5 Lessons From NYC Schools’ New Guidance On Artificial Intelligence

The largest school district in the United States just released AI rules for over one million students. Against a background of parent petitions demanding moratoriums, community boards calling for long-term pauses and a proposal for an AI-focused high school, New York City Public Schools formally released new guidance yesterday.

It could be argued that New York City Public Schools has been slow to act, given that other large school districts, including Chicago, Denver and Charlotte-Mecklenburg, have already released their AI playbooks. But, given New York City’s scale and the political complexity embedded in its public schools, this makes the new AI guidance a test case that schools around the world will be following closely.

Here are five lessons every education leader can take from the newly published guidance and how NYC approached the major issues presented by AI.

Lesson 1: Leading With Prohibition As A Governance Choice

The district’s guidance outlines a new traffic light framework, that firstly focused on what artificial intelligence should not do in their 1,600 schools. They insist that AI should not:

• Make decisions about student placement

• Make decisions about discipline

• Make decisions about promotions

• Make decisions about graduation

• Make decisions about program access

• Be used for developing plans for students with disability (IEPs or 504s)

• Assign grades

• Conduct surveillance or behavioral monitoring

• Provide counseling

It’s not difficult to see why they have given AI these boundaries. The decisions made by AI in the use cases outlined could have huge implications on a student’s school experience and consequently be life-changing. Keeping the human, who hopefully knows and cares for the individual student, at the center is a wise move.

From the outset of the new guidance, it is clear that NYC Public Schools is leading with a risk-averse approach. This is not just a formatting choice in their documentation, but is a clear governance strategy. While some may want schools to prioritize the benefits of AI in education, when it comes to protecting children, safety must always come first.

Many school leaders are faced with a spectrum of feelings from their educators, students, parents, board and community. But, when there is anxiety and when trust is low, everyone needs to know what’s off the table before they can meaningfully engage with the benefits of this new technology.

Last month, I led a workshop with parents from a school in New York City and witnessed this spectrum of feelings. Parents want reassurance that their school is taking control, keeping their child safe and preparing them for this new AI world. Skipping this step keeps the community in the dark and can lead to an appearance of incompetence.

Lesson 2: Separating AI For Teachers From AI For Students

Back to the NYC traffic light framework and the green and yellow use cases of using AI. Green light instances are almost entirely around educator productivity:

• Brainstorming lessons

• Drafting communications

• Scheduling

• Formatting

• Summarizing non-sensitive information

• Translating non-critical materials

The moment the use of AI touches something that could be consequential to a student, the framework moves to yellow:

• Interpreting data

• Translating critical communications

• Supporting diverse learners

These yellow light instances require professional oversight and a qualified review from a human. This is because the risk profile of artificial intelligence shifts dramatically depending on who the output affects. In my experience of working with school districts, many schools allow teachers to use AI for productivity but are afraid to cross the line of letting it be used with students. Staying too risk averse here, could deprive students of gaining the benefits of some AI tools at school.

Lesson 3: Build Compliance Infrastructure Before Deployment

NYC Public Schools is very clear on its expectations of the companies who are supplying artificial intelligence. They introduce a ten-step review called ERMA, and require vendors to sign data processing agreements and pass security reviews. These agreements include the right to revoke the use of an AI tool and penalize the company involved.

For education leaders in small districts, the ten-step process may sound disproportionate, but this fits with a safety-first approach. I have trained hundreds of thousands of educators in the use of AI and it is obvious to me that many educators, who have not been given clear guidance from their leaders, have taken matters into their own hands and used AI independently from their schools to do school work. This can cause complex risks as individual educators use AI that isn’t vetted to process sensitive data and even make decisions about student grades. Clear guidance on institutional AI use from a leadership level is paramount.

Lesson 4: Be Transparent About What You Haven’t Figured Out

What many may find surprising about the NYC Public Schools guidance is its admission that there are unresolved questions. These include issues around:

• Grade-band guidance for different age groups

• Homework and academic integrity

• Cognitive offloading

• Managed vs. personal AI accounts

• Algorithmic bias

• Environmental impact

Furthermore, the ten steps of the ERMA framework themselves don’t yet evaluate for bias, equity impact, or instructional effectiveness.

Having worked closely with education leaders, including some in governments, I believe some of these issues, such as academic integrity and algorithmic bias, can be addressed now and should not be delayed. Guidance may change, but educators need to know where the line is and need training in these issues.

Although I think NYC Public Schools could have done more here, I applaud its transparency. Taking action while not knowing all the answers is a courageous leadership act, and one we desperately need in all corners of education right now. The key is being transparent about the unknowns and being willing to pivot. We need leadership that is comfortable with uncertainty.

Lesson 5: Make Governance A Participation Sport, Not A Publication Event

You would expect a school district as big and complex as NYC would have a multi-layered consultation mechanism, but I think the lesson here is that even the smallest districts or schools should not do this alone.

NYC’s consultations included 25 rounds of feedback with over 1,000 stakeholders, a 76-member Central AI Task Force across multiple divisions, four subcommittees (governance, capacity building, tool evaluation, communications) and an external AI Advisory Council. And it isn’t over yet, as they are currently in a 45-day public comment window through to May 8.

In my experience of helping schools and colleges, most guidance or strategy efforts end in a finished PDF published on a website. The use of AI in education is urgent and so we cannot simply move on once we hit publish. For the school leaders reading this, does your AI policy have an expiry date and a revision mechanism, or does it sit on a shelf?

New York City Public Schools’ guidance is not perfect. But that’s not the point. The impressive part of its efforts is that it is willing to govern in public and that governance is iterative. The districts that will get this right are the ones building systems that can learn and adapt, not the ones publishing definitive answers they don’t have.