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

Reported in placeReported in progressNot applicableOther or ambiguous answerNo answer reported

Pre-deployment testing

Pre-deployment testing
Reported in place: 13 (38.2%)Pre-deployment testing
Reported in progress: 21 (61.8%)

AI impact assessment

AI impact assessment
Reported in place: 11 (32.4%)AI impact assessment
Reported in progress: 12 (35.3%)AI impact assessment
No answer reported: 11 (32.4%)

Independent review

Independent review
Reported in place: 12 (35.3%)Independent review
Reported in progress: 11 (32.4%)Independent review
No answer reported: 11 (32.4%)

Ongoing monitoring

Ongoing monitoring
Reported in place: 12 (35.3%)Ongoing monitoring
Reported in progress: 11 (32.4%)Ongoing monitoring
No answer reported: 11 (32.4%)

Operator training

Operator training
Reported in place: 22 (64.7%)Operator training
Reported in progress: 11 (32.4%)Operator training
No answer reported: 1 (2.9%)

Fail-safe

Fail-safe
Reported in place: 7 (20.6%)Fail-safe
Not applicable: 27 (79.4%)

Appeal process

Appeal process
Reported in place: 3 (8.8%)Appeal process
Reported in progress: 1 (2.9%)Appeal process
Not applicable: 30 (88.2%)

User and public consultation

User and public consultation
Reported in place: 18 (52.9%)User and public consultation
Reported in progress: 10 (29.4%)User and public consultation
Other or ambiguous answer: 6 (17.6%)

Practice	In scope	In place	In progress	N/A	Other	No answer	Answered	In place of applicable
Pre-deployment testing	34	13	21	0	0	0	100%	38% of 34
AI impact assessment	34	11	12	0	0	11	68%	32% of 34
Independent review	34	12	11	0	0	11	68%	35% of 34
Ongoing monitoring	34	12	11	0	0	11	68%	35% of 34
Operator training	34	22	11	0	0	1	97%	65% of 34
Fail-safe	34	7	0	27	0	0	100%	100% of 7
Appeal process	34	3	1	30	0	0	100%	75% of 4
User and public consultation	34	18	10	0	6	0	100%	53% of 34

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
SBA	53%	53%	53%	53%	53%	100%	67%	32%	19
DOE	20%	7%	13%	13%	80%	100%	100%	80%	15

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

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

Use case	Stage	Test	AIA	Review	Monitor	Train	Fail-safe	Appeal	Consult
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
Ask CAS DOE · DOE-522	Pre-deployment	Reported in progress	No answer reported	No answer reported	No answer reported	Reported in place	Not applicable	Not applicable	Reported in place
Ask Alan DOE · DOE-569	Pre-deployment	Reported in progress	No answer reported	No answer reported	No answer reported	Reported in place	Not applicable	Not applicable	Reported in place
DIRECTIVES DOE · DOE-587	Pre-deployment	Reported in progress	No answer reported	No answer reported	No answer reported	Reported in place	Not applicable	Not applicable	Reported in place
FindMATID DOE · DOE-604	Pre-deployment	Reported in progress	No answer reported	No answer reported	No answer reported	Reported in place	Not applicable	Not applicable	Reported in place
Ask IT DOE · DOE-615	Pre-deployment	Reported in progress	No answer reported	No answer reported	No answer reported	Reported in place	Not applicable	Not applicable	Reported in place
ChatSRS DOE · DOE-638	Pre-deployment	Reported in place	No answer reported	No answer reported	No answer reported	Reported in place	Not applicable	Not applicable	Reported in place
UNSPSC Codes DOE · DOE-642	Pre-deployment	Reported in progress	No answer reported	No answer reported	No answer reported	Reported in place	Not applicable	Not applicable	Reported in place
Hanford Ai Liaison (HAL) 2.0 DOE · DOE-653	Pre-deployment	Reported in place	No answer reported	Reported in place	Reported in place	Reported in place	Not applicable	Not applicable	Reported in place
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
Amazon Q Chatbot Pilot DOE · DOE-700	Pre-deployment	Reported in progress	Reported in progress	No answer reported	No answer reported	No answer reported	Not applicable	Not applicable	Other or ambiguous answer
Ask HR DOE · DOE-704	Pre-deployment	Reported in progress	No answer reported	No answer reported	No answer reported	Reported in place	Not applicable	Not applicable	Reported in place
mass3 DOE · DOE-707	Pre-deployment	Reported in progress	No answer reported	No answer reported	No answer reported	Reported in place	Not applicable	Not applicable	Reported in place
AccessAI DOE · DOE-725	Pre-deployment	Reported in progress	No answer reported	No answer reported	No answer reported	Reported in place	Not applicable	Not applicable	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
ODRR Comm - Talking Point Generation SBA · SBA-6	Pre-deployment	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Not applicable	Not applicable	Reported in progress
Amazon Q in Connect SBA · SBA-9	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
Business Plan Creation SBA · SBA-19	Pre-deployment	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

DOE designated 12 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 9 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 8 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?
DHS 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?
20 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.