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.

Governance report

Practice-by-practice evidence

Denominator: 77 records · use cases that answered at least one practice question

Reported in placeReported in progressReported not in placeNot applicableOther or ambiguous answerNo answer reported

Pre-deployment testing

Pre-deployment testing
Reported in place: 21 (27.3%)Pre-deployment testing
Reported in progress: 53 (68.8%)Pre-deployment testing
Reported not in place: 1 (1.3%)Pre-deployment testing
No answer reported: 2 (2.6%)

AI impact assessment

AI impact assessment
Reported in place: 16 (20.8%)AI impact assessment
Reported in progress: 55 (71.4%)AI impact assessment
No answer reported: 6 (7.8%)

Independent review

Independent review
Reported in place: 19 (24.7%)Independent review
Reported in progress: 49 (63.6%)Independent review
Reported not in place: 2 (2.6%)Independent review
No answer reported: 7 (9.1%)

Ongoing monitoring

Ongoing monitoring
Reported in place: 16 (20.8%)Ongoing monitoring
Reported in progress: 52 (67.5%)Ongoing monitoring
No answer reported: 9 (11.7%)

Operator training

Operator training
Reported in place: 19 (24.7%)Operator training
Reported in progress: 49 (63.6%)Operator training
No answer reported: 9 (11.7%)

Fail-safe

Fail-safe
Reported in place: 10 (13.0%)Fail-safe
Reported in progress: 8 (10.4%)Fail-safe
Not applicable: 54 (70.1%)Fail-safe
No answer reported: 5 (6.5%)

Appeal process

Appeal process
Reported in place: 2 (2.6%)Appeal process
Reported in progress: 10 (13.0%)Appeal process
Not applicable: 60 (77.9%)Appeal process
No answer reported: 5 (6.5%)

User and public consultation

User and public consultation
Reported in place: 48 (62.3%)User and public consultation
Reported in progress: 16 (20.8%)User and public consultation
Other or ambiguous answer: 12 (15.6%)User and public consultation
No answer reported: 1 (1.3%)

Practice	In scope	In place	In progress	Not in place	N/A	Other	No answer	Answered	In place of applicable
Pre-deployment testing	77	21	53	1	0	0	2	97%	27% of 77
AI impact assessment	77	16	55	0	0	0	6	92%	21% of 77
Independent review	77	19	49	2	0	0	7	91%	25% of 77
Ongoing monitoring	77	16	52	0	0	0	9	88%	21% of 77
Operator training	77	19	49	0	0	0	9	88%	25% of 77
Fail-safe	77	10	8	0	54	0	5	94%	43% of 23
Appeal process	77	2	10	0	60	0	5	94%	12% of 17
User and public consultation	77	48	16	0	0	12	1	99%	62% of 77

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.

Agency-by-safeguard heatmap

Cell: share reported in place, among applicable recordsIn place Answered

Agency by governance practice
	Testing	Impact assess.	Indep. review	Monitoring	Training	Fail-safe	Appeal	Consultation	n
DOE	12%	5%	14%	7%	12%	100%	0%	81%	43
SBA	65%	65%	65%	65%	65%	100%	67%	40%	20
DOJ	0%	0%	0%	0%	0%	0%	0%	0%	8
EAC	25%	–	0%	–	–	–	–	100%	4
TREAS	100%	100%	0%	0%	100%	100%	0%	100%	1
SSA	100%	0%	–	–	–	–	–	–	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

