BSA urges GSA to make significant changes to the proposed contractual terms for AI procurement, which impede the federal government's IT modernization efforts and ability to adopt low-cost, AI commercial solutions from a competitive marketplace. BSA's recommendations include: 

• Clarifying the prohibition on foreign AI systems or components;
• Expanding the commercial products exception;
• Expanding contractors' intellectual property rights;
• Revising certain requirements to ensure they are feasible to implement;
• Streamlining disclosure, recordkeeping, and change management requirements; and
• Aligning with existing software acquisition frameworks; and Ensuring sufficient time for implementation.