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: 24 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: 10 (41.7%)Pre-deployment testing
Reported in progress: 1 (4.2%)Pre-deployment testing
No answer reported: 13 (54.2%)
24Reported in place: 10 (41.7%)Pre-deployment testing
Reported in progress: 1 (4.2%)Pre-deployment testing
No answer reported: 13 (54.2%)
AI impact assessment
AI impact assessment
Reported in place: 10 (41.7%)AI impact assessment
Reported in progress: 1 (4.2%)AI impact assessment
No answer reported: 13 (54.2%)
24Reported in place: 10 (41.7%)AI impact assessment
Reported in progress: 1 (4.2%)AI impact assessment
No answer reported: 13 (54.2%)
Independent review
Independent review
Reported in place: 10 (41.7%)Independent review
Reported in progress: 1 (4.2%)Independent review
No answer reported: 13 (54.2%)
24Reported in place: 10 (41.7%)Independent review
Reported in progress: 1 (4.2%)Independent review
No answer reported: 13 (54.2%)
Ongoing monitoring
Ongoing monitoring
Reported in place: 10 (41.7%)Ongoing monitoring
Reported in progress: 1 (4.2%)Ongoing monitoring
No answer reported: 13 (54.2%)
24Reported in place: 10 (41.7%)Ongoing monitoring
Reported in progress: 1 (4.2%)Ongoing monitoring
No answer reported: 13 (54.2%)
Operator training
Operator training
Reported in place: 10 (41.7%)Operator training
Reported in progress: 1 (4.2%)Operator training
No answer reported: 13 (54.2%)
24Reported in place: 10 (41.7%)Operator training
Reported in progress: 1 (4.2%)Operator training
No answer reported: 13 (54.2%)
Fail-safe
Fail-safe
Reported in place: 8 (33.3%)Fail-safe
Reported in progress: 1 (4.2%)Fail-safe
Not applicable: 2 (8.3%)Fail-safe
No answer reported: 13 (54.2%)
24Reported in place: 8 (33.3%)Fail-safe
Reported in progress: 1 (4.2%)Fail-safe
Not applicable: 2 (8.3%)Fail-safe
No answer reported: 13 (54.2%)
| 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 | 24 | 10 | 1 | 0 | 0 | 0 | 0 | 13 | 46% | 42% of 24 |
| AI impact assessment | 24 | 10 | 1 | 0 | 0 | 0 | 0 | 13 | 46% | 42% of 24 |
| Independent review | 24 | 10 | 1 | 0 | 0 | 0 | 0 | 13 | 46% | 42% of 24 |
| Ongoing monitoring | 24 | 10 | 1 | 0 | 0 | 0 | 0 | 13 | 46% | 42% of 24 |
| Operator training | 24 | 10 | 1 | 0 | 0 | 0 | 0 | 13 | 46% | 42% of 24 |
| Fail-safe | 24 | 8 | 1 | 0 | 2 | 0 | 0 | 13 | 46% | 36% of 22 |
| Appeal process | 24 | 2 | 1 | 0 | 5 | 3 | 0 | 13 | 46% | 13% of 16 |
| User and public consultation | 24 | 1 | 1 | 0 | 0 | 0 | 9 | 13 | 46% | 4% of 24 |
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 | – | – | – | – | – | – | – | – | 10 |
| DHS | 100% | 100% | 100% | 100% | 100% | 100% | 0% | 20% | 5 |
| SSA | 100% | 100% | 100% | 100% | 100% | 100% | 100% | 0% | 5 |
| NCUA | – | – | – | – | – | – | – | – | 2 |
| DOJ | 0% | 0% | 0% | 0% | 0% | 0% | 0% | 0% | 1 |
| DOE | – | – | – | – | – | – | – | – | 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
14 records with at least one practice unanswered or in progressOpen in explorer| Use case | Stage | Test | AIA | Review | Monitor | Train | Fail-safe | Appeal | Consult |
|---|---|---|---|---|---|---|---|---|---|
| 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 |
| 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 |
| 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 |
| 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 |
| 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 |
| 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 |
| 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 |
| Lung Cancer Prediction Model VA · VA-24-3898 | 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 |
| Screen for Esophageal Adenocarcinoma VA · VA-25-5375 | 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 10 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?
- 5 high-impact use cases mark an appeal process as not applicable. On what basis was each individual outcome judged not contestable?
- 6 high-impact use cases report using PII but give no link to a Privacy Impact Assessment. Is a PIA published elsewhere?
- 4 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.