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: 8 records · use cases that answered at least one practice questionReported in placeReported in progressReported not in placeNot applicableOther or ambiguous answerNo answer reported
Pre-deployment testing
Pre-deployment testing
Reported in place: 2 (25.0%)Pre-deployment testing
Reported in progress: 4 (50.0%)Pre-deployment testing
Reported not in place: 1 (12.5%)Pre-deployment testing
No answer reported: 1 (12.5%)
8Reported in place: 2 (25.0%)Pre-deployment testing
Reported in progress: 4 (50.0%)Pre-deployment testing
Reported not in place: 1 (12.5%)Pre-deployment testing
No answer reported: 1 (12.5%)
AI impact assessment
AI impact assessment
Reported in place: 2 (25.0%)AI impact assessment
Reported in progress: 4 (50.0%)AI impact assessment
No answer reported: 2 (25.0%)
8Reported in place: 2 (25.0%)AI impact assessment
Reported in progress: 4 (50.0%)AI impact assessment
No answer reported: 2 (25.0%)
Independent review
Independent review
Reported in place: 2 (25.0%)Independent review
Reported in progress: 1 (12.5%)Independent review
Reported not in place: 1 (12.5%)Independent review
No answer reported: 4 (50.0%)
8Reported in place: 2 (25.0%)Independent review
Reported in progress: 1 (12.5%)Independent review
Reported not in place: 1 (12.5%)Independent review
No answer reported: 4 (50.0%)
Ongoing monitoring
Ongoing monitoring
Reported in place: 2 (25.0%)Ongoing monitoring
Reported in progress: 1 (12.5%)Ongoing monitoring
No answer reported: 5 (62.5%)
8Reported in place: 2 (25.0%)Ongoing monitoring
Reported in progress: 1 (12.5%)Ongoing monitoring
No answer reported: 5 (62.5%)
Operator training
Operator training
Reported in place: 2 (25.0%)Operator training
Reported in progress: 1 (12.5%)Operator training
No answer reported: 5 (62.5%)
8Reported in place: 2 (25.0%)Operator training
Reported in progress: 1 (12.5%)Operator training
No answer reported: 5 (62.5%)
| 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 | 8 | 2 | 4 | 1 | 0 | 0 | 0 | 1 | 88% | 25% of 8 |
| AI impact assessment | 8 | 2 | 4 | 0 | 0 | 0 | 0 | 2 | 75% | 25% of 8 |
| Independent review | 8 | 2 | 1 | 1 | 0 | 0 | 0 | 4 | 50% | 25% of 8 |
| Ongoing monitoring | 8 | 2 | 1 | 0 | 0 | 0 | 0 | 5 | 38% | 25% of 8 |
| Operator training | 8 | 2 | 1 | 0 | 0 | 0 | 0 | 5 | 38% | 25% of 8 |
| Fail-safe | 8 | 2 | 0 | 0 | 5 | 0 | 0 | 1 | 88% | 67% of 3 |
| Appeal process | 8 | 0 | 0 | 0 | 7 | 0 | 0 | 1 | 88% | 0% of 1 |
| User and public consultation | 8 | 3 | 1 | 0 | 0 | 0 | 4 | 0 | 100% | 38% of 8 |
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 | |
|---|---|---|---|---|---|---|---|---|---|
| DOE | 0% | 0% | – | – | – | 0% | 0% | 0% | 4 |
| FERC | 100% | 100% | 100% | 100% | 100% | 100% | 0% | 100% | 1 |
| EAC | 0% | – | 0% | – | – | – | – | 100% | 1 |
| DOI | – | – | 0% | 0% | 0% | 0% | 0% | 0% | 1 |
| SBA | 100% | 100% | 100% | 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
6 records with at least one practice unanswered or in progressOpen in explorer| Use case | Stage | Test | AIA | Review | Monitor | Train | Fail-safe | Appeal | Consult |
|---|---|---|---|---|---|---|---|---|---|
| OpenAI ChatGPT Pilot DOE · DOE-526 | Pilot | Reported in progress | Reported in progress | No answer reported | No answer reported | No answer reported | Not applicable | Not applicable | Other or ambiguous answer |
| xAI Grok Pilot DOE · DOE-601 | Pilot | Reported in progress | Reported in progress | No answer reported | No answer reported | No answer reported | Not applicable | Not applicable | Other or ambiguous answer |
| Microsoft Copilot Pilot DOE · DOE-676 | Pilot | Reported in progress | Reported in progress | No answer reported | No answer reported | No answer reported | Not applicable | Not applicable | Other or ambiguous answer |
| Anthropic Claude Pilot DOE · DOE-703 | Pilot | Reported in progress | Reported in progress | No answer reported | No answer reported | No answer reported | Not applicable | Not applicable | Other or ambiguous answer |
| CHS Q Business AI Assistant (theKraken) DOI · DOI-0169 | Pilot | No answer reported | No answer reported | Reported in progress | Reported in progress | Reported in progress | Not applicable | Not applicable | Reported in progress |
| Internal Generative AI Tools for Staff Productivity EAC · EAC-2 | Pilot | Reported not in place | No answer reported | Reported not in place | No answer reported | No answer reported | No answer reported | No answer reported | Reported in place |
Unanswered analytical questions
Generated from the data; for follow-up with agencies- 1 high-impact use cases report using PII but give no link to a Privacy Impact Assessment. Is a PIA published elsewhere?
- 2 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.