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 designated high-impact

Reported 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%)

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%)

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%)

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%)

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%)

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%)

Appeal process

Appeal process
Reported in progress: 1 (6.7%)Appeal process
Not applicable: 1 (6.7%)Appeal process
No answer reported: 13 (86.7%)

User and public consultation

User and public consultation
Reported in progress: 1 (6.7%)User and public consultation
Other or ambiguous answer: 1 (6.7%)User and public consultation
No answer reported: 13 (86.7%)

Practice	In scope	In place	In progress	N/A	Other	No answer	Answered	In place of applicable
Pre-deployment testing	15	1	1	0	0	13	13%	7% of 15
AI impact assessment	15	1	1	0	0	13	13%	7% of 15
Independent review	15	1	1	0	0	13	13%	7% of 15
Ongoing monitoring	15	1	1	0	0	13	13%	7% of 15
Operator training	15	1	1	0	0	13	13%	7% of 15
Fail-safe	15	1	1	0	0	13	13%	7% of 15
Appeal process	15	0	1	1	0	13	13%	0% of 14
User and public consultation	15	0	1	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.

Agency-by-safeguard heatmap

Cell: share with any answerIn place Answered

Agency by governance practice
	Testing	Impact assess.	Indep. review	Monitoring	Training	Fail-safe	Appeal	Consultation	n
VA									5
DOJ	33%	33%	33%	33%	33%	33%	33%	33%	3
DHS	50%	50%	50%	50%	50%	50%	50%	50%	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.