Cognitive Safety Standards for AI in K-12 Education: FAS Policy Sprint Submission

Developed and submitted a policy memo to the Federation of American Scientists (FAS) Policy Sprint: Source Code: Building an AI Trust and Fairness Policy Agenda, a competitive initiative in collaboration with the Kapor Foundation to advance evidence-based proposals for fair and trustworthy AI governance.

The memo addresses structural educational inequity created when students from under-resourced communities develop AI dependency during critical developmental windows (ages 11–17), while privileged peers receive human support teaching strategic AI use. Drawing on metacognitive research, developmental psychology, and existing regulatory frameworks, the proposal targets state departments of education and state legislatures as the primary policy audience, which is particularly urgent given the Department of Education's November 2025 announcement transferring K-12 programs to the Department of Labor.

The memo presents three actionable recommendations: (1) state certification programs for educational AI tools requiring metacognitive prompts, transparency mechanisms, verification checkpoints, and reflection protocols; (2) procurement leverage tying state education funding to cognitive safety certification, paired with curriculum integration embedding critical thinking for AI use into existing standards through protocols like "3 Before AI" and if-then planning; and (3) industry transparency and disclosure requirements with ongoing state-level monitoring. Implementation builds on existing state authority including textbook adoption processes, COPPA/FERPA precedent, and procurement mechanisms, requiring no new federal legislation or agencies.

Framework: Builds on the CTRL+Think K-12 AI Literacy Framework, applying cognitive and developmental psychology principles to responsible AI use in schools

Link: FAS Policy Sprint Submission

  • Policy levers: State procurement rules, certification standards, curriculum mandates, FTC oversight, multi-state coordination through SETDA

  • Evidence base: Metacognitive intervention research (Education Endowment Foundation, Diamond, Stanton et al.), cognitive offloading studies (Gerlich, Kosmyna, Shalaby), implementation intention research (Gollwitzer & Sheeran), adolescent metacognitive development (Weil et al.)

  • Relevant context: 70%+ of teens now use generative AI (Common Sense Media, 2024), 20+ states actively drafting AI education legislation (McCann, 2025), federal education oversight in transition

  • Skills demonstrated: Policy analysis, regulatory framework design, evidence synthesis, stakeholder mapping, educational governance, AI literacy curriculum development

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