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: 9 records · use cases designated high-impactReported in placeReported in progressNot applicableNo answer reported
Pre-deployment testing
Pre-deployment testing
Reported in place: 1 (11.1%)Pre-deployment testing
No answer reported: 8 (88.9%)
9Reported in place: 1 (11.1%)Pre-deployment testing
No answer reported: 8 (88.9%)
AI impact assessment
AI impact assessment
Reported in progress: 1 (11.1%)AI impact assessment
No answer reported: 8 (88.9%)
9Reported in progress: 1 (11.1%)AI impact assessment
No answer reported: 8 (88.9%)
Independent review9
Ongoing monitoring9
Operator training9
User and public consultation
User and public consultation
Reported in place: 1 (11.1%)User and public consultation
No answer reported: 8 (88.9%)
9Reported in place: 1 (11.1%)User and public consultation
No answer reported: 8 (88.9%)
| 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 | 9 | 1 | 0 | 0 | 0 | 0 | 0 | 8 | 11% | 11% of 9 |
| AI impact assessment | 9 | 0 | 1 | 0 | 0 | 0 | 0 | 8 | 11% | 0% of 9 |
| Independent review | 9 | 0 | 1 | 0 | 0 | 0 | 0 | 8 | 11% | 0% of 9 |
| Ongoing monitoring | 9 | 1 | 0 | 0 | 0 | 0 | 0 | 8 | 11% | 11% of 9 |
| Operator training | 9 | 1 | 0 | 0 | 0 | 0 | 0 | 8 | 11% | 11% of 9 |
| Fail-safe | 9 | 1 | 0 | 0 | 0 | 0 | 0 | 8 | 11% | 11% of 9 |
| Appeal process | 9 | 0 | 0 | 0 | 1 | 0 | 0 | 8 | 11% | 0% of 8 |
| User and public consultation | 9 | 1 | 0 | 0 | 0 | 0 | 0 | 8 | 11% | 11% of 9 |
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 | – | – | – | – | – | – | – | – | 4 |
| DOJ | – | – | – | – | – | – | – | – | 3 |
| DHS | – | – | – | – | – | – | – | – | 1 |
| STATE | 100% | 0% | 0% | 100% | 100% | 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
9 records with at least one practice unanswered or in progressOpen in explorer| Use case | Stage | Test | AIA | Review | Monitor | Train | Fail-safe | Appeal | Consult |
|---|---|---|---|---|---|---|---|---|---|
| Electronic Health Record AI Enhancements STATE · R3248 | Deployed | Reported in place | Reported in progress | Reported in progress | Reported in place | Reported in place | Reported in place | Not applicable | Reported in place |
| Continuous Glucose Monitoring Summary VA · VA-25-1506 | 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 |
| Electronic Evidence/Video Recording Transcription and Summarization Tool DHS · DHS-2399 | 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 |
| FinCEN Data Summarization DOJ · DOJ-0185 | 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 |
| Voicemail Transcription, Translation and Summarization DOJ · DOJ-0243 | 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 |
| Immigration Case and Filing Content Summary DOJ · DOJ-0288 | 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 |
| Automated Ratings Summarization VA · VA-25-1594 | 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 |
| Ambient Scribing with Patient Chart Exploration VA · VA-25-3149 | 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 |
| Patient Care Services Integration Platform (PCSIP) VA · VA-24-421 | 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 4 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?
- DOJ 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?
- 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 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?
- 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.