In August, the US Department of Education released new guidance calling on states and districts to evaluate technology based on three conditions: whether it has clear instructional purpose; whether it is supported by evidence; and whether it is shown to improve student outcomes. The guidance provides new direction from the federal level to a rapidly changing technology landscape, while reinforcing the central role states and districts play in determining how technology is selected, governed, and used in schools.

The leadership role states must play is particularly visible in the response to AI. Over the past three years, state boards of education and state education agencies across the country have been defining what leadership on AI policy looks like and determining how best to support schools and districts as AI continues to evolve and become integrated into teaching, learning, and system operations.

At FullScale, we used this moment to look across three years of state AI guidance and ask: What do three years of state AI guidance reveal about the evolving role of state leadership?

Looking Across State Guidance

To answer this question, we identified 37 state-level AI guidance documents from state boards of education and state education agencies. Rather than cataloging individual recommendations, we conducted a cross-document thematic analysis to identify the underlying questions states were trying to answer, the challenges they were seeking to solve, and the functions their guidance served. We used Gemini’s NotebookLM to support an initial synthesis, and then subsequently reviewed, verified, and refined every finding.

While individual guidance documents vary considerably in scope, structure, and intended audience, they consistently reflect three distinct ways states support AI adoption across K–12 education:

• Building foundational awareness, helping educators and school systems develop a shared understanding of AI, its opportunities, and its limitations. 
• Establishing governance, providing policies, expectations, and guardrails that support responsible implementation. 
• Enabling early exploration, giving educators and local leaders resources and opportunities to begin integrating AI into teaching, learning, and system operations.

These functions do not represent stages of implementation or a prescribed sequence for action. Instead individual guidance documents frequently address multiple functions simultaneously, reflecting the complementary roles states play as they support AI adoption across their education systems.

Building Foundational Awareness

Before schools and districts can develop policies, adopt AI tools, or redesign instructional practice, they first need a shared understanding of what AI is, where it can create value, and the risks it introduces. Across the state guidance we reviewed, one of the most consistent functions involved helping local leaders build that foundation. States frequently defined key concepts, curated implementation resources, and framed conversations about AI’s opportunities, risks, and potential role in K–12 education.

California’s Department of Education illustrates this function through its guidance, “Guidance for the Safe and Effective Use of Artificial Intelligence in California Public Schools.” California advocates for embedding AI literacy across all core content areas. To help local districts build a shared conceptual framework, the department details a clear progression for student AI literacy that maps out classroom goals for grades TK-12. This recommendation is supported by encouraging districts to offer professional learning that equips administrators, teachers, and staff to model safe, thoughtful and transparent AI use. 

Establishing Governance

As schools and districts begin implementing AI, they face practical questions that extend well beyond understanding the technology. Decisions about acceptable use, privacy, procurement, academic integrity, and long-term oversight require structures that guide responsible use while aligning with broader educational priorities. Across the state guidance we reviewed, states frequently addressed these challenges by providing implementation frameworks, establishing governance processes, aligning AI use with existing state priorities, and giving local leaders practical tools and resources.

Massachusetts’ Department of Elementary and Secondary Education illustrates this function  through a comprehensive approach that extends beyond a single guidance document. Following recommendations from a statewide AI task force, the department developed implementation resources, established legal and policy considerations for AI use, and outlined practical steps districts can use to translate state guidance into local practice. The department continues to support governance as technologies, local uses, and questions surrounding them develop.

Enabling Early Exploration

As schools and districts begin integrating AI into teaching and learning, they face practical decisions that guidance documents alone cannot resolve. Across the state guidance we reviewed, many states help local leaders explore AI in practice by highlighting early use cases, providing implementation supports, creating opportunities for local experimentation, and sharing examples of how districts approach the technology.

The Kentucky Department of Education’s guidance illustrates this function by encouraging districts to explore AI while maintaining local flexibility. Its guidance emphasizes AI’s potential to transform education and the workforce while leaving implementation decisions to local leaders. Since 2023, the department has also published annual feedback from districts describing how they use AI across the state, making local experiences visible and providing a window into how adoption unfolds across different contexts.

Looking Ahead: The Next Opportunity for State Leadership

Three years of state guidance have created important foundations for AI adoption. States have helped schools and districts build shared understanding, establish governance structures, and create opportunities for early exploration while respecting local control. These contributions matter and schools and districts will continue to need them.

Guidance, however, tells us far less about what happens when AI reaches classrooms, schools, and district offices. Educators and leaders must translate statewide frameworks into practice across different instructional, operational, and community contexts. Best practices continue to emerge, and implementation generates new questions, evidence, and knowledge. Guidance can establish expectations, provide frameworks, and create space for explorations, but states, districts, and educators still need to determine what works, for whom, and under what conditions.

Accelerating System Learning

As schools and districts generate new knowledge through AI implementation, states have an opportunity to help that learning travel beyond the places where it first occurs. States can connect educators, surface emerging evidence, and make promising practices visible across contexts, reducing the need for local leaders to navigate similar challenges in isolation.

Several states already demonstrate elements of this approach. North Carolina has complemented its implementation guidance with ongoing webinars, communities of practice, and statewide learning opportunities that help educators share lessons from practice. Connecticut uses statewide AI pilot programs to generate lessons that can inform future guidance. Meanwhile, the New York Artificial Intelligence Consortium brings together educators, researchers, and technology leaders to develop resources collaboratively, share implementation experiences, and identify promising practices across the field.

These are early efforts, and states, districts, and educators still have much to learn about effective AI implementation across different schools and communities. That uncertainty makes the learning emerging from local implementation especially valuable. As states continue to refine their approaches to AI, one of the defining functions of state leadership may be helping lessons from individual schools and districts become shared knowledge that strengthens the education system as a whole.