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: 15 records · use cases designated high-impactReported in place: 13 (86.7%)Pre-deployment testing
Reported in progress: 1 (6.7%)Pre-deployment testing
No answer reported: 1 (6.7%)
Reported in place: 11 (73.3%)AI impact assessment
Reported in progress: 4 (26.7%)
Reported in place: 11 (73.3%)Independent review
Reported in progress: 3 (20.0%)Independent review
No answer reported: 1 (6.7%)
Reported in place: 13 (86.7%)Ongoing monitoring
Reported in progress: 1 (6.7%)Ongoing monitoring
No answer reported: 1 (6.7%)
Reported in place: 13 (86.7%)Operator training
Reported in progress: 1 (6.7%)Operator training
No answer reported: 1 (6.7%)
| 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 | 15 | 13 | 1 | 0 | 0 | 0 | 0 | 1 | 93% | 87% of 15 |
| AI impact assessment | 15 | 11 | 4 | 0 | 0 | 0 | 0 | 0 | 100% | 73% of 15 |
| Independent review | 15 | 11 | 3 | 0 | 0 | 0 | 0 | 1 | 93% | 73% of 15 |
| Ongoing monitoring | 15 | 13 | 1 | 0 | 0 | 0 | 0 | 1 | 93% | 87% of 15 |
| Operator training | 15 | 13 | 1 | 0 | 0 | 0 | 0 | 1 | 93% | 87% of 15 |
| Fail-safe | 15 | 15 | 0 | 0 | 0 | 0 | 0 | 0 | 100% | 100% of 15 |
| Appeal process | 15 | 5 | 0 | 0 | 9 | 1 | 0 | 0 | 100% | 100% of 5 |
| User and public consultation | 15 | 12 | 0 | 0 | 0 | 0 | 3 | 0 | 100% | 80% of 15 |
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 | |
|---|---|---|---|---|---|---|---|---|---|
| DHS | 92% | 85% | 85% | 92% | 92% | 100% | 100% | 85% | 13 |
| USDA | 100% | 0% | 0% | 100% | 100% | 100% | 100% | 0% | 1 |
| SSA | – | 0% | – | – | – | 100% | 0% | 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 |
|---|---|---|---|---|---|---|---|---|---|
| Mobile Fortify DHS · DHS-2731 | Deployed | Reported in place | Reported in progress | Reported in progress | Reported in place | Reported in place | Reported in place | Not applicable | Reported in place |
| Digital Identity Verification Services SSA · R3122 | Deployed | No answer reported | Reported in progress | No answer reported | No answer reported | No answer reported | Reported in place | Precluded by law or guidance | Reported in place |
| Video Surveillance System USDA · USDA-025 | Deployed | Reported in place | Reported in progress | Reported in progress | Reported in place | Reported in place | Reported in place | Reported in place | Other or ambiguous answer |
| FLIR 280 HD DHS · DHS-2745 | Pilot | Reported in progress | Reported in progress | Reported in progress | Reported in progress | Reported in progress | Reported in place | Not applicable | Other or ambiguous answer |
Unanswered analytical questions
Generated from the data; for follow-up with agencies- 3 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?
- 2 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.