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: 47 records · use cases that answered at least one practice question

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

Pre-deployment testing

Pre-deployment testing
Reported in place: 36 (76.6%)Pre-deployment testing
Reported in progress: 11 (23.4%)

AI impact assessment

AI impact assessment
Reported in place: 32 (68.1%)AI impact assessment
Reported in progress: 14 (29.8%)AI impact assessment
No answer reported: 1 (2.1%)

Independent review

Independent review
Reported in place: 32 (68.1%)Independent review
Reported in progress: 6 (12.8%)Independent review
No answer reported: 9 (19.1%)

Ongoing monitoring

Ongoing monitoring
Reported in place: 32 (68.1%)Ongoing monitoring
Reported in progress: 6 (12.8%)Ongoing monitoring
No answer reported: 9 (19.1%)

Operator training

Operator training
Reported in place: 33 (70.2%)Operator training
Reported in progress: 4 (8.5%)Operator training
Other or ambiguous answer: 1 (2.1%)Operator training
No answer reported: 9 (19.1%)

Fail-safe

Fail-safe
Reported in place: 27 (57.4%)Fail-safe
Reported in progress: 3 (6.4%)Fail-safe
Not applicable: 17 (36.2%)

Appeal process

Appeal process
Reported in place: 15 (31.9%)Appeal process
Not applicable: 30 (63.8%)Appeal process
Precluded by law or guidance: 2 (4.3%)

User and public consultation

User and public consultation
Other or ambiguous answer: 47 (100.0%)

Practice	In scope	In place	In progress	N/A	Precluded or waived	Other	No answer	Answered	In place of applicable
Pre-deployment testing	47	36	11	0	0	0	0	100%	77% of 47
AI impact assessment	47	32	14	0	0	0	1	98%	68% of 47
Independent review	47	32	6	0	0	0	9	81%	68% of 47
Ongoing monitoring	47	32	6	0	0	0	9	81%	68% of 47
Operator training	47	33	4	0	0	1	9	81%	70% of 47
Fail-safe	47	27	3	17	0	0	0	100%	90% of 30
Appeal process	47	15	0	30	2	0	0	100%	100% of 15
User and public consultation	47	0	0	0	0	47	0	100%	0% of 47

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
DOE	47%	47%	47%	42%	53%	100%	100%	0%	19
DHS	93%	71%	71%	71%	71%	70%	100%	0%	14
SSA	100%	100%	100%	100%	100%	100%	100%	0%	6
SBA	100%	100%	100%	100%	100%	100%	100%	0%	6
DOL	100%	100%	100%	100%	0%	0%	100%	0%	1
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

17 records with at least one practice unanswered or in progressOpen in explorer

Use case	Stage	Test	AIA	Review	Monitor	Train	Fail-safe	Appeal	Consult
Babel DHS · DHS-185	Deployed	Reported in place	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in place	Other or ambiguous answer
Passive Body Scanner DHS · DHS-2380	Deployed	Reported in place	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Not applicable	Other or ambiguous answer
Traffic Jam DHS · DHS-2570	Deployed	Reported in place	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in progress	Reported in place	Other or ambiguous answer
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
LivChat DOE · DOE-613	Deployed	Reported in place	No answer reported	No answer reported	No answer reported	No answer reported	Not applicable	Not applicable	Other or ambiguous answer
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
Bernie-AI: Infrastructure Planning Support POC DOE · DOE-514	Pilot	Reported in progress	Reported in progress	No answer reported	No answer reported	No answer reported	Not applicable	Not applicable	Other or ambiguous answer
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
NIF Shot Analytics & Predictive Maintenance Support Pilot DOE · DOE-529	Pilot	Reported in progress	Reported in progress	No answer reported	No answer reported	No answer reported	Not applicable	Not applicable	Other or ambiguous answer
M365 Copilot DOE · DOE-574	Pilot	Reported in place	Reported in progress	Reported in progress	Reported in place	Reported in place	Reported in place	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
LISA Chatbot Pilot DOE · DOE-671	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
Amazon Q Chatbot Pilot DOE · DOE-700	Pre-deployment	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

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?
15 high-impact use cases mark an appeal process as not applicable. On what basis was each individual outcome judged not contestable?
11 high-impact use cases report using PII but give no link to a Privacy Impact Assessment. Is a PIA published elsewhere?
8 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.