Immediate Platform Actions:
Cabrillo Signals Match Engine should be configured to rescore all HHS AI/ML opportunities in your pipeline. The classification discrepancy increases probability of mid-contract compliance changes, affecting win probability, cost estimation, and risk ratings. Set automated rescoring triggers for any HHS solicitation mentioning "artificial intelligence," "machine learning," "automated decision," or "algorithmic system." Cross-reference against DHS, DOJ, and VA AI solicitations to identify agencies applying stricter governance standards—these represent lower compliance risk.
Cabrillo Signals Intelligence Hub requires immediate saved search configuration for: (1) HHS AI governance policy updates, (2) OMB guidance revisions or clarifications on impact classification, (3) GAO or OIG reports on AI risk management implementation, (4) SAM.gov (System for Award Management) solicitations from HHS containing AI RMF or high-impact AI language, and (5) contract modifications on existing HHS AI vehicles (OASIS+, CIO-SP4) adding compliance requirements. Set alert frequency to daily for the next 90 days during the likely policy clarification window.
Proposal Studio (Proposal OS) compliance matrices must be updated to address dual-standard AI governance. For HHS proposals, build compliance narratives that meet current low-impact requirements while demonstrating readiness for high-impact reclassification. Populate the win theme library with "governance-ready AI" positioning, "multi-agency AI compliance experience" differentiators, and "reclassification-proof architecture" technical approaches. Configure the bid/no-bid decision engine to flag HHS AI opportunities with elevated compliance risk scores until classification methodology stabilizes.
Notification Chain:
- Capture Managers (immediate)—Need to assess active HHS AI pursuits for reclassification risk and adjust capture strategies, teaming decisions, and pricing assumptions. Must engage HHS program offices within 48 hours to clarify risk assessment expectations.
- Proposal Directors (within 4 hours)—Must update compliance matrices, win themes, and technical approach templates for all AI-related proposals across HHS, DHS, DOJ, and VA. Need to brief proposal teams on multi-agency governance positioning strategies.
- Program Managers with Active HHS AI Contracts (within 8 hours)—Must audit current deliverables against high-impact criteria, document risk assessment methodologies, and prepare impact statements for potential contract modifications. Should initiate proactive discussions with CORs and program offices.
- Business Development VPs (within 12 hours)—Need to understand strategic implications for HHS pipeline, assess competitive positioning against firms with stronger AI governance capabilities, and evaluate teaming opportunities with AI compliance specialists.
- Chief Technology Officer / Chief AI Officer (within 24 hours)—Must review enterprise AI architecture standards to ensure HHS solutions can scale to high-impact requirements without redesign. Should assess reusable compliance artifact investments (bias testing, explainability frameworks) that work across all agencies.
- Contracts and Compliance Directors (within 24 hours)—Need to prepare for potential contract modification negotiations, assess cost impact of reclassification scenarios, and develop compliance upgrade roadmaps for existing HHS AI deliverables.
First 48-Hour Playbook:
Hour 0-4: Capture managers identify all active HHS AI pursuits and contracts in pipeline. Pull current AI use case descriptions, impact classifications, and compliance narratives. Flag any deliverables that would be classified as high-impact under DHS/DOJ/VA standards. Brief executive leadership on exposure scope.
Hour 4-12: Proposal directors convene rapid response team to update compliance matrices and win themes. Pull NIST AI RMF documentation and OMB M-24-10 minimum practices. Cross-reference HHS solicitation language against DHS/DOJ/VA AI requirements to identify governance gaps. Update Proposal Studio libraries with dual-standard compliance approaches.
Hour 12-24: Program managers with active HHS AI contracts conduct technical audits of current deliverables. Document existing risk management practices, bias testing protocols, human oversight mechanisms, and explainability features. Prepare gap analysis comparing current state to high-impact requirements. Draft proactive compliance upgrade proposals for COR discussion.
Hour 24-48: Business development initiates outreach to HHS program offices on active pursuits. Ask clarifying questions about AI risk assessment methodology, impact classification criteria, and anticipated policy changes. Position firm as proactive governance partner. Simultaneously, assess competitive intelligence—which competitors have multi-agency AI governance experience? Evaluate teaming opportunities to fill capability gaps. Update capture plans with reclassification risk mitigation strategies.
Related Resources:
- Secure Operations Guide (/insights/secure-operations-guide) — Framework for managing compliance changes across active contracts
- CMMC (Cybersecurity Maturity Model Certification) Compliance Guide (/insights/cmmc-compliance-guide) — Risk-based compliance methodology applicable to AI governance
- CUI (Controlled Unclassified Information)-Safe CRM Guide (/insights/cui-safe-crm-guide) — Data handling protocols for AI systems processing sensitive information
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