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: 37 records · all use cases in the current filterReported in placeReported in progressNot applicableOther or ambiguous answerNo answer reported
Pre-deployment testing
Pre-deployment testing
Reported in place: 10 (27.0%)Pre-deployment testing
Reported in progress: 2 (5.4%)Pre-deployment testing
No answer reported: 25 (67.6%)
37Reported in place: 10 (27.0%)Pre-deployment testing
Reported in progress: 2 (5.4%)Pre-deployment testing
No answer reported: 25 (67.6%)
AI impact assessment
AI impact assessment
Reported in place: 8 (21.6%)AI impact assessment
Reported in progress: 4 (10.8%)AI impact assessment
No answer reported: 25 (67.6%)
37Reported in place: 8 (21.6%)AI impact assessment
Reported in progress: 4 (10.8%)AI impact assessment
No answer reported: 25 (67.6%)
Independent review
Independent review
Reported in place: 8 (21.6%)Independent review
Reported in progress: 4 (10.8%)Independent review
No answer reported: 25 (67.6%)
37Reported in place: 8 (21.6%)Independent review
Reported in progress: 4 (10.8%)Independent review
No answer reported: 25 (67.6%)
Ongoing monitoring
Ongoing monitoring
Reported in place: 9 (24.3%)Ongoing monitoring
Reported in progress: 3 (8.1%)Ongoing monitoring
No answer reported: 25 (67.6%)
37Reported in place: 9 (24.3%)Ongoing monitoring
Reported in progress: 3 (8.1%)Ongoing monitoring
No answer reported: 25 (67.6%)
Operator training
Operator training
Reported in place: 9 (24.3%)Operator training
Reported in progress: 2 (5.4%)Operator training
Other or ambiguous answer: 1 (2.7%)Operator training
No answer reported: 25 (67.6%)
37Reported in place: 9 (24.3%)Operator training
Reported in progress: 2 (5.4%)Operator training
Other or ambiguous answer: 1 (2.7%)Operator training
No answer reported: 25 (67.6%)
Fail-safe
Fail-safe
Reported in place: 10 (27.0%)Fail-safe
Reported in progress: 2 (5.4%)Fail-safe
No answer reported: 25 (67.6%)
37Reported in place: 10 (27.0%)Fail-safe
Reported in progress: 2 (5.4%)Fail-safe
No answer reported: 25 (67.6%)
| 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 | 37 | 10 | 2 | 0 | 0 | 0 | 0 | 25 | 32% | 27% of 37 |
| AI impact assessment | 37 | 8 | 4 | 0 | 0 | 0 | 0 | 25 | 32% | 22% of 37 |
| Independent review | 37 | 8 | 4 | 0 | 0 | 0 | 0 | 25 | 32% | 22% of 37 |
| Ongoing monitoring | 37 | 9 | 3 | 0 | 0 | 0 | 0 | 25 | 32% | 24% of 37 |
| Operator training | 37 | 9 | 2 | 0 | 0 | 0 | 1 | 25 | 32% | 24% of 37 |
| Fail-safe | 37 | 10 | 2 | 0 | 0 | 0 | 0 | 25 | 32% | 27% of 37 |
| Appeal process | 37 | 3 | 1 | 0 | 8 | 0 | 0 | 25 | 32% | 10% of 29 |
| User and public consultation | 37 | 8 | 1 | 0 | 0 | 0 | 3 | 25 | 32% | 22% of 37 |
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 | 47% | 42% | 42% | 42% | 42% | 47% | 18% | 42% | 19 |
| HHS | – | – | – | – | – | – | – | – | 5 |
| USDA | 25% | 0% | 0% | 25% | 25% | 25% | 25% | 0% | 4 |
| DOJ | – | – | – | – | – | – | – | – | 2 |
| DOI | – | – | – | – | – | – | – | – | 2 |
| SEC | – | – | – | – | – | – | – | – | 1 |
| NASA | – | – | – | – | – | – | – | – | 1 |
| VA | – | – | – | – | – | – | – | – | 1 |
| SSA | – | – | – | – | – | – | – | – | 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
29 records with at least one practice unanswered or in progressOpen in explorer| Use case | Stage | Test | AIA | Review | Monitor | Train | Fail-safe | Appeal | Consult |
|---|---|---|---|---|---|---|---|---|---|
| Passive Body Scanner DHS · DHS-2380 | Deployed | Reported in place | Reported in progress | Reported in progress | Reported in progress | Reported in progress | Reported in progress | Not applicable | Other or ambiguous answer |
| Mobile Fortify DHS · DHS-2577 | Deployed | Reported in progress | Reported in progress | Reported in progress | Reported in progress | Other or ambiguous answer | Reported in progress | Reported in progress | Reported in progress |
| Process Efficiency Traveler Identity for Airline Check-in and Bag Drop DHS · DHS-2417 | 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 |
| Customs Broker License Exam - Proctor Support DHS · DHS-310 | 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 |
| Vessel Detection DHS · DHS-38 | 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 |
| Vault Access Log (SPVAA) DHS · DHS-401 | 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 |
| ELIS Card Photo Validation Service DHS · DHS-189 | 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 |
| Intelligent Document Processing DHS · DHS-2425 | 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 |
| Intelligent Document Processing (IDP) for I-539 Form Digitization DHS · DHS-2385 | 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 |
| JPATS Mobile App (Biometrics) DOJ · DOJ-0234 | 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 |
| Optical Character Recognition Tool 2 DOJ · DOJ-0275 | 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 |
| Structuring Notice of Concern Data HHS · R0600 | 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 |
| Identify infrastructure supports for physical activity (e.g. sidewalks) in satellite and roadway images HHS · R0645 | 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 |
| TowerScout: Automated cooling tower detection from aerial imagery for Legionnaires' Disease outbreak investigation HHS · R0681 | 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 |
| TB Case Browser Image Text Detection HHS · R0945 | 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 |
| TB Portals Outlier Detection Lambda Function HHS · R0975 | 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 |
| GLOBE Program - Image processing NASA · NASA-900 | 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 |
| Optical Character Recognition (OCR) for Records Analysis SEC · SEC-33 | 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 |
| Mobile Wage Reporting SSA · R3105 | 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 |
| 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 |
| Non-Intrusive Inspection (NII) 3D Imaging Tool DHS · DHS-163 | 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 |
| Spot for automated sensing, inspection, and capture DOE · DOE-435 | 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 |
| Level 1 Survey Report Corrosion Level Classification DOI · DOI-0257 | 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 |
| AI for Offshore Energy: Innovative Technology Streamlines Marine Wildlife Surveys [2024 INV#DOI-66] DOI · DOI-0033 | 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 |
| Forest Health Detection Monitoring USDA · USDA-021 | 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 |
| Wildlife Deterrent System USDA · USDA-086 | 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 |
| Automated Road Mapping USDA · USDA-137 | 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 |
| Sharing RVU Provider Metrics VA · VA-25-3029 | 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- 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?
- 8 high-impact use cases mark an appeal process as not applicable. On what basis was each individual outcome judged not contestable?
- 1 high-impact use cases report using PII but give no link to a Privacy Impact Assessment. Is a PIA published elsewhere?
- 1 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.