and does not constitute legal advice. While accuracy is a priority, readers should verify requirements against official OMB and agency publications and consult counsel as needed.