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.

Governance report

Practice-by-practice evidence

Denominator: 132 records · use cases designated high-impact

Reported in placeReported in progressNot applicablePrecluded by law or guidanceOther or ambiguous answerNo answer reported

Pre-deployment testing

Pre-deployment testing
Reported in place: 19 (14.4%)Pre-deployment testing
Reported in progress: 33 (25.0%)Pre-deployment testing
No answer reported: 80 (60.6%)

132

AI impact assessment

AI impact assessment
Reported in place: 16 (12.1%)AI impact assessment
Reported in progress: 36 (27.3%)AI impact assessment
No answer reported: 80 (60.6%)

132

Independent review

Independent review
Reported in place: 16 (12.1%)Independent review
Reported in progress: 36 (27.3%)Independent review
No answer reported: 80 (60.6%)

132

Ongoing monitoring

Ongoing monitoring
Reported in place: 19 (14.4%)Ongoing monitoring
Reported in progress: 33 (25.0%)Ongoing monitoring
No answer reported: 80 (60.6%)

132

Operator training

Operator training
Reported in place: 18 (13.6%)Operator training
Reported in progress: 34 (25.8%)Operator training
No answer reported: 80 (60.6%)

132

Fail-safe

Fail-safe
Reported in place: 16 (12.1%)Fail-safe
Reported in progress: 33 (25.0%)Fail-safe
Not applicable: 3 (2.3%)Fail-safe
No answer reported: 80 (60.6%)

132

Appeal process

Appeal process
Reported in place: 7 (5.3%)Appeal process
Reported in progress: 33 (25.0%)Appeal process
Not applicable: 9 (6.8%)Appeal process
Precluded by law or guidance: 3 (2.3%)Appeal process
No answer reported: 80 (60.6%)

132

User and public consultation

User and public consultation
Reported in place: 6 (4.5%)User and public consultation
Reported in progress: 35 (26.5%)User and public consultation
Other or ambiguous answer: 11 (8.3%)User and public consultation
No answer reported: 80 (60.6%)

132

Practice	In scope	In place	In progress	N/A	Precluded or waived	Other	No answer	Answered	In place of applicable
Pre-deployment testing	132	19	33	0	0	0	80	39%	14% of 132
AI impact assessment	132	16	36	0	0	0	80	39%	12% of 132
Independent review	132	16	36	0	0	0	80	39%	12% of 132
Ongoing monitoring	132	19	33	0	0	0	80	39%	14% of 132
Operator training	132	18	34	0	0	0	80	39%	14% of 132
Fail-safe	132	16	33	3	0	0	80	39%	12% of 129
Appeal process	132	7	33	9	3	0	80	39%	6% of 120
User and public consultation	132	6	35	0	0	11	80	39%	5% of 132

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.

Agency-by-safeguard heatmap

Cell: share reported in place, among applicable recordsIn place Answered

Agency by governance practice
	Testing	Impact assess.	Indep. review	Monitoring	Training	Fail-safe	Appeal	Consultation	n
VA	–	–	–	–	–	–	–	–	52
DOJ	0%	0%	0%	0%	0%	0%	0%	0%	41
DHS	85%	77%	77%	85%	77%	83%	60%	38%	13
DOE	–	–	–	–	–	–	–	–	7
SSA	100%	100%	100%	100%	100%	100%	100%	0%	6
NCUA	–	–	–	–	–	–	–	–	5
USDA	–	–	–	–	–	–	–	–	3
EPA	50%	0%	0%	50%	50%	0%	0%	0%	2
HHS	–	–	–	–	–	–	–	–	1
FDIC	–	–	–	–	–	–	–	–	1
STATE	100%	0%	0%	100%	100%	100%	100%	100%	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

