Legal: AI in grants
Below is a summary of GenAI usage guidelines by various governmental agencies.
Aspect |
USDA |
Department of Energy |
NSF |
NEH |
NIH |
Use of AI in Peer Reviews |
Not directly addressed; must comply with Commerce’s AI Risk Framework principles. |
At this time prohibited |
Prohibited |
Prohibited |
Prohibited |
Use of AI to Generate Ideas |
Permissible under responsible use and disclosure requirements or limited specific guidance |
Allowed, must acknowledge AI's role |
Disclosure required if used. Proposers are responsible for ensuring the integrity of their proposal |
Allowed, must acknowledge AI's role |
Responsibility lies with applicant |
Use of AI for Editing |
Permitted with accountability and documentation under risk guidelines |
Encouraged |
Allowed, no required disclosure |
Allowed, cite if substantial AI use |
Allowed |
Citing AI-Created Work |
Required |
Required |
Required |
Required |
Responsibility lies with applicant |
Notes:
- USDA: they use AI models in solving agri problems, there is an inventory of cases. They follow US Dept. of Commerce Risk Mgmt. framework.
- Department of Energy: AI is also seen as a mean to resolve the existing problems under human oversight. “When GenAI solutions play a role in creating an idea, approach, or invention at DOE or a National Laboratory, employees must clearly identify the specific contribution (e.g., attribution in a report, laboratory record, invention disclosure) and cite the GenAI as part of their research methodology”
- NSF: AI is prohibited in peer review but “Proposers are encouraged to indicate in the project description. The extent to which, if any, generative AI technology was used and how it was used to develop their proposal.” Overall, NSF states that they want to first research the extent to which AI is used by the community. Proposer is responsible for ensuring authenticity and accuracy.
- National Endowment for the Humanities: for applicants ensuring that “proposals are fact-based and that they have properly acknowledged and referenced all sources”. Use of AI is permitted but should be acknowledged. However, NEH reserves the right to declare an application ineligible.
- NIH: AI is prohibited in peer review but NIH itself is exploring possibilities to use AI in their internal operations, such as grant management. “While use of AI technologies is not prohibited as you prepare an application, doing so is at your own risk since generative AI could, for example, plagiarize text or fabricate information. This would constitute research misconduct and require actions by NIH to address noncompliance.”
Sources:
https://www.usda.gov/data/AI_Inventory
https://nvlpubs.nist.gov/nistpubs/ai/NIST.AI.100-1.pdf
https://www.neh.gov/sites/default/files/2025-01/NEH.AI_.Policy-10.23.24.pdf
https://grants.nih.gov/grants/guide/notice-files/NOT-OD-23-149.html
https://myresearchpath.duke.edu/updates/nsf-notice-use-generative-ai-proposal-process