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: 59 records · all use cases in the current filter

Reported in progressOther or ambiguous answerNo answer reported

Pre-deployment testing

Pre-deployment testing
Reported in progress: 8 (13.6%)Pre-deployment testing
No answer reported: 51 (86.4%)

AI impact assessment

AI impact assessment
Reported in progress: 8 (13.6%)AI impact assessment
No answer reported: 51 (86.4%)

Independent review

Independent review
Reported in progress: 8 (13.6%)Independent review
No answer reported: 51 (86.4%)

Ongoing monitoring

Ongoing monitoring
Reported in progress: 8 (13.6%)Ongoing monitoring
No answer reported: 51 (86.4%)

Operator training

Operator training
Reported in progress: 6 (10.2%)Operator training
Other or ambiguous answer: 2 (3.4%)Operator training
No answer reported: 51 (86.4%)

Fail-safe

Fail-safe
Reported in progress: 8 (13.6%)Fail-safe
No answer reported: 51 (86.4%)

Appeal process

Appeal process
Reported in progress: 8 (13.6%)Appeal process
No answer reported: 51 (86.4%)

User and public consultation

User and public consultation
Reported in progress: 8 (13.6%)User and public consultation
No answer reported: 51 (86.4%)

Practice	In scope	In progress	Other	No answer	Answered	In place of applicable
Pre-deployment testing	59	8	0	51	14%	0% of 59
AI impact assessment	59	8	0	51	14%	0% of 59
Independent review	59	8	0	51	14%	0% of 59
Ongoing monitoring	59	8	0	51	14%	0% of 59
Operator training	59	6	2	51	14%	0% of 59
Fail-safe	59	8	0	51	14%	0% of 59
Appeal process	59	8	0	51	14%	0% of 59
User and public consultation	59	8	0	51	14%	0% of 59

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
HHS	–	–	–	–	–	–	–	–	21
DOJ	0%	0%	0%	0%	0%	0%	0%	0%	10
DHS	0%	0%	0%	0%	0%	0%	0%	0%	9
VA	–	–	–	–	–	–	–	–	5
SEC	–	–	–	–	–	–	–	–	2
USDA	–	–	–	–	–	–	–	–	2
DOI	–	–	–	–	–	–	–	–	2
TREAS	–	–	–	–	–	–	–	–	2
SSA	–	–	–	–	–	–	–	–	2
NASA	–	–	–	–	–	–	–	–	1
FRB	–	–	–	–	–	–	–	–	1
DOL	–	–	–	–	–	–	–	–	1
EPA	–	–	–	–	–	–	–	–	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

