Governance and accountability
Governance evidence
What agencies reported about the OMB M-25-21 minimum practices for high-impact AI. This is a disclosure analysis, not an audit, a compliance finding or an official assessment. An unanswered question is missing evidence, not evidence that a safeguard is absent.
Practice-by-practice evidence
Denominator: 12 records · use cases designated high-impactReported in placeReported in progressNot applicablePrecluded by law or guidanceOther or ambiguous answerNo answer reported
Pre-deployment testing
Pre-deployment testing
Reported in place: 3 (25.0%)Pre-deployment testing
No answer reported: 9 (75.0%)
12Reported in place: 3 (25.0%)Pre-deployment testing
No answer reported: 9 (75.0%)
AI impact assessment
AI impact assessment
Reported in place: 2 (16.7%)AI impact assessment
Reported in progress: 1 (8.3%)AI impact assessment
No answer reported: 9 (75.0%)
12Reported in place: 2 (16.7%)AI impact assessment
Reported in progress: 1 (8.3%)AI impact assessment
No answer reported: 9 (75.0%)
Independent review
Independent review
Reported in place: 2 (16.7%)Independent review
Reported in progress: 1 (8.3%)Independent review
No answer reported: 9 (75.0%)
12Reported in place: 2 (16.7%)Independent review
Reported in progress: 1 (8.3%)Independent review
No answer reported: 9 (75.0%)
Ongoing monitoring12
Operator training12
Fail-safe
Fail-safe
Reported in place: 2 (16.7%)Fail-safe
Not applicable: 1 (8.3%)Fail-safe
No answer reported: 9 (75.0%)
12Reported in place: 2 (16.7%)Fail-safe
Not applicable: 1 (8.3%)Fail-safe
No answer reported: 9 (75.0%)
| Practice | In scope | In place | In progress | Not in place | N/A | Precluded or waived | Other | No answer | Answered | In place of applicable |
|---|---|---|---|---|---|---|---|---|---|---|
| Pre-deployment testing | 12 | 3 | 0 | 0 | 0 | 0 | 0 | 9 | 25% | 25% of 12 |
| AI impact assessment | 12 | 2 | 1 | 0 | 0 | 0 | 0 | 9 | 25% | 17% of 12 |
| Independent review | 12 | 2 | 1 | 0 | 0 | 0 | 0 | 9 | 25% | 17% of 12 |
| Ongoing monitoring | 12 | 3 | 0 | 0 | 0 | 0 | 0 | 9 | 25% | 25% of 12 |
| Operator training | 12 | 3 | 0 | 0 | 0 | 0 | 0 | 9 | 25% | 25% of 12 |
| Fail-safe | 12 | 2 | 0 | 0 | 1 | 0 | 0 | 9 | 25% | 18% of 11 |
| Appeal process | 12 | 0 | 0 | 0 | 2 | 1 | 0 | 9 | 25% | 0% of 9 |
| User and public consultation | 12 | 0 | 1 | 0 | 0 | 0 | 2 | 9 | 25% | 0% of 12 |
Answered = records with any answer ÷ records in scope. In place of applicable = reported in place ÷ (in scope minus not applicable, precluded and waived). Unanswered records stay in that denominator, so the rate is a lower bound on reported evidence, not an estimate of real practice.
| Testing | Impact assess. | Indep. review | Monitoring | Training | Fail-safe | Appeal | Consultation | n | |
|---|---|---|---|---|---|---|---|---|---|
| VA | – | – | – | – | – | – | – | – | 8 |
| DOJ | – | – | – | – | – | – | – | – | 1 |
| DHS | 100% | 100% | 100% | 100% | 100% | 100% | 0% | 0% | 1 |
| EPA | 100% | 0% | 0% | 100% | 100% | 0% | 0% | 0% | 1 |
| SSA | 100% | 100% | 100% | 100% | 100% | 100% | 0% | 0% | 1 |
Hatched cells: the agency answered nothing for that practice, so there is no evidence either way. Compare agencies with care: each agency is one reporting unit, and portfolios differ in size and type.
Records requiring further investigation
10 records with at least one practice unanswered or in progressOpen in explorer| Use case | Stage | Test | AIA | Review | Monitor | Train | Fail-safe | Appeal | Consult |
|---|---|---|---|---|---|---|---|---|---|
| RCRA PA EPA · 78 | Deployed | Reported in place | Reported in progress | Reported in progress | Reported in place | Reported in place | Not applicable | Not applicable | Reported in progress |
| Heuristic Behavior Analytics VA · VA-25-2537 | Deployed | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported |
| VA CART SYNTAX Risk Model VA · VA-24-5542 | Deployed | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported |
| VA CART Mortality Model VA · VA-24-5583 | Deployed | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported |
| VA CART Nephropathy Risk Model VA · VA-24-5624 | Deployed | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported |
| VA CART Bleeding Risk Model VA · VA-24-5788 | Deployed | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported |
| AI-driven Fraud Detection DOJ · DOJ-0339 | Pre-deployment | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported |
| Fall Prediction Tool VA · VA-24-5579 | Pre-deployment | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported |
| EEO Consultation and Guidance VA · VA-25-13 | Pre-deployment | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported |
| Secure Access Service Edge (SASE) VA · VA-25-6479 | Pilot | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported |
Unanswered analytical questions
Generated from the data; for follow-up with agencies- VA designated 8 use cases high-impact but answered none of the minimum-practice questions for any of them. Were the practices assessed, and where is that recorded?
- 1 high-impact use cases are reported as deployed while their AI impact assessment is reported in progress. Was deployment authorised before the assessment was complete?
- 2 high-impact use cases mark an appeal process as not applicable. On what basis was each individual outcome judged not contestable?
- 1 high-impact use cases report using PII but give no link to a Privacy Impact Assessment. Is a PIA published elsewhere?
These are questions the inventory raises but cannot answer. They are not findings of non-compliance.