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 place: 20 (95.2%)Pre-deployment testing
No answer reported: 1 (4.8%)
Reported in place: 17 (81.0%)AI impact assessment
Reported in progress: 4 (19.0%)
Reported in place: 17 (81.0%)Independent review
Reported in progress: 3 (14.3%)Independent review
No answer reported: 1 (4.8%)
Reported in place: 19 (90.5%)Ongoing monitoring
Reported in progress: 1 (4.8%)Ongoing monitoring
No answer reported: 1 (4.8%)
| 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 | 20 | 0 | 0 | 0 | 0 | 0 | 1 | 95% | 95% of 21 |
| AI impact assessment | 21 | 17 | 4 | 0 | 0 | 0 | 0 | 0 | 100% | 81% of 21 |
| Independent review | 21 | 17 | 3 | 0 | 0 | 0 | 0 | 1 | 95% | 81% of 21 |
| Ongoing monitoring | 21 | 19 | 1 | 0 | 0 | 0 | 0 | 1 | 95% | 90% of 21 |
| Operator training | 21 | 20 | 0 | 0 | 0 | 0 | 0 | 1 | 95% | 95% of 21 |
| Fail-safe | 21 | 21 | 0 | 0 | 0 | 0 | 0 | 0 | 100% | 100% of 21 |
| Appeal process | 21 | 7 | 0 | 0 | 13 | 1 | 0 | 0 | 100% | 100% of 7 |
| User and public consultation | 21 | 21 | 0 | 0 | 0 | 0 | 0 | 0 | 100% | 100% 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 | |
|---|---|---|---|---|---|---|---|---|---|
| DHS | 100% | 94% | 94% | 100% | 100% | 100% | 100% | 100% | 16 |
| SSA | 67% | 67% | 67% | 33% | 67% | 100% | 0% | 100% | 3 |
| STATE | 100% | 0% | 0% | 100% | 100% | 100% | 100% | 100% | 2 |
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
5 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 |
| 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 |
| 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- 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?
- 13 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?
- 3 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.