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

Use case	Stage	Test	AIA	Review	Monitor	Train	Fail-safe	Appeal	Consult
Mobile Fortify DHS · DHS-2577	Deployed	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Other or ambiguous answer	Reported in progress	Reported in progress	Reported in progress
License Plate Capture and Analysis DHS · DHS-2666	Deployed	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Other or ambiguous answer	Reported in progress	Reported in progress	Reported in progress
Cyber Threat Analysis (Recorded Future) DHS · DHS-399	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
Intelligent Document Processing DHS · DHS-2425	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
Text Analytics for Survey Responses (TASR) DHS · DHS-45	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
ELIS Evidence Classifier Service DHS · DHS-16	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
Intelligent Document Processing (IDP) for I-539 Form Digitization DHS · DHS-2385	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
PDF Intake (PDFI) for myUSCIS DHS · DHS-2598	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
License Plate Reader DHS · DHS-2626	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
FOIA Request Lexical Similarity Tool in the Document Review Platform (Term Frequency – Inverse Document Frequency (TF-IDF) - Cosine) DOI · DOI-0020	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
Enabling FOIA Request Clustering Capability in the Document Review Platform (Density Based Algorithm alongside Term Frequency – Inverse Document Frequency (TF-IDF)) DOI · DOI-0019	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
Adobe Suite Applications DOJ · DOJ-0001	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
Unmanned Aerial Systems (UAS) DOJ · DOJ-0003	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
Thomson Reuters CLEAR - License Plate Recognition DOJ · DOJ-0048	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
OCR and Translation DOJ · DOJ-0123	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
Language Translation, Optical Character Recognition (OCR), Object Detection, Language Detection, Alert Noise Reduction DOJ · DOJ-0138	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
Automated Medication Dispensing Cabinet DOJ · DOJ-0143	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
Nlets Nationwide License Plate Reader Pointer Index DOJ · DOJ-0198	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
Optical Character Recognition Tool 2 DOJ · DOJ-0275	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
FOIA Production Tools DOJ · DOJ-0295	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
Fingerprint (Friction Ridge) Optical Character Recognition (OCR) DOJ · DOJ-0296	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
Automatic Document Processing DOL · DOL-13	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
Microsoft Power Automate (custom document processing model) EPA · 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
PDF Optical Character Recognition (Text) FRB · FRB-0003	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
Structuring Notice of Concern Data HHS · R0600	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
Document Review for Alignment with Executive Orders: Position Descriptions HHS · R0617	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
Document Review for Alignment with Executive Orders: Grant Materials HHS · R0618	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
Grant management support: structuring information in applications HHS · R0619	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
CDC Chatbot HHS · R0669	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
Quality Surveillance Dashboard (QSD) HHS · R0821	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
Annual Report CMC HHS · R0822	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: Application References Previously: Application-DMF Reference HHS · R0823	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: Extracting DMF Facilities from unstructured documents Previously: DMF (Drug Master File) Facilities HHS · R0824	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: Information Visualization Platform (InfoViP) to Support Analysis of FAERS safety reports Previously: Information Visualization Platform (InfoViP) to Support Analysis of adverse event reports HHS · R0825	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: Module 3 Facilities Extraction Previously: Module 3 Faculties HHS · R0827	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
Packaging Materials and Suppliers HHS · R0828	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
Real World Data/Evidence HHS · R0830	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
Regulatory Starting Material HHS · R0831	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
Category Subcategory Classification - Safety Reports Bot HHS · R0841	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 Extraction from IND Safety Reports using OCR/AI Technologies HHS · R0842	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
Machine Learning as a Service: Translate and extract text from images using AI HHS · R0876	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
Machine Learning as a Service: Extract data from product labels, business forms, and image files HHS · R0877	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
DAIT AIDS-Related Research Solution HHS · R0912	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
NCI-DOE Collaboration, MOSSAIC project (Modeling Outcomes using Surveillance Data and Scalable AI for Cancer) HHS · R0927	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
TB Case Browser Image Text Detection HHS · R0945	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
NextGen Data Analytics: Letters of Agreement NASA · NASA-26	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
Optical Character Recognition (OCR) for Records Analysis SEC · SEC-33	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
Extracting data from FOIA request forms SEC · SEC-40	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
Handwriting Recognition of Forms; Intelligent Document Processing Platform - Forms Classification and Data Extraction SSA · R3098	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
Mobile Wage Reporting SSA · R3105	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
FORMS AI TREAS · REQ-2025-02100	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
Line-Item Consolidation for Form 1120 TREAS · TREAS-IRS-4	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
Automated PDF Document Processing and Information Extraction USDA · USDA-033	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
Dam Inspection Report Document Processing USDA · USDA-048	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
Automated Claims Processing VA · VA-24-1938	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
Mail Automation Services VA · VA-24-4763	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
Venue Fit VA · VA-24-4238	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
eDiscovery (VASI 2460): Predictive Coding VA · VA-25-3234	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
Auto Doc ID VA · VA-25-733	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

Unanswered analytical questions

Generated from the data; for follow-up with agencies

VA 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?
8 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?
7 high-impact use cases report using PII but give no link to a Privacy Impact Assessment. Is a PIA published elsewhere?
2 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.