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 · use cases designated high-impactReported in placeReported in progressNot applicableOther or ambiguous answerNo answer reported
Pre-deployment testing
Pre-deployment testing
Reported in place: 1 (6.7%)Pre-deployment testing
Reported in progress: 1 (6.7%)Pre-deployment testing
No answer reported: 13 (86.7%)
15Reported in place: 1 (6.7%)Pre-deployment testing
Reported in progress: 1 (6.7%)Pre-deployment testing
No answer reported: 13 (86.7%)
AI impact assessment
AI impact assessment
Reported in place: 1 (6.7%)AI impact assessment
Reported in progress: 1 (6.7%)AI impact assessment
No answer reported: 13 (86.7%)
15Reported in place: 1 (6.7%)AI impact assessment
Reported in progress: 1 (6.7%)AI impact assessment
No answer reported: 13 (86.7%)
Independent review
Independent review
Reported in place: 1 (6.7%)Independent review
Reported in progress: 1 (6.7%)Independent review
No answer reported: 13 (86.7%)
15Reported in place: 1 (6.7%)Independent review
Reported in progress: 1 (6.7%)Independent review
No answer reported: 13 (86.7%)
Ongoing monitoring
Ongoing monitoring
Reported in place: 1 (6.7%)Ongoing monitoring
Reported in progress: 1 (6.7%)Ongoing monitoring
No answer reported: 13 (86.7%)
15Reported in place: 1 (6.7%)Ongoing monitoring
Reported in progress: 1 (6.7%)Ongoing monitoring
No answer reported: 13 (86.7%)
Operator training
Operator training
Reported in place: 1 (6.7%)Operator training
Reported in progress: 1 (6.7%)Operator training
No answer reported: 13 (86.7%)
15Reported in place: 1 (6.7%)Operator training
Reported in progress: 1 (6.7%)Operator training
No answer reported: 13 (86.7%)
Fail-safe
Fail-safe
Reported in place: 1 (6.7%)Fail-safe
Reported in progress: 1 (6.7%)Fail-safe
No answer reported: 13 (86.7%)
15Reported in place: 1 (6.7%)Fail-safe
Reported in progress: 1 (6.7%)Fail-safe
No answer reported: 13 (86.7%)
| 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 | 1 | 0 | 0 | 0 | 0 | 13 | 13% | 7% of 15 |
| AI impact assessment | 15 | 1 | 1 | 0 | 0 | 0 | 0 | 13 | 13% | 7% of 15 |
| Independent review | 15 | 1 | 1 | 0 | 0 | 0 | 0 | 13 | 13% | 7% of 15 |
| Ongoing monitoring | 15 | 1 | 1 | 0 | 0 | 0 | 0 | 13 | 13% | 7% of 15 |
| Operator training | 15 | 1 | 1 | 0 | 0 | 0 | 0 | 13 | 13% | 7% of 15 |
| Fail-safe | 15 | 1 | 1 | 0 | 0 | 0 | 0 | 13 | 13% | 7% of 15 |
| Appeal process | 15 | 0 | 1 | 0 | 1 | 0 | 0 | 13 | 13% | 0% of 14 |
| User and public consultation | 15 | 0 | 1 | 0 | 0 | 0 | 1 | 13 | 13% | 0% 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 | |
|---|---|---|---|---|---|---|---|---|---|
| VA | – | – | – | – | – | – | – | – | 5 |
| DOJ | 0% | 0% | 0% | 0% | 0% | 0% | 0% | 0% | 3 |
| DHS | 50% | 50% | 50% | 50% | 50% | 50% | 0% | 0% | 2 |
| TREAS | – | – | – | – | – | – | – | – | 2 |
| DOE | – | – | – | – | – | – | – | – | 2 |
| NCUA | – | – | – | – | – | – | – | – | 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 |
|---|---|---|---|---|---|---|---|---|---|
| Insider Threat Management and User Activity Monitoring DOJ · DOJ-0119 | 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 |
| Supervisory Stress Testing NCUA · NCUA_ONES-02 | 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 |
| Stratification Tool for Opioid Risk Mitigation (STORM) VA · VA-24-4152 | 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 |
| REACH VET Suicide Risk Prediction and Recovery Engagement VA · VA-24-4234 | 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 |
| Advance RPM Maintenance Operating Reporter (ARMOR) DHS · DHS-314 | 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 |
| Advanced Long Term Environmental Monitoring Systems (ALTEMIS) DOE · DOE-714 | 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 |
| Identifying Controlling Variables for Mercury Vapor Release at Y-12's Alpha-4 DOE · DOE-736 | 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 |
| Enhanced Proactive Financial Analysis Techniques for Fusion Desktop DOJ · DOJ-0184 | 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 |
| Capture and Convert Structured Data from Scanned Case Documents to Support Advanced Analysis and Trend Forecasting DOJ · DOJ-0360 | 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 |
| IRS IaaP Accelerator ( AI-Powered Infrastructure as a Product Accelerator) TREAS · TREAS-IRS-104 | 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 |
| GenAI for Low Code Platform TREAS · TREAS-IRS-46 | 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 |
| Employee Transactions for HR Decision-Making VA · VA-25-897 | 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 |
| Pharmacy AI Managed Inventory System (PHAIMIS) VA · VA-24-2828 | 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 |
| Billing Claims Prediction VA · VA-24-462 | 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- VA designated 5 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?
- 1 high-impact use cases mark an appeal process as not applicable. On what basis was each individual outcome judged not contestable?
- 1 high-impact use cases report using PII but give no link to a Privacy Impact Assessment. Is a PIA published elsewhere?
- 4 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.