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: 19 records · all use cases in the current filterReported in placeReported in progressNot applicableNo answer reported
Pre-deployment testing
Pre-deployment testing
Reported in place: 2 (10.5%)Pre-deployment testing
No answer reported: 17 (89.5%)
19Reported in place: 2 (10.5%)Pre-deployment testing
No answer reported: 17 (89.5%)
AI impact assessment19
Independent review19
Ongoing monitoring
Ongoing monitoring
Reported in place: 1 (5.3%)Ongoing monitoring
Reported in progress: 1 (5.3%)Ongoing monitoring
No answer reported: 17 (89.5%)
19Reported in place: 1 (5.3%)Ongoing monitoring
Reported in progress: 1 (5.3%)Ongoing monitoring
No answer reported: 17 (89.5%)
Operator training19
User and public consultation
User and public consultation
Reported in place: 2 (10.5%)User and public consultation
No answer reported: 17 (89.5%)
19Reported in place: 2 (10.5%)User and public consultation
No answer reported: 17 (89.5%)
| 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 | 19 | 2 | 0 | 0 | 0 | 0 | 0 | 17 | 11% | 11% of 19 |
| AI impact assessment | 19 | 2 | 0 | 0 | 0 | 0 | 0 | 17 | 11% | 11% of 19 |
| Independent review | 19 | 2 | 0 | 0 | 0 | 0 | 0 | 17 | 11% | 11% of 19 |
| Ongoing monitoring | 19 | 1 | 1 | 0 | 0 | 0 | 0 | 17 | 11% | 5% of 19 |
| Operator training | 19 | 2 | 0 | 0 | 0 | 0 | 0 | 17 | 11% | 11% of 19 |
| Fail-safe | 19 | 2 | 0 | 0 | 0 | 0 | 0 | 17 | 11% | 11% of 19 |
| Appeal process | 19 | 0 | 0 | 0 | 2 | 0 | 0 | 17 | 11% | 0% of 17 |
| User and public consultation | 19 | 2 | 0 | 0 | 0 | 0 | 0 | 17 | 11% | 11% of 19 |
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 | – | – | – | – | – | – | – | – | 8 |
| HHS | – | – | – | – | – | – | – | – | 2 |
| DHS | – | – | – | – | – | – | – | – | 2 |
| SSA | 100% | 100% | 100% | 50% | 100% | 100% | 0% | 100% | 2 |
| PBGC | – | – | – | – | – | – | – | – | 2 |
| DOL | – | – | – | – | – | – | – | – | 1 |
| DOJ | – | – | – | – | – | – | – | – | 1 |
| OSC | – | – | – | – | – | – | – | – | 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
18 records with at least one practice unanswered or in progressOpen in explorer| Use case | Stage | Test | AIA | Review | Monitor | Train | Fail-safe | Appeal | Consult |
|---|---|---|---|---|---|---|---|---|---|
| PDF Intake (PDFI) for myUSCIS DHS · DHS-2598 | 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 |
| Automatic Document Processing DOL · DOL-13 | 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 |
| Individual Assistance Document Translation DHS · DHS-2713 | 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 |
| Call Center Management and Service Delivery Support DOJ · DOJ-0089 | 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 |
| Medicare AI Drug Search HHS · R0784 | 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 |
| Marketplace Qualified Health Plan Benefit AI Assistant (discovery) HHS · R0785 | 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 |
| Copilot Studio OSC · OSC-0001 | 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 |
| Pension Plan Summary Report Assistance PBGC · PBGC - 09 | 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 |
| Analysis of Plan Benefits for Standard Terminations PBGC · PBGC -13 | 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 |
| Policy Assistance Tool (PAT) SSA · R3116 | Pilot | Reported in place | Reported in place | Reported in place | Reported in progress | Reported in place | Reported in place | Not applicable | Reported in place |
| 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 |
| Veterans Life Tailored VA · VA-25-3521 | 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 |
| BillieGPT POC VA · VA-25-605 | 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 |
| Smart Claim Check VA · VA-25-1348 | 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 |
| Generative Annotations VA · VA-25-2373 | 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 |
| VBA Mail Management Services (MMS) - Modification VA · VA-25-5852 | 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 |
| Call Center Knowledge Navigator VA · VA-24-2143 | 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 |
| Master Claims Assistance Tool (M-CAT) VA · VA-24-4804 | 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- 2 high-impact use cases mark an appeal process as not applicable. On what basis was each individual outcome judged not contestable?
These are questions the inventory raises but cannot answer. They are not findings of non-compliance.