Statement on Use of Artificial Intelligence (AI) for the Transcription or Recording of Meetings by ED Grantees
The Department is clarifying that the use of AI for the transcription (including the capture of meeting notes) or recording of meetings that are connected to grants supported by the Department is generally permissible unless otherwise precluded by law. However, grantees should be aware of the following considerations:
- Notification: Grantees should notify (1) all attendees via a written and verbal disclaimer that they are enabling the AI transcription or recording of meetings prior to doing so and, (2) attendees of the ways in which the transcription will be used, including if the transcript will be distributed to meeting participants. When meeting participants decline to participate in a meeting that will be transcribed or recorded, grantees may need to find alternative ways to conduct the meeting.
- Accuracy: After an AI-transcribed meeting has ended, grantees should review and appropriately edit the transcript to ensure clarity and accuracy. Grantees should be aware this process can be time- and resource-intensive.
- Distribution: As a good practice, grantees should offer a reviewed and appropriately edited transcript to all meeting participants after the AI-transcribed meeting has ended.
- Agency Requests: Under some circumstances, Department employees may require that an AI recording and/or AI transcription function be disabled for meetings in which Department employees participate (e.g., Department sponsored meetings with grantees or Department employees declining to participate in recorded meetings sponsored by grantees, applicants, or other non-Department entities).
- Records Retention: Any transcript or other related records generated by AI (including original and edited transcripts) in a meeting supported by Department grant funds must be retained as grant records per 2 CFR § 200.334 for a period of at least three years following the submission of the final performance report of the grant.
- Privacy: Before using AI transcription or recording services or products, grantees should ensure an appropriate understanding of how data is processed and take appropriate steps to protect confidential or personally identifiable information. Generally, meeting participants should avoid discussing personally identifiable information as a safeguard against unauthorized sharing, as well as to make it easier to share the transcripts and to respond to requests to access the transcripts.
For any questions regarding this guidance, please reach out to your project officer.
**Please note: Any Further AI Grants Policy Updates forthcoming will be posted here.