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 applicablePrecluded by law or guidanceOther or ambiguous answerNo answer reported
Pre-deployment testing
Pre-deployment testing
Reported in place: 4 (26.7%)Pre-deployment testing
Reported in progress: 1 (6.7%)Pre-deployment testing
No answer reported: 10 (66.7%)
15Reported in place: 4 (26.7%)Pre-deployment testing
Reported in progress: 1 (6.7%)Pre-deployment testing
No answer reported: 10 (66.7%)
AI impact assessment
AI impact assessment
Reported in place: 3 (20.0%)AI impact assessment
Reported in progress: 3 (20.0%)AI impact assessment
No answer reported: 9 (60.0%)
15Reported in place: 3 (20.0%)AI impact assessment
Reported in progress: 3 (20.0%)AI impact assessment
No answer reported: 9 (60.0%)
Independent review
Independent review
Reported in place: 3 (20.0%)Independent review
Reported in progress: 1 (6.7%)Independent review
No answer reported: 11 (73.3%)
15Reported in place: 3 (20.0%)Independent review
Reported in progress: 1 (6.7%)Independent review
No answer reported: 11 (73.3%)
Ongoing monitoring
Ongoing monitoring
Reported in place: 3 (20.0%)Ongoing monitoring
Reported in progress: 1 (6.7%)Ongoing monitoring
No answer reported: 11 (73.3%)
15Reported in place: 3 (20.0%)Ongoing monitoring
Reported in progress: 1 (6.7%)Ongoing monitoring
No answer reported: 11 (73.3%)
Operator training
Operator training
Reported in place: 3 (20.0%)Operator training
Reported in progress: 1 (6.7%)Operator training
No answer reported: 11 (73.3%)
15Reported in place: 3 (20.0%)Operator training
Reported in progress: 1 (6.7%)Operator training
No answer reported: 11 (73.3%)
Fail-safe
Fail-safe
Reported in place: 3 (20.0%)Fail-safe
Reported in progress: 1 (6.7%)Fail-safe
Not applicable: 1 (6.7%)Fail-safe
No answer reported: 10 (66.7%)
15Reported in place: 3 (20.0%)Fail-safe
Reported in progress: 1 (6.7%)Fail-safe
Not applicable: 1 (6.7%)Fail-safe
No answer reported: 10 (66.7%)
| 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 | 4 | 1 | 0 | 0 | 0 | 0 | 10 | 33% | 27% of 15 |
| AI impact assessment | 15 | 3 | 3 | 0 | 0 | 0 | 0 | 9 | 40% | 20% of 15 |
| Independent review | 15 | 3 | 1 | 0 | 0 | 0 | 0 | 11 | 27% | 20% of 15 |
| Ongoing monitoring | 15 | 3 | 1 | 0 | 0 | 0 | 0 | 11 | 27% | 20% of 15 |
| Operator training | 15 | 3 | 1 | 0 | 0 | 0 | 0 | 11 | 27% | 20% of 15 |
| Fail-safe | 15 | 3 | 1 | 0 | 1 | 0 | 0 | 10 | 33% | 21% of 14 |
| Appeal process | 15 | 1 | 1 | 0 | 2 | 1 | 0 | 10 | 33% | 8% of 12 |
| User and public consultation | 15 | 3 | 1 | 0 | 0 | 0 | 1 | 10 | 33% | 20% 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 | |
|---|---|---|---|---|---|---|---|---|---|
| DHS | 50% | 50% | 50% | 50% | 50% | 40% | 25% | 33% | 6 |
| DOJ | 0% | 0% | 0% | 0% | 0% | 0% | 0% | 0% | 2 |
| SSA | 50% | 0% | – | – | – | 50% | 0% | 50% | 2 |
| HHS | – | – | – | – | – | – | – | – | 1 |
| FDIC | – | – | – | – | – | – | – | – | 1 |
| GSA | – | – | – | – | – | – | – | – | 1 |
| VA | – | – | – | – | – | – | – | – | 1 |
| TREAS | – | – | – | – | – | – | – | – | 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
12 records with at least one practice unanswered or in progressOpen in explorer| Use case | Stage | Test | AIA | Review | Monitor | Train | Fail-safe | Appeal | Consult |
|---|---|---|---|---|---|---|---|---|---|
| Passport Anomaly Model DHS · DHS-81 | 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 |
| Empty Container Detection Model (Cargo Insights Team) DHS · DHS-68 | 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 |
| National Insurance Crime Bureau ISO ClaimSearch DOJ · DOJ-0022 | 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 & Analytics: Healthcare Fraud Detection DOJ · DOJ-0071 | 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 |
| Background Check Tool for Fraud Investigations FDIC · FDIC-71 | 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 |
| GrantSolutions Recipient Risk Tool HHS · R1033 | 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 |
| SSA 800# Public Question & Answer Bot and OIG Hotline recording of fraud, waste and abuse. SSA · R3106 | Deployed | Reported in place | Reported in progress | 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 |
| Payment Redirect Fraud (PRF) Model VA · VA-24-3291 | 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- 2 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?
- 2 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?
These are questions the inventory raises but cannot answer. They are not findings of non-compliance.