Using Generative AI for Stance Analysis of Public Comments on CDC’s Proposed Rules

Section 1: Use Case Identifiers

Use Case ID: HHS-CDC-00025
Agency: HHS
Op Div/Staff Div: CDC
Use Case Topic Area: Mission-Enabling (internal agency support)
Is the AI use case found in the below list of general commercial AI products and services?
None of the above.
Describe the AI system's outputs.
Reviewing the public comments currently involves a manual review process that necessitates a high level of time and effort on the part of regulatory analysts. To improve the process of reviewing public comments as part of regulatory analysis, our team implemented topic modeling (Grootendorst et al., 2022) and sentiment analysis (Hartman et al., 2023) of comments published to the new amendment to foreign quarantine regulation published by CDC on July 10, 2023. This solution expands these efforts by using generative AI models to try for capture stance expressed in each comment. While there is also an option to manually label and train models for stance detection, custom-trained text classification models may not be transferable to future rules due to rule-specific discussions and arguments. In contrast, using generative AI models for stance detection can be transferable to future rules irrespective of the discussion contexts and arguments.
Stage of Development: Implementation and Assessment
Is the AI use case rights-impacting, safety-impacting, both, or neither?
Neither

Section 2: Use Case Summary

Date Initiated: 07/2023
Date when Acquisition and/or Development began: 07/2023
Date Implemented: N/A
Date Retired: N/A
Was the AI system involved in this use case developed (or is it to be developed) under contract(s) or in-house?
Developed in-house.
Provide the Procurement Instrument Identifier(s) (PIID) of the contract(s) used.
N/A
Is this AI use case supporting a High-Impact Service Provider (HISP) public-facing service?
N/A
Does this AI use case disseminate information to the public?
No
How is the agency ensuring compliance with Information Quality Act guidelines, if applicable?
N/A
Does this AI use case involve personally identifiable information (PII) that is maintained by the agency?
No
Has the Senior Agency Official for Privacy (SAOP) assessed the privacy risks associated with this AI use case?
ongoing

Section 3: Data and Code

Do you have access to an enterprise data catalog or agency-wide data repository that enables you to identify whether or not the necessary datasets exist and are ready to develop your use case?
No
Describe any agency-owned data used to train, fine-tune, and/or evaluate performance of the model(s) used in this use case.
NA
Is there available documentation for the model training and evaluation data that demonstrates the degree to which it is appropriate to be used in analysis or for making predictions?
Documentation is missing or not available
Which, if any, demographic variables does the AI use case explicitly use as model features?
N/A
Does this project include custom-developed code?
Yes
If the code is open-source, provide the link for the publicly available source code.
N/A

Section 4: AI Enablement and Infrastructure

Does this AI use case have an associated Authority to Operate (ATO) for an AI system?
No
System Name: N/A
How long have you waited for the necessary developer tools to implement the AI use case?
Less than 6 months
For this AI use case, is the required IT infrastructure provisioned via a centralized intake form or process inside the agency?
Yes
Do you have a process in place to request access to computing resources for model training and development of the AI involved in this use case?
Yes
Has communication regarding the provisioning of your requested resources been timely?
Yes
How are existing data science tools, libraries, data products, and internally-developed AI infrastructure being re-used for the current AI use case?
Use of existing data platforms
Has information regarding the AI use case, including performance metrics and intended use of the model, been made available for review and feedback within the agency?
Limited documentation for review