A Functional Classification Test

Core Principle

A system is classified based on what it does at the moment it delivers content to a student, not how it is labeled, marketed, or implemented.

Part I: Instructional Actor Threshold Test (Binary Gate)

A system is classified as an Instructional Actor if all of the following are true:

1. Generates Novel Content at Runtime

  • Output is not pre-authored or fixed

  • Two students can receive materially different responses to similar prompts

2. Provides Explanatory or Decision-Guiding Content

  • Explains concepts, provides steps, evaluates reasoning, or advises actions

  • Not limited to retrieval or display

3. Lacks Pre-Delivery Institutional Control

  • No human or system acting on behalf of the institution determines the exact output before delivery

4. Influences Student Cognition Across the Interaction

  • Output shapes how the student thinks, reasons, or proceeds

  • Not a passive, bounded tool (e.g., calculator, static reference)

If all four conditions are met → Default classification: Instructional Actor

If any condition is not met → proceed to Part II.

Part II: Tool Qualification Test (All Required)

A system may be classified as a Tool only if it satisfies all of the following:

1. Bounded Output Space

  • Outputs are constrained, predictable, and enumerable

  • Behavior does not materially vary across users beyond defined parameters

2. Pre-Determined or Reviewable Content

  • Content is either pre-authored, or

  • Can be reviewed and approved prior to delivery

3. Full Reconstructability

  • Every interaction can be logged, replayed, and attributed

4. Institutional Control Over Outputs

  • The institution can constrain outputs and prevent disallowed content before delivery

5. Clear Binding of Responsibility

  • A single entity has authority over outputs

  • That entity is contractually and financially responsible

If any condition fails → the system cannot be classified as a Tool

Part III — Conditional Governance Requirements (Hybrid / Transitional Systems)

Core Rule

If a system exhibits any instructional actor characteristics, even partially, it must satisfy the corresponding governance conditions:

1. If the system generates variable or individualized outputs → Attribution + Reconstruction required

  • All interactions must be:

    • logged

    • reconstructable

    • attributable (see definition below)

2. If the system provides explanations, feedback, or guidance → Authority required

  • The institution must:

    • maintain institutional control over outputs at the point of delivery, or

    • restrict use to contexts where outputs are bounded and reviewable

3. If the system behavior is non-deterministic → Constraint required

  • The system must:

    • enforce limits on output behavior

    • prevent disallowed outputs before delivery

4. If outputs can influence student decisions or reasoning → Binding required

  • A responsible entity must:

    • formally accept liability for outputs

    • be contractually and financially accountable

5. If any of the above conditions cannot be met

The system cannot be deployed in student-facing use without elevated governance or reclassification as an Instructional Actor.

Behavior - Requirement

Variability Attribution

Guidance Authority

Non-determinism Constraint

Influence Binding

B. Model Substitution or Upgrade
Underlying system changes (e.g., LLM integration)
Behavior becomes non-deterministic

C. Loss of Reconstructability
Logs become incomplete or unavailable

D. Expansion of Use Case
System begins providing explanations, feedback, or guidance

E. Loss of Binding
Vendor disclaims outputs or no entity retains full responsibility

Part IV: Governance Implications (Non-Optional)

Classification determines required governance.

If Tool

  • Standard instructional governance applies

  • Policy and supervision may be sufficient

If Instructional Actor

The system must satisfy:

  • Attribution — identifiable responsible entity

  • Authority — control at generation

  • Reconstruction — full interaction logging

  • Binding — financial and legal responsibility

If these conditions are not met:

The system is operating as an instructional actor without an accountability structure.

Definition of Attribution

Attribution exists only if the institution can, for any specific student interaction:

  1. Reconstruct the full interaction sequence

    • including prompts, system outputs, and relevant system state

  2. Identify the system configuration

    • model/version or system state that produced the output

  3. Distinguish between student-originated and system-generated content

  4. Attach the output to a specific accountable entity

    • with both authority over the system and responsibility for its behavior

Failure condition

Attribution does not exist if any of the following are true:

  • Interaction sequences cannot be fully reconstructed

  • System behavior cannot be tied to a specific version or configuration

  • Outputs cannot be clearly separated from user input

  • No single accountable entity can be identified