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: 22 records · all use cases in the current filterReported in placeReported in progressPrecluded by law or guidanceNo answer reported
AI impact assessment
AI impact assessment
Reported in progress: 1 (4.5%)AI impact assessment
No answer reported: 21 (95.5%)
22Reported in progress: 1 (4.5%)AI impact assessment
No answer reported: 21 (95.5%)
Appeal process22
User and public consultation
User and public consultation
Reported in place: 1 (4.5%)User and public consultation
No answer reported: 21 (95.5%)
22Reported in place: 1 (4.5%)User and public consultation
No answer reported: 21 (95.5%)
| 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 | 22 | 0 | 0 | 0 | 0 | 0 | 0 | 22 | 0% | 0% of 22 |
| AI impact assessment | 22 | 0 | 1 | 0 | 0 | 0 | 0 | 21 | 5% | 0% of 22 |
| Independent review | 22 | 0 | 0 | 0 | 0 | 0 | 0 | 22 | 0% | 0% of 22 |
| Ongoing monitoring | 22 | 0 | 0 | 0 | 0 | 0 | 0 | 22 | 0% | 0% of 22 |
| Operator training | 22 | 0 | 0 | 0 | 0 | 0 | 0 | 22 | 0% | 0% of 22 |
| Fail-safe | 22 | 1 | 0 | 0 | 0 | 0 | 0 | 21 | 5% | 5% of 22 |
| Appeal process | 22 | 0 | 0 | 0 | 0 | 1 | 0 | 21 | 5% | 0% of 21 |
| User and public consultation | 22 | 1 | 0 | 0 | 0 | 0 | 0 | 21 | 5% | 5% of 22 |
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 | |
|---|---|---|---|---|---|---|---|---|---|
| DHS | – | – | – | – | – | – | – | – | 9 |
| DOJ | – | – | – | – | – | – | – | – | 7 |
| HHS | – | – | – | – | – | – | – | – | 2 |
| GSA | – | – | – | – | – | – | – | – | 1 |
| TREAS | – | – | – | – | – | – | – | – | 1 |
| SSA | – | 0% | – | – | – | 100% | 0% | 100% | 1 |
| STATE | – | – | – | – | – | – | – | – | 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
22 records with at least one practice unanswered or in progressOpen in explorer| Use case | Stage | Test | AIA | Review | Monitor | Train | Fail-safe | Appeal | Consult |
|---|---|---|---|---|---|---|---|---|---|
| Process Efficiency Traveler Identity for Airline Check-in and Bag Drop DHS · DHS-2417 | 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 |
| Autonomous Surveillance Tower DHS · DHS-35 | 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 |
| Biometric Check-in for ATD-ISAP (SmartLINK) DHS · DHS-407 | 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 |
| Biometrics Enrollment Tool (BET) Fingerprint Quality Check DHS · DHS-14 | 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 |
| Open-Source Intelligence for Investigations DHS · DHS-2759 | 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 |
| AdaptiveMFA DHS · DHS-419 | 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 |
| Lexis Nexis DHS · DHS-2605 | 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 |
| JPATS Mobile App (Biometrics) DOJ · DOJ-0234 | 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 |
| Aware DOJ · DOJ-0235 | 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 |
| Object Detection Tool 1 DOJ · DOJ-0277 | 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 |
| Login.gov: artificial intelligence technology used for detecting and mitigating fraud for remote unsupervised identity verification GSA · R1167 | 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 |
| Digital Identity Verification Services SSA · R3122 | Deployed | No answer reported | Reported in progress | No answer reported | No answer reported | No answer reported | Reported in place | Precluded by law or guidance | Reported in place |
| Identity Verification TREAS · TREAS-IRS-59 | 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 |
| Program Integrity (RRAD-PI) AI Counter-Fraud Enhancement Measures DHS · DHS-2724 | 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 |
| Facial Recognition for National Security and Transnational Criminal Organizations DHS · DHS-2729 | Pilot | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported |
| Friction Ridge Print Comparisons DOJ · DOJ-0065 | Pilot | 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 & Analytics: Transportation OCR DOJ · DOJ-0073 | 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 |
| Conduit AI DOJ · DOJ-0310 | Pilot | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported |
| Cocounsel AI DOJ · DOJ-0313 | Pilot | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported |
| Unaccompanied Child Sponsor Identity Verification HHS · R0614 | 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 |
| Pathogen strain characterization from mixed strain samples HHS · R0698 | 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 |
| Consular Affairs FaceVACS STATE · R3216 | 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- 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 are reported as deployed while their AI impact assessment is reported in progress. Was deployment authorised before the assessment was complete?
- 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.