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

Reported in placeReported in progressReported not in placeNot applicableNo answer reported

Pre-deployment testing

Pre-deployment testing
Reported in place: 11 (61.1%)Pre-deployment testing
Reported in progress: 3 (16.7%)Pre-deployment testing
Reported not in place: 1 (5.6%)Pre-deployment testing
No answer reported: 3 (16.7%)

AI impact assessment

AI impact assessment
Reported in place: 5 (27.8%)AI impact assessment
Reported in progress: 3 (16.7%)AI impact assessment
No answer reported: 10 (55.6%)

Independent review

Independent review
Reported in place: 9 (50.0%)Independent review
Reported in progress: 3 (16.7%)Independent review
Reported not in place: 1 (5.6%)Independent review
No answer reported: 5 (27.8%)

Ongoing monitoring

Ongoing monitoring
Reported in place: 8 (44.4%)Ongoing monitoring
Reported in progress: 4 (22.2%)Ongoing monitoring
No answer reported: 6 (33.3%)

Operator training

Operator training
Reported in place: 12 (66.7%)Operator training
Reported in progress: 3 (16.7%)Operator training
No answer reported: 3 (16.7%)

Fail-safe

Fail-safe
Reported in place: 1 (5.6%)Fail-safe
Not applicable: 14 (77.8%)Fail-safe
No answer reported: 3 (16.7%)

Appeal process

Appeal process
Reported in progress: 1 (5.6%)Appeal process
Not applicable: 14 (77.8%)Appeal process
No answer reported: 3 (16.7%)

User and public consultation

User and public consultation
Reported in place: 16 (88.9%)User and public consultation
Reported in progress: 2 (11.1%)

Practice	In scope	In place	In progress	Not in place	N/A	No answer	Answered	In place of applicable
Pre-deployment testing	18	11	3	1	0	3	83%	61% of 18
AI impact assessment	18	5	3	0	0	10	44%	28% of 18
Independent review	18	9	3	1	0	5	72%	50% of 18
Ongoing monitoring	18	8	4	0	0	6	67%	44% of 18
Operator training	18	12	3	0	0	3	83%	67% of 18
Fail-safe	18	1	0	0	14	3	83%	25% of 4
Appeal process	18	0	1	0	14	3	83%	0% of 4
User and public consultation	18	16	2	0	0	0	100%	89% of 18

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	75%	0%	63%	50%	88%	0%	0%	100%	8
SBA	80%	80%	80%	80%	80%	0%	0%	80%	5
EAC	0%	–	0%	–	–	–	–	100%	3
DOI	–	–	0%	0%	0%	0%	0%	0%	1
TREAS	100%	100%	0%	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

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

Use case	Stage	Test	AIA	Review	Monitor	Train	Fail-safe	Appeal	Consult
Hanford Ai Liaison (HAL) 1.1 DOE · DOE-469	Deployed	Reported in place	No answer reported	Reported in place	Reported in place	Reported in place	Not applicable	Not applicable	Reported in place
LANL AI Portal DOE · DOE-495	Deployed	Reported in place	Reported in progress	Reported in place	Reported in place	Reported in place	Not applicable	Not applicable	Reported in place
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
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
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
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
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
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
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
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
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
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
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

Unanswered analytical questions

Generated from the data; for follow-up with agencies

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 report using PII but give no link to a Privacy Impact Assessment. Is a PIA published elsewhere?
8 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.