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Jessica Tillipman

@jtillipman.bsky.social
137 followers 80 following 101 posts

Associate Dean for Government Procurement Law Studies | Expert in Anti-Corruption, AI Governance & Public Sector Integrity | GW Law

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Jessica Tillipman @jtillipman.bsky.social · 11/08/2026
Thank you!
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Jessica Tillipman @jtillipman.bsky.social · 11/08/2026
Writing an aspirational AI policy goal is easy; operationalizing it is not.
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Jessica Tillipman @jtillipman.bsky.social · 11/08/2026
What can AI vendors learn from federal AI use? A lot more than people realize.
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Jessica Tillipman @jtillipman.bsky.social · 11/08/2026
If your commercial AI agreement promises to “not train on your data,” how does it define “train” and how does it define “data?”
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Jessica Tillipman @jtillipman.bsky.social · 11/08/2026
The challenge of defining AI data rights.
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Jessica Tillipman @jtillipman.bsky.social · 11/08/2026
AI “regulation by contract” becomes the de facto governance mechanism when neither Congress nor the executive branch acts.
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Jessica Tillipman @jtillipman.bsky.social · 11/08/2026
My new article for @lawfare addresses this challenge, why defining these things is hard, and what it takes to turn an AI governance goal into an enforceable procurement obligation. www.lawfaremedia.org/article/the-...
lawfaremedia.org
The Most Important Phrase in GSA’s Revised AI Clause Has No Definition
The revision fixed much of the first draft’s overreach, but the clause still doesn’t say where the government’s data protections begin and end.
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Jessica Tillipman @jtillipman.bsky.social · 11/08/2026
“We don’t train on your data” promises far less than most people assume. The federal government is trying to write a contract clause that addresses what AI vendors can learn from federal AI use. 🧵
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Reposted by Jessica Tillipman
Lawfare @lawfaremedia.org · 11/08/2026
The GSA's proposed data protections clause for AI usage, which includes what government use of AI reveals, doesn’t say where these protections begin and end. The next revision must define what “government usage context” means in practice for effective implementation, writes @jtillipman.bsky.social.
lawfaremedia.org
The Most Important Phrase in GSA’s Revised AI Clause Has No Definition
The revision fixed much of the first draft’s overreach, but the clause still doesn’t say where the government’s data protections begin and end.
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Jessica Tillipman @jtillipman.bsky.social · 25/06/2026
Fraud enforcement is essential, but you cannot task-force your way out of a fraud problem. That was my message when I testified before the U.S. Congress Joint Economic Committee today on Medicare and Medicaid fraud. My opening statement below. youtu.be/gsWnQXWnvEI?...
youtu.be
Associate Dean Jessica Tillipman testifies before the U.S. Congress, Joint Economic Committee
YouTube video by GW Law Government Procurement Law Program
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Reposted by Jessica Tillipman
Lawfare @lawfaremedia.org · 23/06/2026
Despite the fact that the Trump administration's new AI executive order goes out of its way to say that its frontier-model evaluation framework is voluntary, AI companies have indicated they would comply. @jtillipman.bsky.social explains why.
lawfaremedia.org
‘Voluntary’ Until the Government Is Your Customer
The new AI executive order disclaims a licensing mandate. Federal procurement can impose one anyway.
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Jessica Tillipman @jtillipman.bsky.social · 29/03/2026
If the government can brand a contractor a national security threat for refusing to accept contract terms, every federal contract negotiation becomes existential. jessicatillipman.com?p=2260
jessicatillipman.com
Blacklisting by Tweet Is Not a Thing: What the Federal Contracting Rules Require When Firing a Contractor (Like a Dog)
“I don’t know if it’s murder, but it looks like an attempt to cripple Anthropic. And specifically, my concern is whether Anthropic is being punished for criticizing the government’s contracting positi...
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Jessica Tillipman @jtillipman.bsky.social · 29/03/2026
You cannot blacklist a federal contractor by tweet. The government had lawful tools for ending its relationship with Anthropic. It did not use them. cc @alanrozenshtein.com for the companion piece.
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Jessica Tillipman @jtillipman.bsky.social · 19/03/2026
Less than two weeks ago, GSA proposed a new AI procurement clause for federal AI procurements. The clause gets the governance problem right, then blows right past it. My new piece in @lawfaremedia.org: www.lawfaremedia.org/article/the-...
lawfaremedia.org
The GSA’s Draft AI Clause Is Governance by Sledgehammer
The General Services Administration’s draft AI clause gets the governance problem right—then blows right past it.
