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 · use cases that answered at least one practice questionReported in place: 8 (42.1%)Pre-deployment testing
Reported in progress: 7 (36.8%)Pre-deployment testing
Reported not in place: 1 (5.3%)Pre-deployment testing
No answer reported: 3 (15.8%)
Reported in place: 5 (26.3%)AI impact assessment
Reported in progress: 8 (42.1%)AI impact assessment
No answer reported: 6 (31.6%)
Reported in place: 7 (36.8%)Independent review
Reported in progress: 2 (10.5%)Independent review
Reported not in place: 2 (10.5%)Independent review
No answer reported: 8 (42.1%)
Reported in place: 6 (31.6%)Ongoing monitoring
Reported in progress: 3 (15.8%)Ongoing monitoring
No answer reported: 10 (52.6%)
Reported in place: 7 (36.8%)Operator training
Reported in progress: 2 (10.5%)Operator training
No answer reported: 10 (52.6%)
Reported in place: 4 (21.1%)Fail-safe
Not applicable: 11 (57.9%)Fail-safe
No answer reported: 4 (21.1%)
| 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 | 8 | 7 | 1 | 0 | 0 | 0 | 3 | 84% | 42% of 19 |
| AI impact assessment | 19 | 5 | 8 | 0 | 0 | 0 | 0 | 6 | 68% | 26% of 19 |
| Independent review | 19 | 7 | 2 | 2 | 0 | 0 | 0 | 8 | 58% | 37% of 19 |
| Ongoing monitoring | 19 | 6 | 3 | 0 | 0 | 0 | 0 | 10 | 47% | 32% of 19 |
| Operator training | 19 | 7 | 2 | 0 | 0 | 0 | 0 | 10 | 47% | 37% of 19 |
| Fail-safe | 19 | 4 | 0 | 0 | 11 | 0 | 0 | 4 | 79% | 50% of 8 |
| Appeal process | 19 | 0 | 1 | 0 | 14 | 0 | 0 | 4 | 79% | 0% of 5 |
| User and public consultation | 19 | 9 | 1 | 0 | 0 | 0 | 7 | 2 | 89% | 47% 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 | |
|---|---|---|---|---|---|---|---|---|---|
| DOE | 22% | 0% | 11% | 11% | 11% | 50% | 0% | 11% | 9 |
| EAC | 33% | – | 0% | – | – | – | – | 100% | 3 |
| SBA | 100% | 100% | 100% | 100% | 100% | 100% | 0% | 100% | 3 |
| DOI | – | – | 50% | 50% | 50% | 0% | 0% | 0% | 2 |
| FERC | 100% | 100% | 100% | 100% | 100% | 100% | 0% | 100% | 1 |
| SSA | 100% | 100% | 100% | 0% | 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
15 records with at least one practice unanswered or in progressOpen in explorer| Use case | Stage | Test | AIA | Review | Monitor | Train | Fail-safe | Appeal | Consult |
|---|---|---|---|---|---|---|---|---|---|
| AI Chat Bot for IT User Services DOE · DOE-463 | Pilot | Reported in progress | Reported in progress | 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 |
| 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 |
| LISA Chatbot Pilot DOE · DOE-671 | 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 |
| 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 |
| Foundation Models to Advance Earth Science [2024 INV#WO0000000107153] DOI · DOI-0172 | Pilot | No answer reported | No answer reported | Reported in place | Reported in place | Reported in place | Not applicable | Reported in progress | No answer reported |
| CHS Q Business AI Assistant (theKraken) DOI · DOI-0169 | Pilot | No answer reported | No answer reported | Reported in progress | Reported in progress | Reported in progress | Not applicable | Not applicable | Reported in progress |
| 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 |
| 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 |
Unanswered analytical questions
Generated from the data; for follow-up with agencies- DOJ 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?
- 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?
- DOE 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 mark an appeal process as not applicable. On what basis was each individual outcome judged not contestable?
- 4 high-impact use cases report using PII but give no link to a Privacy Impact Assessment. Is a PIA published elsewhere?
- 6 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.