Advisory Note | Beyond Procurement: Redefining Governance as Stewardship
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Advisory Notes distill complex governance concepts into clear, actionable insights for leaders navigating institutional change. They connect frameworks, sector trends, and regulatory context to the architectural conditions that make oversight real and reviewable.
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Governance Is Not Procurement
In many institutions, “governance” is confined to procurement—contracts, clauses, RFPs, and vendor assessments standing in for diligence. Useful, yes; sufficient, no.
When governance is reduced to buying decisions, leaders manage transactions instead of designing systems. Accessibility becomes a checkbox, AI risk a contract clause, and privacy a policy upload. The result: compliance without capability.¹
Governance is not a purchasing function; it is the framework through which organizations translate values into decisions and accountability. Procurement supports that framework but does not define it. As the National Institute of Standards and Technology (NIST) explains, “governance functions establish the organizational policies, processes, and accountability structures that enable the AI lifecycle to be trustworthy.”¹ OMB’s 2024 governance directive reinforces this distinction, noting that “effective governance requires integrating risk management and internal control into agency decision-making, performance management, and oversight structures.”² When governance is reduced to transactions, organizations lose the ability to coordinate risk, align decisions, or demonstrate accountability across systems.
Procurement ≠ Governance
Procurement is a function of governance, not its frame.
Governance sets direction, ensures coherence, and sustains accountability across relationships and operations. It is the structure that gives procurement purpose.
Lexicon Hierarchy
Governance — The organizing framework for trust and accountability.
Stewardship — The sustaining culture of responsibility and transparency.
Alignment — The integration of values—accessibility, equity, privacy—into systems.
Procurement — The transactional mechanism for acquisition and partnership.
Procurement is where governance becomes visible, but governance gives it coherence. Maryland’s Procurement Advisor underscored this principle, observing that “a procurement culture focused on stewardship, transparency, and best value requires continuous improvement and cross-agency collaboration.”³
From Compliance to Culture
Effective governance does not end with rule adherence—it begins there. Compliance establishes order, but culture sustains it. Governance matures when institutions move from verifying actions to internalizing accountability.
That shift requires structure. Policies must translate into routines: training cycles, feedback loops, and performance measures that make accountability visible. When these mechanisms operate predictably, responsibility becomes habit rather than exception.
Stewardship bridges compliance and culture. It replaces one-time attestations with ongoing reflection—asking not only “Did we meet the requirement?” but “Did the process achieve the accountability it promised?” Procurement tracks transactions; stewardship monitors integrity. Over time, this reflex reshapes how teams design, decide, and communicate.
The risks of limiting accountability to procurement are well documented. As Schooner and Tillipman observe in their analysis of federal acquisition systems, “when agencies lack the professional capacity to manage what they purchase, the risks to oversight, performance, and accountability increase.”⁴ Compliance without capability is not governance—it is fragility disguised as order.
Operational Stewardship in Practice
Governance matures when principles become practice. Operational stewardship is where leadership decisions take shape in frameworks and partnerships that sustain accountability over time.
Frame expectations early.
Connect incentives across partners.
Reinforce continuity, not compliance.
When these principles are embedded, oversight transforms into trust. Institutions design for resilience rather than react to risk.
Operational stewardship turns governance from a checklist into a system of continuity. The language leaders use to describe that system determines how it endures.
Why Language Matters
Governance depends on clarity—how leaders define responsibility determines how institutions practice it. When accountability is framed in procurement terms, attention narrows to transactions. When expressed through the language of stewardship, it signals that responsibility is continuous and shared.
Language directs behavior. Words such as review or approval can confine governance to oversight; terms like alignment or continuity invite collaboration and learning. Each choice shapes how teams interpret their roles and how systems adapt under pressure.
Clear language makes structure visible. It sets expectations, reduces ambiguity, and enables verification. NACUBO’s 2025 State of Higher Education report captures this shift, noting that business officers are now expected to “lead with purpose—aligning finance, technology, and mission to sustain long-term institutional trust.”⁵ In that sense, communication is itself a governance mechanism—a tool that organizes accountability across functions. Institutions that speak precisely about responsibility act predictably under scrutiny.
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Sources & Citations
¹ Nat’l Inst. of Standards & Tech., Artificial Intelligence Risk Management Framework 1.0 (2023), https://nvlpubs.nist.gov/nistpubs/ai/nist.ai.100-1.pdf.
² Off. of Mgmt. & Budget, M-24-18: Advancing Governance, Risk Management, and Internal Control in Federal Agencies (Nov. 2024), https://www.whitehouse.gov/wp-content/uploads/2024/10/M-24-18-AI-Acquisition-Memorandum.pdf.
³ Procurement Advisor to the Md. Bd. of Pub. Works, FY 2023 Procurement Advisor’s Report (2023), https://bpw.maryland.gov/Publications/FY2023%20Procurement%20Advisor%27s%20Report_FINAL.pdf.
⁴ Tillipman, Jessica and Schooner, Steven L., FEATURE COMMENT: Institutional Amnesia And The Neglect Of The Federal Acquisition Workforce (July 30, 2025). 67 GC ¶ 182 (July 2025), GWU Legal Studies Research Paper 2025-40, GWU Law School Public Law Research Paper 2025-40, Available at SSRN: https://ssrn.com/abstract=5374044 or http://dx.doi.org/10.2139/ssrn.5374044.
⁵ Nat’l Ass’n of Coll. & Univ. Bus. Officers (NACUBO), State of Higher Education 2025, https://www.nacubo.org/Advocacy/State-of-Higher-Education.
TL Advisory references independent academic and policy research for contextual illustration; findings cited here have not been independently verified. This publication reflects the professional judgment and authorship of TL Advisory. All analysis and interpretation are the product of human expertise, supported by structured editorial review.