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Jessica Tillipman @jtillipman.bsky.social · 19/03/2026
Just to be clear, this is not how our procurement system was designed to work.
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Jessica Tillipman @jtillipman.bsky.social · 19/03/2026
Ok, so let's take them at their word that the post was just the beginning. This means that the Secretary publicly announced the outcome, directed his subordinates to produce the justification, and the justification confirms the predetermined conclusion.
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Jessica Tillipman @jtillipman.bsky.social · 19/03/2026
The government's own brief concedes the sequence, arguing that the Secretary's social media post was not final agency action but merely "the beginning" of the process.
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Jessica Tillipman @jtillipman.bsky.social · 19/03/2026
But here they bypassed all of that. The President tweeted, then the Secretary tweeted, then the Department reverse-engineered an administrative record to backfill the justification.
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Jessica Tillipman @jtillipman.bsky.social · 19/03/2026
The government has long understood that excluding a contractor can have severe consequences. That's why we call it the corporate death penalty.
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Jessica Tillipman @jtillipman.bsky.social · 19/03/2026
It includes notice to the contractor, an opportunity to respond, a debarring official who is insulated from political pressure, findings based on grounds specified in the regulation, and judicial review.
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Jessica Tillipman @jtillipman.bsky.social · 19/03/2026
FAR 9.4 covers this situation. If the government believes a contractor is not responsible (i.e., it can't be trusted to perform reliably or poses a risk to government interests), there is a detailed, decades-old framework: suspension and debarment. jessicatillipman.com/u-s-federal-pr…
jessicatillipman.com
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Jessica Tillipman @jtillipman.bsky.social · 19/03/2026
No one is saying the government can't decide to stop contracting with Anthropic. It obviously can. The issue is that we have tools in our procurement system to exclude contractors, and blacklisting by tweet isn't one of them.
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Jessica Tillipman @jtillipman.bsky.social · 18/03/2026
My latest essay in Lawfare: www.lawfaremedia.org/article/the-...
lawfaremedia.org
The GSA’s Draft AI Clause Is Governance by Sledgehammer
The General Services Administration’s draft AI clause gets the governance problem right—then blows right past it.
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Jessica Tillipman @jtillipman.bsky.social · 18/03/2026
It's that GSA is doing so after months of policy statements pointing in the opposite direction, through a commercial channel, with a clause that reads like too many competing agendas forced into a single instrument.
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Jessica Tillipman @jtillipman.bsky.social · 18/03/2026
Less than two weeks ago, @USGSA proposed a new AI procurement clause for federal AI procurements. The clause gets the governance problem right, then blows right past it. What's striking is not that the government is finally building governance into AI acquisition.
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Reposted by Jessica Tillipman
Lawfare @lawfaremedia.org · 18/03/2026
The GSA correctly identifies the governance gaps in federal AI procurement as an issue to be addressed but its proposed contract clause tries to do too much at once through the wrong channel, writes @jtillipman.bsky.social.
lawfaremedia.org
The GSA’s Draft AI Clause Is Governance by Sledgehammer
The General Services Administration’s draft AI clause gets the governance problem right—then blows right past it.
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Reposted by Jessica Tillipman
Lawfare @lawfaremedia.org · 11/03/2026
"Although the public debate has framed this as a fight over whether the Pentagon or Silicon Valley controls military AI, the deeper problem is structural: a procurement framework carrying questions it was never designed to answer," writes @jtillipman.bsky.social.
lawfaremedia.org
Military AI Policy by Contract: The Limits of Procurement as Governance
Over the past year, the United States has moved toward an AI governance model that is flexible yet profoundly inadequate: regulation by contract.
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Reposted by Jessica Tillipman
GW Law Government Procurement Law Program @gwlawgovcon.bsky.social · 11/03/2026
Dean Jessica Tillipman has published an essay for @lawfaremedia.org about the Anthropic / Pentagon / OpenAI story, and asks: why are rules on surveillance, autonomous weapons, and intelligence oversight being made through contracts in the first place? www.lawfaremedia.org/article/mili...
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Jessica Tillipman @jtillipman.bsky.social · 10/03/2026
In my new essay for @lawfaremedia.org, I analyze the OpenAI-Pentagon agreement and what the language actually constrains. The larger question: why is surveillance, autonomous weapon, and intelligence policy being decided through contracts? www.lawfaremedia.org/article/mili...
lawfaremedia.org
Military AI Policy by Contract: The Limits of Procurement as Governance
Over the past year, the United States has moved toward an AI governance model that is flexible yet profoundly inadequate: regulation by contract.