64 records with at least one practice unanswered or in progressOpen in explorer

Use case	Stage	Test	AIA	Review	Monitor	Train	Fail-safe	Appeal	Consult
ServiceNow Predictive Intelligence DOE · DOE-430	Deployed	Reported in place	Reported in progress	Reported in place	Reported in place	Reported in place	Not applicable	Not applicable	Reported in place
Copilot Studio DOE · DOE-444	Deployed	Reported in progress	Reported in place	Reported in place	Reported in progress	Reported in place	Reported in place	Not applicable	Other or ambiguous answer
Copilot for Microsoft 365 DOE · DOE-452	Deployed	Reported in progress	Reported in place	Reported in place	Reported in progress	Reported in place	Reported in place	Not applicable	Other or ambiguous answer
ChatGPT Enterprise DOE · DOE-498	Deployed	Reported in place	Reported in progress	Reported in place	Reported in place	Reported in place	Not applicable	Not applicable	Reported in place
Microsoft Bing Service DOE · DOE-510	Deployed	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Not applicable	Not applicable	Reported in place
Visual Studio Enterprise DOE · DOE-519	Deployed	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Not applicable	Not applicable	Reported in place
Microsoft OneNote DOE · DOE-525	Deployed	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Not applicable	Not applicable	Reported in place
Microsoft Azure Authoring Tools DOE · DOE-536	Deployed	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Not applicable	Not applicable	Reported in place
Apple Intelligence DOE · DOE-549	Deployed	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Not applicable	Not applicable	Reported in place
Microsoft ScreenSketch DOE · DOE-551	Deployed	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Not applicable	Not applicable	Reported in place
Microsoft Visual C++ Additional Runtime DOE · DOE-552	Deployed	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Not applicable	Not applicable	Reported in place
Microsoft Project DOE · DOE-556	Deployed	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Not applicable	Not applicable	Reported in place
Google Chrome Generative AI DOE · DOE-561	Deployed	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Not applicable	Not applicable	Reported in place
GitHub Co-Pilot DOE · DOE-571	Deployed	Reported in place	No answer reported	Reported in place	Reported in progress	Reported in progress	Not applicable	Not applicable	Reported in place
Microsoft Copilot DOE · DOE-577	Deployed	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Not applicable	Not applicable	Reported in place
Microsoft Visual C++ Redistributable DOE · DOE-596	Deployed	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Not applicable	Not applicable	Reported in place
Microsoft Teams DOE · DOE-599	Deployed	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Not applicable	Not applicable	Reported in place
Microsoft Search in Bing DOE · DOE-602	Deployed	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Not applicable	Not applicable	Reported in place
Microsoft Teams Classic DOE · DOE-608	Deployed	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Not applicable	Not applicable	Reported in place
Microsoft MSPaint DOE · DOE-623	Deployed	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Not applicable	Not applicable	Reported in place
Visual Studio Community DOE · DOE-631	Deployed	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Not applicable	Not applicable	Reported in place
Microsoft OneDrive DOE · DOE-634	Deployed	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Not applicable	Not applicable	Reported in place
Microsoft 365 DOE · DOE-651	Deployed	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Not applicable	Not applicable	Reported in place
Microsoft Visual C++ Minimum Runtime DOE · DOE-667	Deployed	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Not applicable	Not applicable	Reported in place
Microsoft OneDrive MUI DOE · DOE-669	Deployed	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Not applicable	Not applicable	Reported in place
Microsoft 365 Apps for Enterprise DOE · DOE-685	Deployed	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Not applicable	Not applicable	Reported in place
Microsoft Outlook MUI DOE · DOE-691	Deployed	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Not applicable	Not applicable	Reported in place
Microsoft Edge DOE · DOE-698	Deployed	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Not applicable	Not applicable	Reported in place
SQL Server Management Studio DOE · DOE-710	Deployed	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Not applicable	Not applicable	Reported in place
Microsoft Exchange Server DOE · DOE-711	Deployed	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Not applicable	Not applicable	Reported in place
Microsoft Skype App DOE · DOE-721	Deployed	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Not applicable	Not applicable	Reported in place
Microsoft OneNote MUI DOE · DOE-735	Deployed	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Not applicable	Not applicable	Reported in place
Microsoft PowerPoint MUI DOE · DOE-744	Deployed	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Not applicable	Not applicable	Reported in place
