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: 6 records · use cases that answered at least one practice questionReported in place: 3 (50.0%)Pre-deployment testing
Reported in progress: 3 (50.0%)
Reported in place: 2 (33.3%)AI impact assessment
Reported in progress: 3 (50.0%)AI impact assessment
Reported not in place: 1 (16.7%)
Reported in place: 2 (33.3%)Independent review
Reported in progress: 3 (50.0%)Independent review
No answer reported: 1 (16.7%)
Reported in place: 2 (33.3%)Ongoing monitoring
Reported in progress: 3 (50.0%)Ongoing monitoring
Other or ambiguous answer: 1 (16.7%)
Reported in progress: 1 (16.7%)Appeal process
Not applicable: 4 (66.7%)Appeal process
No answer reported: 1 (16.7%)
Reported in place: 3 (50.0%)User and public consultation
Reported in progress: 3 (50.0%)
| 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 | 6 | 3 | 3 | 0 | 0 | 0 | 0 | 0 | 100% | 50% of 6 |
| AI impact assessment | 6 | 2 | 3 | 1 | 0 | 0 | 0 | 0 | 100% | 33% of 6 |
| Independent review | 6 | 2 | 3 | 0 | 0 | 0 | 0 | 1 | 83% | 33% of 6 |
| Ongoing monitoring | 6 | 2 | 3 | 0 | 0 | 0 | 1 | 0 | 100% | 33% of 6 |
| Operator training | 6 | 2 | 4 | 0 | 0 | 0 | 0 | 0 | 100% | 33% of 6 |
| Fail-safe | 6 | 2 | 0 | 0 | 4 | 0 | 0 | 0 | 100% | 100% of 2 |
| Appeal process | 6 | 0 | 1 | 0 | 4 | 0 | 0 | 1 | 83% | 0% of 2 |
| User and public consultation | 6 | 3 | 3 | 0 | 0 | 0 | 0 | 0 | 100% | 50% of 6 |
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 | |
|---|---|---|---|---|---|---|---|---|---|
| SBA | 40% | 40% | 40% | 40% | 40% | 100% | 0% | 40% | 5 |
| EPA | 100% | 0% | – | 0% | 0% | 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
4 records with at least one practice unanswered or in progressOpen in explorer| Use case | Stage | Test | AIA | Review | Monitor | Train | Fail-safe | Appeal | Consult |
|---|---|---|---|---|---|---|---|---|---|
| Agency Records Management System EPA · 73 | Deployed | Reported in place | Reported not in place | No answer reported | Other or ambiguous answer | Reported in progress | Reported in place | No answer reported | Reported in place |
| Audit Green Book Classification SBA · SBA-3 | Pre-deployment | Reported in progress | Reported in progress | Reported in progress | Reported in progress | Reported in progress | Not applicable | Not applicable | Reported in progress |
| 7(a) Purchases ML Model SBA · SBA-7 | Pre-deployment | Reported in progress | Reported in progress | Reported in progress | Reported in progress | Reported in progress | Not applicable | Reported in progress | Reported in progress |
| Multi-Agent Orchestration SBA · SBA-40 | Pre-deployment | Reported in progress | Reported in progress | Reported in progress | Reported in progress | Reported in progress | Reported in place | Not applicable | Reported in progress |
Unanswered analytical questions
Generated from the data; for follow-up with agencies- 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?
- 6 governance answers are ambiguous (for example, an answer option from a different question). What did the agency intend?
These are questions the inventory raises but cannot answer. They are not findings of non-compliance.