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: 15 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: 7 (46.7%)Pre-deployment testing
Reported in progress: 8 (53.3%)

AI impact assessment

AI impact assessment
Reported in place: 5 (33.3%)AI impact assessment
Reported in progress: 9 (60.0%)AI impact assessment
No answer reported: 1 (6.7%)

Independent review

Independent review
Reported in place: 5 (33.3%)Independent review
Reported in progress: 8 (53.3%)Independent review
Reported not in place: 1 (6.7%)Independent review
No answer reported: 1 (6.7%)

Ongoing monitoring

Ongoing monitoring
Reported in place: 5 (33.3%)Ongoing monitoring
Reported in progress: 8 (53.3%)Ongoing monitoring
No answer reported: 2 (13.3%)

Operator training

Operator training
Reported in place: 5 (33.3%)Operator training
Reported in progress: 8 (53.3%)Operator training
No answer reported: 2 (13.3%)

Fail-safe

Fail-safe
Reported in place: 3 (20.0%)Fail-safe
Not applicable: 10 (66.7%)Fail-safe
No answer reported: 2 (13.3%)

Appeal process

Appeal process
Reported in place: 2 (13.3%)Appeal process
Reported in progress: 1 (6.7%)Appeal process
Not applicable: 10 (66.7%)Appeal process
No answer reported: 2 (13.3%)

User and public consultation

User and public consultation
Reported in place: 4 (26.7%)User and public consultation
Reported in progress: 8 (53.3%)User and public consultation
Other or ambiguous answer: 2 (13.3%)User and public consultation
No answer reported: 1 (6.7%)

Practice	In scope	In place	In progress	Not in place	N/A	Other	No answer	Answered	In place of applicable
Pre-deployment testing	15	7	8	0	0	0	0	100%	47% of 15
AI impact assessment	15	5	9	0	0	0	1	93%	33% of 15
Independent review	15	5	8	1	0	0	1	93%	33% of 15
Ongoing monitoring	15	5	8	0	0	0	2	87%	33% of 15
Operator training	15	5	8	0	0	0	2	87%	33% of 15
Fail-safe	15	3	0	0	10	0	2	87%	60% of 5
Appeal process	15	2	1	0	10	0	2	87%	40% of 5
User and public consultation	15	4	8	0	0	2	1	93%	27% of 15

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	38%	38%	38%	38%	38%	100%	67%	23%	13
EAC	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

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

Use case	Stage	Test	AIA	Review	Monitor	Train	Fail-safe	Appeal	Consult
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
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
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
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
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

Unanswered analytical questions

Generated from the data; for follow-up with agencies

14 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.