On January 23, 2025, marking one of his first actions during his second term, President Trump enacted Executive Order (EO) 14179, titled “Removing Barriers to American Leadership in Artificial Intelligence.” This move fulfilled a campaign promise to revoke Executive Order 14110, commonly referred to as the Biden AI EO.
It is understandable that AI took precedence in President Trump’s agenda for his second term. During his first term, he became the inaugural president to issue an EO focused on artificial intelligence. On February 11, 2019, he released Executive Order 13859 aimed at preserving American Leadership in AI. This groundbreaking order acknowledged the critical role of AI in both the economic landscape and national security of the United States. It set the groundwork for future AI investments by allocating federal funds to double AI research funding, establishing national AI research institutions, and providing regulatory guidelines for private sector AI development. Furthermore, the Trump Administration initiated recommendations for federal agencies to adopt AI technologies within government operations.
The new EO appoints the Assistant to the President for Science and Technology, the Special Advisor for AI and Crypto, and the Assistant to the President for National Security Affairs, in collaboration with relevant agency heads, a timeframe of 180 days—until July 22, 2025—to shape a new AI Action Plan that supersedes policies previously established under the Biden Administration.
OSTP/NSF RFI
To facilitate the creation of the AI Action Plan within the stipulated timeframe, the National Science Foundation’s Networking and Information Technology Research and Development (NITRD) National Coordination Office (NCO), on behalf of the Office of Science and Technology Policy (OSTP), has issued a Request for Information (RFI) concerning the development of an AI Action Plan. The deadline for comments is March 15, 2025.
This presents a significant opportunity for stakeholders to offer valuable, practical insights to the second Trump Administration. As indicated in the RFI, the administration aims to utilize this feedback to “identify priority policy actions required to maintain and enhance America’s AI leadership while ensuring that unnecessary regulatory burdens do not hinder private sector AI innovations.
Epstein Becker Green, along with its Artificial Intelligence team and its healthcare, employment, and regulatory experts, is actively tracking how the administration’s plan will tackle health care AI and workplace AI regulation. During President Trump’s initial term, the administration primarily centered its AI policies around national security. With the substantial growth in the types and applications of AI tools since then, it is expected that the Trump Administration will extend its regulatory focus during this term to aim at fortifying “America’s global AI leadership.”
Our clients across the healthcare sector have increasingly adopted various AI tools for both clinical and administrative functions, as well as for employment decision-making purposes. We collaborate with clients to manage enterprise risks while fostering a strategic advantage through AI advancements, and we look forward to influencing current AI policies in collaboration with federal policymakers.
Submission Guidelines
The OSTP invites contributions regarding the most crucial policy actions to be included in the forthcoming AI Action Plan. Responses can encompass any aspect of relevant AI policy, such as hardware and chips, data centers, energy efficiency, model development, open source initiatives, application and usage (in either the private or public sector), clarity and reliability of AI model outputs, cybersecurity, data privacy throughout the AI system lifecycle (including protection against AI model attacks), risks, regulatory measures and governance, technical standards, national security concerns, research and development, workforce education, competition, intellectual property, procurement strategies, international collaboration, and export regulations.
Respondents are encouraged to propose specific AI policy measures addressing the mentioned topics. Comments may be sent via email to [email protected] or mailed to the address listed on page 2 of the RFI. Email submissions should be machine-readable and not copy-protected, and must include “AI Action Plan” in the subject line. Additional submission guidelines, including formatting and page restrictions, are provided on page 2.
For assistance in submitting comments on the AI Action Plan, please connect with your Epstein Becker Green attorney or the blog authors.