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Reposted by Jessica Tillipman
Lawfare @lawfaremedia.org · 10/03/2026
The public debate has framed the Anthropic-DOD fight as a struggle between the Pentagon or Silicon Valley over control of military AI. But the deeper problem is a structural one, argues @jtillipman.bsky.social.
lawfaremedia.org
Military AI Policy by Contract: The Limits of Procurement as Governance
Over the past year, the United States has moved toward an AI governance model that is flexible yet profoundly inadequate: regulation by contract.
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Jessica Tillipman @jtillipman.bsky.social · 02/03/2026
Thank you!
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Jessica Tillipman @jtillipman.bsky.social · 01/03/2026
Can AI companies restrict government use of their technology? They do it all the time. Whether and how depends on the acquisition pathway, contract type, and terms. My explainer: jessicatillipman.com/what-rights-... #Anthropic #openai #pentagon #DoD #govcon
jessicatillipman.com
What Rights Do AI Companies Have in Government Contracts?
The Anthropic-Pentagon debate has produced a lot of commentary and very little procurement literacy. Can AI companies restrict government use of their technology? They do it all the time. Whether and ...
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Jessica Tillipman @jtillipman.bsky.social · 25/02/2026
The bigger issue here is that it waters down these designations. They are transforming what is designed to be national security tools into a point of leverage for business.” (2/2)
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Jessica Tillipman @jtillipman.bsky.social · 25/02/2026
I talked to the NYT about the Pentagon / Anthropic dispute. “The Pentagon knows they are issuing an extreme threat. They are using every button or lever they have….. (1/2) www.nytimes.com/2026/02/24/u...
nytimes.com
Pentagon Gives A.I. Company an Ultimatum
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Jessica Tillipman @jtillipman.bsky.social · 23/02/2026
The Pentagon v. Anthropic. “Any lawful use” contract language can sound wonky and niche to most people, but it has huge consequences as evidenced by this current impasse. I addressed this topic and more with Sam Lee on his podcast below. youtu.be/fPiUVXsJl1k?...
youtu.be
The Pentagon is taking on Anthropic, says GW Dean Jessica Tillipman
YouTube video by GovCon Intelligence
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Reposted by Jessica Tillipman
Bridget Dooling @bridgetdooling.bsky.social · 13/02/2026
@jtillipman.bsky.social: "complex challenges arise when [AI tools] extend into discretionary functions, including core evaluative tasks, that federal procurement doctrine presumes a human decision-maker will perform." www.yalejreg.com/nc/abdicated...
yalejreg.com
Abdicated Judgment: AI Tools and the Future of Reasoned Decision-Making in Federal Procurement, by Jessica Tillipman - Yale Journal on Regulation
Federal agencies are rapidly expanding their use of artificial intelligence (AI) in government procurement. Much of the public discussion has centered on relatively narrow applications, such as tools ...
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Jessica Tillipman @jtillipman.bsky.social · 17/02/2026
Federal agencies are adopting AI evaluation tools without asking whether the awards will survive protest scrutiny. It was a privilege to contribute to @YaleJREG’s symposium on AI and the APA: www.yalejreg.com/nc/abdicated...
yalejreg.com
Abdicated Judgment: AI Tools and the Future of Reasoned Decision-Making in Federal Procurement, by Jessica Tillipman - Yale Journal on Regulation
Federal agencies are rapidly expanding their use of artificial intelligence (AI) in government procurement. Much of the public discussion has centered on relatively narrow applications, such as tools ...
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Jessica Tillipman @jtillipman.bsky.social · 22/01/2026
AI procurement has a hidden supply chain. Most public-sector procurement teams never see it. In this piece, I explain why I use a wedding cake as a risk-identification tool for procurement stakeholders. 🔗 Read it here: jessicatillipman.com/why-a-weddin...
jessicatillipman.com
Why a Wedding Cake? Mapping AI’s Hidden Procurement Supply Chain - Jessica Tillipman
Explore the complexities of procurement for AI systems and the risks of buying blind in the contracting process.
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Reposted by Jessica Tillipman
GW Law Government Procurement Law Program @gwlawgovcon.bsky.social · 20/01/2026
The latest volume of the SSRN Public Procurement, Government Contracts & Outsourcing eJournal, sponsored by the GW Law Government Procurement Law Program, is now available. 🔗 Read it here: hq.ssrn.com/journals/Vie...
