On April 3, 2025, the White House issued two significant memoranda—M-25-21 and M-25-22—that collectively establish a new baseline for artificial intelligence use in the federal government.
These documents formalize a set of tight timelines and governance expectations:
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Within 60 days: Designate a Chief AI Officer (CAIO)
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Within 90 days: Establish an AI Governance Board
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Within 180 days: Publish an Agency AI Strategy
Agencies across the federal landscape are now on the clock.
While these mandates provide a clear policy signal, they also create new questions:
- How do you move quickly without increasing risk?
- How do you deliver working AI systems while complying with evolving requirements?
- And how do you avoid the typical pitfalls of vendor lock-in, under-documented pilots or siloed efforts?
What the Memos Require
OMB M-25-21: Accelerating Federal Use of AI
This memo focuses on internal governance and oversight. Key requirements include:- Appointment of a Chief AI Officer (CAIO)
- Creation of an AI Governance Board
- Maintenance of an AI use case inventory
- Risk management protocols for high-impact AI
- Where appropriate, release of AI code and models as open source
- Integration of AI with broader workforce training and data policy
OMB M-25-22: Driving Efficient Acquisition of AI
This memo covers procurement reform and AI system acquisition. Key elements:- Agencies must prioritize interoperable, vendor-neutral systems
- Data ownership and IP rights must be clearly defined and protected
- Performance metrics and explainability must be built into acquisition processes
- Contractors must disclose AI use where relevant
- Agencies must ensure systems are built for monitoring and change over time
How the DoD is Moving Faster
The Department of Defense is taking these requirements further. In March 2025, the Secretary of Defense signed a focused directive to modernize software acquisition across all service branches and agencies.View the Memo – “Directing Modern Software Acquisition to Maximize Lethality” (PDF)The Department’s guidance aligns closely with what OMB is requiring, but it adds specificity around execution. In particular, it emphasizes:
- Using OTAs (Other Transaction Authorities) to accelerate acquisition
- Integrating modular, iterative delivery into every software system
- Avoiding traditional, slow procurement cycles in favor of rapid cycles of build, test, improve
Why OTAs Matter Now
Traditional acquisition methods were not built for AI systems. OTAs provide a way to bypass rigid procurement structures and allow agencies to engage with innovative vendors for research, prototyping and pilot deployment. Sprinklenet is actively exploring OTA pathways with several components of the federal government. If you are a CAIO, procurement official, or governance board member looking to move fast while managing risk, OTAs may be your best path forward. We are happy to advise on OTA-compatible scoping, documentation and delivery frameworks. Learn more about Sprinklenet’s AI services.A Practical Framework for Implementation
To help agencies interpret the mandates and shape their approach, we developed the following model.Framework: Core Pillars of Successful AI Implementation
This framework reflects the patterns we have seen in successful AI deployments across both government and commercial environments. It aligns closely with the goals of M-25-21, M-25-22, and the DoD lethality directive.
Sprinklenet’s Role
Sprinklenet is a certified small business and AI consulting firm. We provide:- Strategic guidance for CAIOs and governance boards
- AI prototyping and MVPs that meet risk and documentation requirements
- Support for AI impact assessments, red-teaming, and post-deployment audits
- Custom tools for model traceability and explainability
- Training pathways for workforce enablement
Conclusion: A Moment to Build Responsibly and Fast
The mandates are not optional. But they also represent an opportunity. This is a rare moment for federal agencies to modernize their approach to AI and software before external regulation or vendor inertia sets the terms. Start with a prototype. Define your risk posture. Build with openness in mind. And leverage available tools like OTAs and the growing ecosystem of trusted firms. If you need support thinking through your agency’s next step, Sprinklenet is here to help.Update: AI Mandates Gain Momentum Through Procurement Reform
Since publishing this guide, the White House has released two additional policy actions that reinforce the urgency and direction of AI adoption in the federal government.April 15, 2025 – Executive Order: Enforcing Cost-Effective Commercial Solutions
This Executive Order directs agencies to prioritize commercially available technologies over custom-built systems. All active and future contracts must demonstrate that no commercial alternative exists before pursuing bespoke development. Agencies are required to report compliance to OMB and justify exceptions through formal waivers. This reinforces a fast-moving, commercial-first approach to technology acquisition.April 16, 2025 – Announcement: Revolutionary Federal Procurement Overhaul
One day later, the White House announced the most significant rewrite of the Federal Acquisition Regulation (FAR) in decades. The goal: reduce complexity, speed up acquisitions, and make it easier for emerging vendors and small businesses to deliver results. This aligns directly with OMB and DoD guidance—rapid procurement of modular, auditable AI systems is now not just preferred, but expected.Taken together, these actions validate the core argument of this guide: federal AI deployment must be fast, transparent, and grounded in real-world solutions. Agencies that align with these mandates will be best positioned to deliver meaningful, secure, and cost-effective AI capabilities in the months ahead.
