Comment on FR Doc # 2026-12205

Cyber Strategy Institute submits this supplemental comment in addition to its July 2026 written comment matrix and oral remarks delivered during the July 14, 2026 GSA listening session. This supplemental filing responds to the developed docket record and provides additional proposed language addressing: 1. The distinction between model development origin and continuing operational control; 2. Treatment of publicly released open-weight models where the original publisher has no contractual privity, Government Data access, operational role, or continuing control; 3. An emergency model-substitution pathway for provider outages, security incidents, deprecations, and Government actions; 4. Allocation of compliance responsibilities according to each supply-chain role’s actual span of control; and 5. A defined evidence package for open-weight and self-hosted deployments. CSI’s central recommendation is that model provenance remain a documented security input, but that eligibility and trust determinations ultimately rely on demonstrable system properties: operational control, Government Data exposure, update authority, network egress, auditability, runtime enforcement, containment, substitution, and recovery. The submission includes: CSI Supplemental Comment, GSAR 552.239-7001, PDF; CSI Supplemental Comment Matrix, XLSX; and CSI Supplemental Comment Matrix, PDF. The spreadsheet and PDF matrix contain identical proposed clause amendments. The spreadsheet is provided for agency analysis and extraction; the PDF is provided as a fixed-format review copy. Submitted by Cyber Strategy Institute Notice-MVAC-2026-01 Docket GSA-GSAR-2026-0331