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Jessica Tillipman @jtillipman.bsky.social · 19/01/2026
Despite the current narrative framing the program as “fraud-filled,” “fraud” under US law requires proof of intent, determined only through judicial process. The audit can identify leads and make referrals, but can’t determine fraud.​​​​​​​​​​​​​​​​ Read more: jessicatillipman.com/testimony/ (2/2)
jessicatillipman.com
Testimony - Jessica Tillipman
Congressional Testimony Congressional Testimony on Government Procurement and Public Integrity  Issues Past Testimony
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Jessica Tillipman @jtillipman.bsky.social · 19/01/2026
Today’s the deadline for submission of documents in response to the @SBAgov’s 8(a) audit. A friendly reminder—here are the categories of things the audit may find: • Documentation deficiencies • Administrative errors • Eligibility violations • Waste/mismanagement (1/2)
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Jessica Tillipman @jtillipman.bsky.social · 17/01/2026
With Hegseth’s announcement that he plans to “take a sledgehammer” to the 8(a) contracting program, here’s the link again to my recent Senate testimony on the subject.
papers.ssrn.com
Running Government Like a Small Business: Cut Waste, Crush Fraud, Hearing Before the United States Senate Committee on Small Business and Entrepreneurship
This testimony analyzes the 2025 Small Business Administration "audit" of the 8(a) Program within the broader federal procurement integrity framework,
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Jessica Tillipman @jtillipman.bsky.social · 15/01/2026
The United States is accelerating toward a corruption crisis of its own making. My new article, "Buying Blind: Corruption Risk and the Erosion of Oversight in Federal AI Procurement," is now available (forthcoming, Public Contract Law Journal, Vol. 55, No. 2): jessicatillipman.com/buying-blind...
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Reposted by Jessica Tillipman
GW Law Government Procurement Law Program @gwlawgovcon.bsky.social · 15/01/2026
On December 10, Associate Dean Jessica Tillipman submitted testimony for the record to the U.S. Senate Committee on Small Business and Entrepreneurship following the Committee’s hearing, “Running Government Like a Small Business: Cut Waste, Crush Fraud.” 🔗 Link: papers.ssrn.com/sol3/papers....
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Jessica Tillipman @jtillipman.bsky.social · 31/12/2025
Fraud is in the News Again. Here’s the Bigger Picture. I shared this resource back in February, but with fraud and government spending dominating the headlines, now seems like a good time to revisit it. jessicatillipman.com/fraud-is-in-...
jessicatillipman.com
Fraud is in the News Again. Here's the Bigger Picture. - Jessica Tillipman
I shared this resource back in February, but with fraud and government spending dominating the headlines, now seems like a good time to revisit it.
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Jessica Tillipman @jtillipman.bsky.social · 10/06/2025
My new piece, "The Cost of a Lie," which addresses the recent Kousisis decision, is now available: www.gwlr.org/kousisis-the... Kousisis is a notable departure from recent SCOTUS decisions that have narrowed the scope of fraud and corruption statutes in the United States.
gwlr.org
The Cost of a Lie: Kousisis Affirms Criminal Fraud Liability Without Economic Harm
June 10, 2025 Kousisis et al. v. United States, 605 U.S. ____, 145 S. Ct. 1382 (2025) (Barrett, J.) Response by Jessica Tillipman Geo. Wash. L. Rev. On the Docket (Oct. Term 2024) Slip Opinion | SCOTU...
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Jessica Tillipman @jtillipman.bsky.social · 05/06/2025
Yep - it always comes back to culture. I think the Gov’t has a lot more tools on the audit and oversight side, but the private sector is light years ahead on compliance best practices.
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Jessica Tillipman @jtillipman.bsky.social · 05/06/2025
New GAO report is highly critical of DOD’s anti-fraud efforts: “DOD leadership has not demonstrated a strong commitment to fraud risk management.”
t.co
https://www.gao.gov/products/gao-25-108500
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Jessica Tillipman @jtillipman.bsky.social · 29/05/2025
I’m providing an introduction to procurement fraud and the false claims act today at 1 PM eastern time. It’s free and virtual -registration information below.
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Jessica Tillipman @jtillipman.bsky.social · 27/05/2025
Interested in learning more about fraud in government spending? I am happy to be partnering again with DAU to teach their Summer Law Series. All 5 virtual sessions are free and open to the public and the first session kicks off this Thursday with fraud. Registration info below 👇
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