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: 21 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 (4.8%)Pre-deployment testing
Reported in progress: 1 (4.8%)Pre-deployment testing
No answer reported: 19 (90.5%)
21Reported in place: 1 (4.8%)Pre-deployment testing
Reported in progress: 1 (4.8%)Pre-deployment testing
No answer reported: 19 (90.5%)
AI impact assessment
AI impact assessment
Reported in progress: 2 (9.5%)AI impact assessment
No answer reported: 19 (90.5%)
21Reported in progress: 2 (9.5%)AI impact assessment
No answer reported: 19 (90.5%)
Independent review21
Ongoing monitoring
Ongoing monitoring
Reported in place: 1 (4.8%)Ongoing monitoring
Reported in progress: 1 (4.8%)Ongoing monitoring
No answer reported: 19 (90.5%)
21Reported in place: 1 (4.8%)Ongoing monitoring
Reported in progress: 1 (4.8%)Ongoing monitoring
No answer reported: 19 (90.5%)
Operator training
Operator training
Reported in place: 1 (4.8%)Operator training
Other or ambiguous answer: 1 (4.8%)Operator training
No answer reported: 19 (90.5%)
21Reported in place: 1 (4.8%)Operator training
Other or ambiguous answer: 1 (4.8%)Operator training
No answer reported: 19 (90.5%)
Fail-safe
Fail-safe
Reported in place: 1 (4.8%)Fail-safe
Reported in progress: 1 (4.8%)Fail-safe
No answer reported: 19 (90.5%)
21Reported in place: 1 (4.8%)Fail-safe
Reported in progress: 1 (4.8%)Fail-safe
No answer reported: 19 (90.5%)
| 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 | 21 | 1 | 1 | 0 | 0 | 0 | 0 | 19 | 10% | 5% of 21 |
| AI impact assessment | 21 | 0 | 2 | 0 | 0 | 0 | 0 | 19 | 10% | 0% of 21 |
| Independent review | 21 | 0 | 2 | 0 | 0 | 0 | 0 | 19 | 10% | 0% of 21 |
| Ongoing monitoring | 21 | 1 | 1 | 0 | 0 | 0 | 0 | 19 | 10% | 5% of 21 |
| Operator training | 21 | 1 | 0 | 0 | 0 | 0 | 1 | 19 | 10% | 5% of 21 |
| Fail-safe | 21 | 1 | 1 | 0 | 0 | 0 | 0 | 19 | 10% | 5% of 21 |
| Appeal process | 21 | 0 | 1 | 0 | 1 | 0 | 0 | 19 | 10% | 0% of 20 |
| User and public consultation | 21 | 1 | 1 | 0 | 0 | 0 | 0 | 19 | 10% | 5% of 21 |
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 | – | – | – | – | – | – | – | – | 10 |
| DOJ | – | – | – | – | – | – | – | – | 6 |
| DHS | 0% | 0% | 0% | 0% | 0% | 0% | 0% | 0% | 3 |
| NASA | – | – | – | – | – | – | – | – | 1 |
| STATE | 100% | 0% | 0% | 100% | 100% | 100% | 0% | 100% | 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
21 records with at least one practice unanswered or in progressOpen in explorer| Use case | Stage | Test | AIA | Review | Monitor | Train | Fail-safe | Appeal | Consult |
|---|---|---|---|---|---|---|---|---|---|
| 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 |
| Intelligent Camera Analytics for Security and Operations NASA · NASA-753 | 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 |
| Electronic Health Record AI Enhancements STATE · R3248 | Deployed | Reported in place | Reported in progress | Reported in progress | Reported in place | Reported in place | Reported in place | Not applicable | Reported in place |
| Automated Decision Support VA · VA-24-4722 | 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 |
| Continuous Glucose Monitoring Summary VA · VA-25-1506 | 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 |
| Sleep Apnea VA · VA-25-2168 | 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 |
| Smartphone Information Forensics Triage DHS · DHS-2705 | 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 |
| Electronic Evidence/Video Recording Transcription and Summarization Tool DHS · DHS-2399 | 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 |
| FinCEN Data Summarization DOJ · DOJ-0185 | 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 |
| Narrative Analysis for Fusion Desktop DOJ · DOJ-0190 | 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 |
| Narrative Analysis for DOJ MIS DOJ · DOJ-0191 | 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 |
| Voicemail Transcription, Translation and Summarization DOJ · DOJ-0243 | 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 |
| Immigration Case and Filing Content Summary DOJ · DOJ-0288 | 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 |
| AI Evidence and Claim Consolidation DOJ · DOJ-0347 | 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 |
| Summarization of Clinical Data VA · VA-25-6276 | 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 |
| Automated Ratings Summarization VA · VA-25-1594 | 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 |
| Summarize Progress Notes VA · VA-24-3365 | 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 |
| Deduplication in Record Management VA · VA-25-1430 | 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 |
| Ambient Scribing with Patient Chart Exploration VA · VA-25-3149 | 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 |
| JLV Booster VA · VA-25-3415 | 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 |
| Patient Care Services Integration Platform (PCSIP) VA · VA-24-421 | 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 |
Unanswered analytical questions
Generated from the data; for follow-up with agencies- VA designated 10 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?
- DOJ designated 6 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?
- 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?
- 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?
- 5 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.