116 records with at least one practice unanswered or in progressOpen in explorer

Use case	Stage	Test	AIA	Review	Monitor	Train	Fail-safe	Appeal	Consult
Cryptocurrency Analysis DHS · DHS-2561	Deployed	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress
Verification Match Model DHS · DHS-2384	Deployed	Reported in place	Reported in progress	Reported in progress	Reported in place	Reported in progress	Reported in place	Reported in place	Reported in progress
Airlines Travel Intelligence Program DOJ · DOJ-0002	Deployed	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress
Axon FUSUS (via HIDTA partners) DOJ · DOJ-0005	Deployed	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress
FINDER DOJ · DOJ-0017	Deployed	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress
First Two DOJ · DOJ-0018	Deployed	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress
ShotSpotter (via access to external state/local systems) DOJ · DOJ-0028	Deployed	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress
Whooster DOJ · DOJ-0034	Deployed	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress
ELSAG/Leonardo (via HIDTA partners) DOJ · DOJ-0036	Deployed	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress
Cloudflare Turnstile DOJ · DOJ-0056	Deployed	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress
LPR: DEA DEASIL Program DOJ · DOJ-0061	Deployed	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress
LPR: State Partner DOJ · DOJ-0062	Deployed	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress
LPR: Federal Partner DOJ · DOJ-0063	Deployed	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress
LPR: Commercial Solution DOJ · DOJ-0064	Deployed	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress
Data & Analytics: Gunshot Detection System DOJ · DOJ-0082	Deployed	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress
Autonomous Drone Detection and Monitoring DOJ · DOJ-0092	Deployed	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress
Digital Forensics DOJ · DOJ-0103	Deployed	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress
Next Generation Identification DOJ · DOJ-0135	Deployed	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress
ASCVD (Atherosclerotic Cardiovascular Disease) Risk Estimator DOJ · DOJ-0142	Deployed	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress
Automated Medication Dispensing Cabinet DOJ · DOJ-0143	Deployed	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress
BRAVO Classification DOJ · DOJ-0146	Deployed	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress
Building Automation Systems DOJ · DOJ-0147	Deployed	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress
Community Treatment Pipeline Screening DOJ · DOJ-0149	Deployed	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress
Medical Claims Adjudication DOJ · DOJ-0156	Deployed	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress
Medical Designations Calculator DOJ · DOJ-0157	Deployed	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress
NLETs Arrest Classification DOJ · DOJ-0158	Deployed	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress
Psychological Test Interpretation - Pearson Assessments DOJ · DOJ-0161	Deployed	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress
Static-99 Sex Offender Data System (SODS) DOJ · DOJ-0163	Deployed	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress
TruNarc, Smith Detection DOJ · DOJ-0166	Deployed	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress
Trunet Systems DOJ · DOJ-0167	Deployed	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress
Truview DOJ · DOJ-0168	Deployed	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress
UAS Threat Detector DOJ · DOJ-0169	Deployed	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress
Fingerprint (Friction Ridge) Optical Character Recognition (OCR) DOJ · DOJ-0296	Deployed	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress
Background Searches DOJ · DOJ-0324	Deployed	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress
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
Automatically-Scored Writing Assessment (AWA) FDIC · FDIC – 32	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
Supervisory Stress Testing NCUA · NCUA_ONES-02	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
Risk Indicator Model NCUA · NCUA_ONES-03	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
Moody’s Stress Test Modeling NCUA · NCUA-12-2025	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
ADCo MBS/CMO Modeling NCUA · NCUA-13-2025	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
CoStar CRE Modeling NCUA · NCUA-14-2025	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-Augmented Declassification Review STATE · R3213	Deployed	Reported in place	Reported in progress	Reported in progress	Reported in place	Reported in place	Reported in place	Reported in place	Reported in place
VA.gov Chatbot: Summative Content VA · VA-24-2717	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
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
Concept Clustering VA · VA-25-3275	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
Payment Redirect Fraud (PRF) Model VA · VA-24-3291	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
Automated Decision Support VA · VA-24-4722	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 Adenoma Detection VA · VA-24-2008	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
Zio ECG Utilization Service VA · VA-24-2754	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
3M/Solventum 360 Encompass Computer Assisted Coding - Auto Suggestion VA · VA-24-3205	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
eCaremanager (Philips) VA · VA-24-3906	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
CareLink Home Monitoring VA · VA-24-4107	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
Stratification Tool for Opioid Risk Mitigation (STORM) VA · VA-24-4152	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
REACH VET Suicide Risk Prediction and Recovery Engagement VA · VA-24-4234	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
Velacur VA · VA-24-4279	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
RayStation 11B VA · VA-24-4443	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
Preventice BodyGuardian Remote Monitoring System VA · VA-24-4599	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
Persyst 14 EEG Review and Analysis Software VA · VA-24-4648	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
OPTIS Mobile Next Imaging System, OPTIS Integrated Next Imaging System VA · VA-24-4689	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
CARTO 3 EP Navigation System Software V8.0 (FG-5400-00, FG-5400-00U) VA · VA-24-5468	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
Care Assessment Needs (CAN) Score VA · VA-24-5501	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
BioPlex 2200 ANA Screen with Medical Decision Support Software for Use with BioPlex 2200 Multi-Analyte Detection System VA · VA-24-5714	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
Acumen Hypotension Prediction Index - EV1000 Clinical Platform, Acumen Hypotension Prediction Index - Hemosphere Advanced Monitoring Platform, Acumen Hypotension Prediction Index, Hemosphere Advanced Monitoring Platform - Pressure VA · VA-24-6042	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
No Missed Malignancy (NMM) VA · VA-25-2045	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
VASQIP Mortality Calculator VA · VA-25-4960	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
Frailty Risk Analysis VA · VA-25-5001	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
Advance RPM Maintenance Operating Reporter (ARMOR) DHS · DHS-314	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
ORNL: AI for Transportation and Mobility DOE · DOE-331	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
ORNL: AI for Energy Generation and Distribution DOE · DOE-333	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
ORNL: AI for Advanced Manufacturing DOE · DOE-334	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
ORNL: AI for Neutron Science DOE · DOE-338	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
ORNL: AI for Fusion Energy DOE · DOE-340	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
Advanced Long Term Environmental Monitoring Systems (ALTEMIS) DOE · DOE-714	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
Identifying Controlling Variables for Mercury Vapor Release at Y-12's Alpha-4 DOE · DOE-736	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
Evidence.com DOJ · DOJ-0058	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
Friction Ridge Print Comparisons DOJ · DOJ-0065	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

Showing 80 of 116, deployed first.

Unanswered analytical questions

Generated from the data; for follow-up with agencies

VA designated 52 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?
DOE designated 7 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?
NCUA designated 5 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?
USDA designated 3 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?
36 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?
9 high-impact use cases mark an appeal process as not applicable. On what basis was each individual outcome judged not contestable?
36 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.