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: 21 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: 1 (4.8%)Pre-deployment testing
Reported in progress: 3 (14.3%)Pre-deployment testing
No answer reported: 17 (81.0%)
21Reported in place: 1 (4.8%)Pre-deployment testing
Reported in progress: 3 (14.3%)Pre-deployment testing
No answer reported: 17 (81.0%)
AI impact assessment
AI impact assessment
Reported in place: 1 (4.8%)AI impact assessment
Reported in progress: 3 (14.3%)AI impact assessment
No answer reported: 17 (81.0%)
21Reported in place: 1 (4.8%)AI impact assessment
Reported in progress: 3 (14.3%)AI impact assessment
No answer reported: 17 (81.0%)
Independent review
Independent review
Reported in place: 1 (4.8%)Independent review
Reported in progress: 2 (9.5%)Independent review
No answer reported: 18 (85.7%)
21Reported in place: 1 (4.8%)Independent review
Reported in progress: 2 (9.5%)Independent review
No answer reported: 18 (85.7%)
Ongoing monitoring
Ongoing monitoring
Reported in place: 1 (4.8%)Ongoing monitoring
Reported in progress: 2 (9.5%)Ongoing monitoring
No answer reported: 18 (85.7%)
21Reported in place: 1 (4.8%)Ongoing monitoring
Reported in progress: 2 (9.5%)Ongoing monitoring
No answer reported: 18 (85.7%)
Operator training
Operator training
Reported in place: 1 (4.8%)Operator training
Reported in progress: 2 (9.5%)Operator training
No answer reported: 18 (85.7%)
21Reported in place: 1 (4.8%)Operator training
Reported in progress: 2 (9.5%)Operator training
No answer reported: 18 (85.7%)
Fail-safe
Fail-safe
Reported in place: 1 (4.8%)Fail-safe
Reported in progress: 1 (4.8%)Fail-safe
Not applicable: 2 (9.5%)Fail-safe
No answer reported: 17 (81.0%)
21Reported in place: 1 (4.8%)Fail-safe
Reported in progress: 1 (4.8%)Fail-safe
Not applicable: 2 (9.5%)Fail-safe
No answer reported: 17 (81.0%)
| 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 | 21 | 1 | 3 | 0 | 0 | 0 | 0 | 17 | 19% | 5% of 21 |
| AI impact assessment | 21 | 1 | 3 | 0 | 0 | 0 | 0 | 17 | 19% | 5% of 21 |
| Independent review | 21 | 1 | 2 | 0 | 0 | 0 | 0 | 18 | 14% | 5% of 21 |
| Ongoing monitoring | 21 | 1 | 2 | 0 | 0 | 0 | 0 | 18 | 14% | 5% of 21 |
| Operator training | 21 | 1 | 2 | 0 | 0 | 0 | 0 | 18 | 14% | 5% of 21 |
| Fail-safe | 21 | 1 | 1 | 0 | 2 | 0 | 0 | 17 | 19% | 5% of 19 |
| Appeal process | 21 | 1 | 1 | 0 | 2 | 0 | 0 | 17 | 19% | 5% of 19 |
| User and public consultation | 21 | 1 | 2 | 0 | 0 | 0 | 1 | 17 | 19% | 5% of 21 |
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 | |
|---|---|---|---|---|---|---|---|---|---|
| DOJ | 0% | 0% | 0% | 0% | 0% | 0% | 0% | 0% | 6 |
| VA | – | – | – | – | – | – | – | – | 3 |
| TREAS | – | – | – | – | – | – | – | – | 3 |
| DOI | – | – | – | – | – | – | – | – | 2 |
| SBA | 50% | 50% | 50% | 50% | 50% | 100% | 100% | 50% | 2 |
| DOE | 0% | 0% | – | – | – | 0% | 0% | 0% | 2 |
| NASA | – | – | – | – | – | – | – | – | 1 |
| HHS | – | – | – | – | – | – | – | – | 1 |
| DHS | – | – | – | – | – | – | – | – | 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
20 records with at least one practice unanswered or in progressOpen in explorer| Use case | Stage | Test | AIA | Review | Monitor | Train | Fail-safe | Appeal | Consult |
|---|---|---|---|---|---|---|---|---|---|
| Insider Threat Management and User Activity Monitoring DOJ · DOJ-0119 | 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 |
| LIGER Generative AI Toolkit DHS · DHS-2454 | 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 |
| Bernie-AI: Infrastructure Planning Support POC DOE · DOE-514 | Pilot | Reported in progress | Reported in progress | No answer reported | No answer reported | No answer reported | Not applicable | Not applicable | Other or ambiguous answer |
| VIPER (Visualizaiton for Predictive Maintenance Recommendation) DOE · DOE-541 | 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 |
| Use of artificial intelligence tools for optimization and documentation for computer codes [2024 INV#WO0000000109681] DOI · DOI-0232 | 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 |
| Forecasting Earthquake Ground Motion Time Series [2024 INV#WO0000000109733] DOI · DOI-0140 | 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 |
| R (Forecasting, predictive analytics, data/statistical analysis) DOJ · DOJ-0041 | 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 |
| Stata (Forecasting, predictive analytics, data/statistical analysis) DOJ · DOJ-0042 | 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 |
| Matlab (Forecasting, predictive analytics, data/statistical analysis) DOJ · DOJ-0043 | 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 |
| Databricks (Forecasting, predictive analytics, data/statistical analysis) DOJ · DOJ-0044 | 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 |
| Capture and Convert Structured Data from Scanned Case Documents to Support Advanced Analysis and Trend Forecasting DOJ · DOJ-0360 | 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 identification of "High-Risk" Health Centers HHS · R0898 | 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 |
| Diffusion Modeling of the Solar Corona NASA · NASA-878 | 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 |
| Business Development SBA · SBA-2 | Pre-deployment | Reported in progress | Reported in progress | Reported in progress | Reported in progress | Reported in progress | Not applicable | Not applicable | Reported in progress |
| GenAI Productivity Tool Pilot TREAS · REQ-2024-01953 | 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 |
| Integrated Financial Management Information System (IFMIS) TREAS · TREAS-IRS-125 | 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 |
| GenAI for Low Code Platform TREAS · TREAS-IRS-46 | 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 |
| Employee Transactions for HR Decision-Making VA · VA-25-897 | 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 |
| Artificial Intelligence Assisted Procurement Tools (AIAPT) VA · VA-25-4889 | 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 |
| Potential Fraud or Waste VA · VA-24-1360 | 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 |
Unanswered analytical questions
Generated from the data; for follow-up with agencies- 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?
- 1 high-impact use cases report using PII but give no link to a Privacy Impact Assessment. Is a PIA published elsewhere?
- 2 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.