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: 13 records · deployed high-impact use casesReported in placeReported in progressNot applicablePrecluded by law or guidanceOther or ambiguous answerNo answer reported
Pre-deployment testing
Pre-deployment testing
Reported in place: 4 (30.8%)Pre-deployment testing
Reported in progress: 3 (23.1%)Pre-deployment testing
No answer reported: 6 (46.2%)
13Reported in place: 4 (30.8%)Pre-deployment testing
Reported in progress: 3 (23.1%)Pre-deployment testing
No answer reported: 6 (46.2%)
AI impact assessment
AI impact assessment
Reported in place: 3 (23.1%)AI impact assessment
Reported in progress: 4 (30.8%)AI impact assessment
No answer reported: 6 (46.2%)
13Reported in place: 3 (23.1%)AI impact assessment
Reported in progress: 4 (30.8%)AI impact assessment
No answer reported: 6 (46.2%)
Independent review
Independent review
Reported in place: 3 (23.1%)Independent review
Reported in progress: 4 (30.8%)Independent review
No answer reported: 6 (46.2%)
13Reported in place: 3 (23.1%)Independent review
Reported in progress: 4 (30.8%)Independent review
No answer reported: 6 (46.2%)
Ongoing monitoring
Ongoing monitoring
Reported in place: 4 (30.8%)Ongoing monitoring
Reported in progress: 3 (23.1%)Ongoing monitoring
No answer reported: 6 (46.2%)
13Reported in place: 4 (30.8%)Ongoing monitoring
Reported in progress: 3 (23.1%)Ongoing monitoring
No answer reported: 6 (46.2%)
Operator training
Operator training
Reported in place: 4 (30.8%)Operator training
Reported in progress: 3 (23.1%)Operator training
No answer reported: 6 (46.2%)
13Reported in place: 4 (30.8%)Operator training
Reported in progress: 3 (23.1%)Operator training
No answer reported: 6 (46.2%)
Fail-safe
Fail-safe
Reported in place: 3 (23.1%)Fail-safe
Reported in progress: 3 (23.1%)Fail-safe
Not applicable: 1 (7.7%)Fail-safe
No answer reported: 6 (46.2%)
13Reported in place: 3 (23.1%)Fail-safe
Reported in progress: 3 (23.1%)Fail-safe
Not applicable: 1 (7.7%)Fail-safe
No answer reported: 6 (46.2%)
| 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 | 13 | 4 | 3 | 0 | 0 | 0 | 0 | 6 | 54% | 31% of 13 |
| AI impact assessment | 13 | 3 | 4 | 0 | 0 | 0 | 0 | 6 | 54% | 23% of 13 |
| Independent review | 13 | 3 | 4 | 0 | 0 | 0 | 0 | 6 | 54% | 23% of 13 |
| Ongoing monitoring | 13 | 4 | 3 | 0 | 0 | 0 | 0 | 6 | 54% | 31% of 13 |
| Operator training | 13 | 4 | 3 | 0 | 0 | 0 | 0 | 6 | 54% | 31% of 13 |
| Fail-safe | 13 | 3 | 3 | 0 | 1 | 0 | 0 | 6 | 54% | 25% of 12 |
| Appeal process | 13 | 0 | 3 | 0 | 3 | 1 | 0 | 6 | 54% | 0% of 9 |
| User and public consultation | 13 | 1 | 4 | 0 | 0 | 0 | 2 | 6 | 54% | 8% of 13 |
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 | – | – | – | – | – | – | – | – | 6 |
| DOJ | 0% | 0% | 0% | 0% | 0% | 0% | 0% | 0% | 3 |
| DHS | 100% | 100% | 100% | 100% | 100% | 100% | 0% | 50% | 2 |
| EPA | 100% | 0% | 0% | 100% | 100% | 0% | 0% | 0% | 1 |
| SSA | 100% | 100% | 100% | 100% | 100% | 100% | 0% | 0% | 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
10 records with at least one practice unanswered or in progressOpen in explorer| Use case | Stage | Test | AIA | Review | Monitor | Train | Fail-safe | Appeal | Consult |
|---|---|---|---|---|---|---|---|---|---|
| Financial and Cryptocurrency Analysis: Federal Partner DOJ · DOJ-0083 | 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 |
| Financial and Cryptocurrency Analysis: Commercial Solution DOJ · DOJ-0084 | 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 |
| Data Synthesis, Sentiment, Filtering, and Location Linking DOJ · DOJ-0121 | 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 |
| RCRA PA EPA · 78 | Deployed | Reported in place | Reported in progress | Reported in progress | Reported in place | Reported in place | Not applicable | Not applicable | Reported in progress |
| Heuristic Behavior Analytics VA · VA-25-2537 | 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 |
| AIDOC BriefCase VA · VA-24-1803 | 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 |
| VA CART SYNTAX Risk Model VA · VA-24-5542 | 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 |
| VA CART Mortality Model VA · VA-24-5583 | 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 |
| VA CART Nephropathy Risk Model VA · VA-24-5624 | 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 |
| VA CART Bleeding Risk Model VA · VA-24-5788 | 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 13 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?
- 4 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 mark an appeal process as not applicable. On what basis was each individual outcome judged not contestable?
- 4 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.