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: 52 records · use cases that answered at least one practice question

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

Pre-deployment testing

Pre-deployment testing
Reported in place: 19 (36.5%)Pre-deployment testing
Reported in progress: 33 (63.5%)

AI impact assessment

AI impact assessment
Reported in place: 16 (30.8%)AI impact assessment
Reported in progress: 36 (69.2%)

Independent review

Independent review
Reported in place: 16 (30.8%)Independent review
Reported in progress: 36 (69.2%)

Ongoing monitoring

Ongoing monitoring
Reported in place: 19 (36.5%)Ongoing monitoring
Reported in progress: 33 (63.5%)

Operator training

Operator training
Reported in place: 18 (34.6%)Operator training
Reported in progress: 34 (65.4%)

Fail-safe

Fail-safe
Reported in place: 16 (30.8%)Fail-safe
Reported in progress: 33 (63.5%)Fail-safe
Not applicable: 3 (5.8%)

Appeal process

Appeal process
Reported in place: 7 (13.5%)Appeal process
Reported in progress: 33 (63.5%)Appeal process
Not applicable: 9 (17.3%)Appeal process
Precluded by law or guidance: 3 (5.8%)

User and public consultation

User and public consultation
Reported in place: 6 (11.5%)User and public consultation
Reported in progress: 35 (67.3%)User and public consultation
Other or ambiguous answer: 11 (21.2%)

Practice	In scope	In place	In progress	N/A	Precluded or waived	Other	Answered	In place of applicable
Pre-deployment testing	52	19	33	0	0	0	100%	37% of 52
AI impact assessment	52	16	36	0	0	0	100%	31% of 52
Independent review	52	16	36	0	0	0	100%	31% of 52
Ongoing monitoring	52	19	33	0	0	0	100%	37% of 52
Operator training	52	18	34	0	0	0	100%	35% of 52
Fail-safe	52	16	33	3	0	0	100%	33% of 49
Appeal process	52	7	33	9	3	0	100%	18% of 40
User and public consultation	52	6	35	0	0	11	100%	12% of 52

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
DOJ	0%	0%	0%	0%	0%	0%	0%	0%	32
DHS	92%	83%	83%	92%	83%	91%	75%	42%	12
SSA	100%	100%	100%	100%	100%	100%	100%	0%	6
EPA	100%	0%	0%	100%	100%	0%	0%	0%	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

36 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
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

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.