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: 37 records · use cases designated high-impact

Reported in placeReported in progressNot applicablePrecluded by law or guidanceOther or ambiguous answerNo answer reported

Pre-deployment testing

Pre-deployment testing
Reported in place: 33 (89.2%)Pre-deployment testing
Reported in progress: 3 (8.1%)Pre-deployment testing
No answer reported: 1 (2.7%)

AI impact assessment

AI impact assessment
Reported in place: 30 (81.1%)AI impact assessment
Reported in progress: 7 (18.9%)

Independent review

Independent review
Reported in place: 30 (81.1%)Independent review
Reported in progress: 6 (16.2%)Independent review
No answer reported: 1 (2.7%)

Ongoing monitoring

Ongoing monitoring
Reported in place: 32 (86.5%)Ongoing monitoring
Reported in progress: 4 (10.8%)Ongoing monitoring
No answer reported: 1 (2.7%)

Operator training

Operator training
Reported in place: 34 (91.9%)Operator training
Reported in progress: 2 (5.4%)Operator training
No answer reported: 1 (2.7%)

Fail-safe

Fail-safe
Reported in place: 37 (100.0%)

Appeal process

Appeal process
Reported in place: 11 (29.7%)Appeal process
Not applicable: 23 (62.2%)Appeal process
Precluded by law or guidance: 3 (8.1%)

User and public consultation

User and public consultation
Reported in place: 21 (56.8%)User and public consultation
Reported in progress: 1 (2.7%)User and public consultation
Other or ambiguous answer: 15 (40.5%)

Practice	In scope	In place	In progress	N/A	Precluded or waived	Other	No answer	Answered	In place of applicable
Pre-deployment testing	37	33	3	0	0	0	1	97%	89% of 37
AI impact assessment	37	30	7	0	0	0	0	100%	81% of 37
Independent review	37	30	6	0	0	0	1	97%	81% of 37
Ongoing monitoring	37	32	4	0	0	0	1	97%	86% of 37
Operator training	37	34	2	0	0	0	1	97%	92% of 37
Fail-safe	37	37	0	0	0	0	0	100%	100% of 37
Appeal process	37	11	0	23	3	0	0	100%	100% of 11
User and public consultation	37	21	1	0	0	15	0	100%	57% of 37

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 reported in place, among applicable recordsIn place Answered

Agency by governance practice
	Testing	Impact assess.	Indep. review	Monitoring	Training	Fail-safe	Appeal	Consultation	n
DHS	96%	88%	88%	96%	92%	100%	100%	67%	24
SSA	88%	88%	88%	75%	88%	100%	100%	38%	8
STATE	100%	0%	0%	100%	100%	100%	100%	100%	2
DOE	0%	100%	100%	0%	100%	100%	0%	0%	2
USDA	100%	0%	0%	100%	100%	100%	100%	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
Mobile Fortify DHS · DHS-2731	Deployed	Reported in place	Reported in progress	Reported in progress	Reported in place	Reported in place	Reported in place	Not applicable	Reported in place
Verification Match Model DHS · DHS-2384	Deployed	Reported in place	Reported in progress	Reported in progress	Reported in place	Reported in progress	Reported in place	Reported in place	Reported in progress
Copilot Studio DOE · DOE-444	Deployed	Reported in progress	Reported in place	Reported in place	Reported in progress	Reported in place	Reported in place	Not applicable	Other or ambiguous answer
Copilot for Microsoft 365 DOE · DOE-452	Deployed	Reported in progress	Reported in place	Reported in place	Reported in progress	Reported in place	Reported in place	Not applicable	Other or ambiguous answer
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
AI-Augmented Declassification Review STATE · R3213	Deployed	Reported in place	Reported in progress	Reported in progress	Reported in place	Reported in place	Reported in place	Reported in place	Reported in place
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
Video Surveillance System USDA · USDA-025	Deployed	Reported in place	Reported in progress	Reported in progress	Reported in place	Reported in place	Reported in place	Reported in place	Other or ambiguous answer
FLIR 280 HD DHS · DHS-2745	Pilot	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in place	Not applicable	Other or ambiguous answer
Policy Assistance Tool (PAT) SSA · R3116	Pilot	Reported in place	Reported in place	Reported in place	Reported in progress	Reported in place	Reported in place	Not applicable	Reported in place

Unanswered analytical questions

Generated from the data; for follow-up with agencies

6 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?
23 high-impact use cases mark an appeal process as not applicable. On what basis was each individual outcome judged not contestable?
9 high-impact use cases report using PII but give no link to a Privacy Impact Assessment. Is a PIA published elsewhere?
13 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.