Microsoft Power BI Desktop DOE · DOE-748	Deployed	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Not applicable	Not applicable	Reported in place
Microsoft Azure PowerShell DOE · DOE-749	Deployed	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Not applicable	Not applicable	Reported in place
Palantir (via access to external state LE system) DOJ · DOJ-0025	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
Data & Analytics: Database Tools DOJ · DOJ-0069	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
Critical Mention DOJ · DOJ-0116	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
Evidence.com DOJ · DOJ-0117	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
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
Pacer Search DOJ · DOJ-0215	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
JAWS (Text-to-Speech Assistant for Accessibility) DOJ · DOJ-0222	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
Palantir DOJ · DOJ-0272	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
Grants Lifecycle Application System EAC · EAC-3	Deployed	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported	Reported in place
SSA 800# Public Question & Answer Bot and OIG Hotline recording of fraud, waste and abuse. SSA · R3106	Deployed	Reported in place	Reported in progress	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported
GenAI Productivity Tool TREAS · TREASURY-OCIO-001	Deployed	Reported in place	Reported in place	Reported in progress	Reported in progress	Reported in place	Reported in place	Reported in progress	Reported in place
Ariculate 360 AI Assistant DOE · DOE-511	Pre-deployment	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Not applicable	Not applicable	Reported in place
Microsoft Co-Pilot DOE · DOE-518	Pilot	Reported in place	No answer reported	Reported in place	Reported in progress	Reported in progress	Not applicable	Not applicable	Reported in place
OpenAI ChatGPT Pilot DOE · DOE-526	Pilot	Reported in progress	Reported in progress	No answer reported	No answer reported	No answer reported	Not applicable	Not applicable	Other or ambiguous answer
M365 Copilot DOE · DOE-574	Pilot	Reported in place	Reported in progress	Reported in progress	Reported in place	Reported in place	Reported in place	Not applicable	Other or ambiguous answer
xAI Grok Pilot DOE · DOE-601	Pilot	Reported in progress	Reported in progress	No answer reported	No answer reported	No answer reported	Not applicable	Not applicable	Other or ambiguous answer
Microsoft Copilot Pilot DOE · DOE-676	Pilot	Reported in progress	Reported in progress	No answer reported	No answer reported	No answer reported	Not applicable	Not applicable	Other or ambiguous answer
LexisNexis DOE · DOE-684	Pre-deployment	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Not applicable	Not applicable	Reported in progress
Anthropic Claude Pilot DOE · DOE-703	Pilot	Reported in progress	Reported in progress	No answer reported	No answer reported	No answer reported	Not applicable	Not applicable	Other or ambiguous answer
AI Answers in Clearinghouse Network EAC · EAC-1	Pilot	Reported in place	No answer reported	Reported not in place	No answer reported	No answer reported	No answer reported	No answer reported	Reported in place
Internal Generative AI Tools for Staff Productivity EAC · EAC-2	Pilot	Reported not in place	No answer reported	Reported not in place	No answer reported	No answer reported	No answer reported	No answer reported	Reported in place
Routing emails from shared inboxes EAC · EAC-4	Pilot	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported	Reported in place
Meeting Minutes Summary Tool SBA · SBA-1	Pre-deployment	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Not applicable	Not applicable	Reported in progress
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
Generative AI for SBA.gov product training SBA · SBA-13	Pre-deployment	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Not applicable	Not applicable	Reported in progress
ChatGPT for OMS Marketing SBA · SBA-15	Retired	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Not applicable	Not applicable	Reported in progress
Employee Center AI Search SBA · SBA-20	Pre-deployment	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Not applicable	Reported in progress	Reported in progress
AI Incident Summarization SBA · SBA-35	Pre-deployment	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in place	Not applicable	Reported in progress
AI-Powered Search and Recovery SBA · SBA-41	Pre-deployment	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in place	Not applicable	Reported in progress

Unanswered analytical questions

Generated from the data; for follow-up with agencies

VA 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?
8 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?
2 high-impact use cases mark an appeal process as not applicable. On what basis was each individual outcome judged not contestable?
14 high-impact use cases report using PII but give no link to a Privacy Impact Assessment. Is a PIA published elsewhere?
55 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.