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.
Practice-by-practice evidence
Denominator: 15 records · all use cases in the current filterReported in placeReported in progressNot applicableNo answer reported
Pre-deployment testing
Pre-deployment testing
Reported in place: 1 (6.7%)Pre-deployment testing
Reported in progress: 3 (20.0%)Pre-deployment testing
No answer reported: 11 (73.3%)
15Reported in place: 1 (6.7%)Pre-deployment testing
Reported in progress: 3 (20.0%)Pre-deployment testing
No answer reported: 11 (73.3%)
AI impact assessment
AI impact assessment
Reported in place: 1 (6.7%)AI impact assessment
Reported in progress: 3 (20.0%)AI impact assessment
No answer reported: 11 (73.3%)
15Reported in place: 1 (6.7%)AI impact assessment
Reported in progress: 3 (20.0%)AI impact assessment
No answer reported: 11 (73.3%)
Independent review
Independent review
Reported in place: 1 (6.7%)Independent review
Reported in progress: 3 (20.0%)Independent review
No answer reported: 11 (73.3%)
15Reported in place: 1 (6.7%)Independent review
Reported in progress: 3 (20.0%)Independent review
No answer reported: 11 (73.3%)
Ongoing monitoring
Ongoing monitoring
Reported in place: 1 (6.7%)Ongoing monitoring
Reported in progress: 3 (20.0%)Ongoing monitoring
No answer reported: 11 (73.3%)
15Reported in place: 1 (6.7%)Ongoing monitoring
Reported in progress: 3 (20.0%)Ongoing monitoring
No answer reported: 11 (73.3%)
Operator training
Operator training
Reported in place: 1 (6.7%)Operator training
Reported in progress: 3 (20.0%)Operator training
No answer reported: 11 (73.3%)
15Reported in place: 1 (6.7%)Operator training
Reported in progress: 3 (20.0%)Operator training
No answer reported: 11 (73.3%)
Fail-safe
Fail-safe
Reported in place: 1 (6.7%)Fail-safe
Reported in progress: 3 (20.0%)Fail-safe
No answer reported: 11 (73.3%)
15Reported in place: 1 (6.7%)Fail-safe
Reported in progress: 3 (20.0%)Fail-safe
No answer reported: 11 (73.3%)
| 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 | 15 | 1 | 3 | 0 | 0 | 0 | 0 | 11 | 27% | 7% of 15 |
| AI impact assessment | 15 | 1 | 3 | 0 | 0 | 0 | 0 | 11 | 27% | 7% of 15 |
| Independent review | 15 | 1 | 3 | 0 | 0 | 0 | 0 | 11 | 27% | 7% of 15 |
| Ongoing monitoring | 15 | 1 | 3 | 0 | 0 | 0 | 0 | 11 | 27% | 7% of 15 |
| Operator training | 15 | 1 | 3 | 0 | 0 | 0 | 0 | 11 | 27% | 7% of 15 |
| Fail-safe | 15 | 1 | 3 | 0 | 0 | 0 | 0 | 11 | 27% | 7% of 15 |
| Appeal process | 15 | 0 | 3 | 0 | 1 | 0 | 0 | 11 | 27% | 0% of 14 |
| User and public consultation | 15 | 1 | 3 | 0 | 0 | 0 | 0 | 11 | 27% | 7% 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.
| Testing | Impact assess. | Indep. review | Monitoring | Training | Fail-safe | Appeal | Consultation | n | |
|---|---|---|---|---|---|---|---|---|---|
| DOJ | 0% | 0% | 0% | 0% | 0% | 0% | 0% | 0% | 9 |
| DHS | 33% | 33% | 33% | 33% | 33% | 33% | 0% | 33% | 3 |
| HHS | – | – | – | – | – | – | – | – | 2 |
| VA | – | – | – | – | – | – | – | – | 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 |
|---|---|---|---|---|---|---|---|---|---|
| Financial and Cryptocurrency Analysis: Federal Partner DOJ · DOJ-0083 | 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 |
| Financial and Cryptocurrency Analysis: Commercial Solution DOJ · DOJ-0084 | 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 |
| ServiceNow DOJ · DOJ-0107 | Deployed | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported |
| Data Synthesis, Sentiment, Filtering, and Location Linking DOJ · DOJ-0121 | 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 |
| Procurement Data Triage Tool DOJ · DOJ-0267 | Deployed | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported |
| Analytics-Driven Supplement Evaluation (ASE) HHS · R0818 | Deployed | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported |
| Renamed: FAR-based Facility Signal Detection Tool
Previously: Post-market Surveillance Reports Signal Detection and Cluster Analysis. HHS · R0819 | Deployed | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported |
| Smartphone Information Forensics Triage DHS · DHS-2705 | Pre-deployment | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported |
| AI Resume & ATS App DHS · DHS-2721 | Pre-deployment | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported |
| Narrative Analysis for Fusion Desktop DOJ · DOJ-0190 | Pre-deployment | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported |
| Narrative Analysis for DOJ MIS DOJ · DOJ-0191 | Pre-deployment | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported |
| Entity Extraction and Summarization DOJ · DOJ-0300 | Pre-deployment | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported |
| AI-Enabled Workflow Automation DOJ · DOJ-0335 | Pre-deployment | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported |
| VAHC CRM- Veteran Self-Service VA · VA-25-5693 | Pre-deployment | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported |
Unanswered analytical questions
Generated from the data; for follow-up with agencies- 3 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?
- 1 high-impact use cases mark an appeal process as not applicable. On what basis was each individual outcome judged not contestable?
- 3 high-impact use cases report using PII but give no link to a Privacy Impact Assessment. Is a PIA published elsewhere?
These are questions the inventory raises but cannot answer. They are not findings of non-compliance.