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: 78 records · all use cases in the current filterReported in placeReported in progressNot applicablePrecluded by law or guidanceWaived by CAIOOther or ambiguous answerNo answer reported
AI impact assessment
AI impact assessment
Reported in place: 62 (79.5%)AI impact assessment
Reported in progress: 10 (12.8%)AI impact assessment
No answer reported: 6 (7.7%)
78Reported in place: 62 (79.5%)AI impact assessment
Reported in progress: 10 (12.8%)AI impact assessment
No answer reported: 6 (7.7%)
Independent review
Independent review
Reported in place: 67 (85.9%)Independent review
Reported in progress: 7 (9.0%)Independent review
Waived by CAIO: 1 (1.3%)Independent review
No answer reported: 3 (3.8%)
78Reported in place: 67 (85.9%)Independent review
Reported in progress: 7 (9.0%)Independent review
Waived by CAIO: 1 (1.3%)Independent review
No answer reported: 3 (3.8%)
Operator training
Operator training
Reported in place: 75 (96.2%)Operator training
Reported in progress: 2 (2.6%)Operator training
Other or ambiguous answer: 1 (1.3%)
78Reported in place: 75 (96.2%)Operator training
Reported in progress: 2 (2.6%)Operator training
Other or ambiguous answer: 1 (1.3%)
| 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 | 78 | 78 | 0 | 0 | 0 | 0 | 0 | 0 | 100% | 100% of 78 |
| AI impact assessment | 78 | 62 | 10 | 0 | 0 | 0 | 0 | 6 | 92% | 79% of 78 |
| Independent review | 78 | 67 | 7 | 0 | 0 | 1 | 0 | 3 | 96% | 87% of 77 |
| Ongoing monitoring | 78 | 78 | 0 | 0 | 0 | 0 | 0 | 0 | 100% | 100% of 78 |
| Operator training | 78 | 75 | 2 | 0 | 0 | 0 | 1 | 0 | 100% | 96% of 78 |
| Fail-safe | 78 | 52 | 0 | 0 | 26 | 0 | 0 | 0 | 100% | 100% of 52 |
| Appeal process | 78 | 22 | 0 | 0 | 50 | 3 | 0 | 3 | 96% | 88% of 25 |
| User and public consultation | 78 | 44 | 2 | 0 | 0 | 0 | 32 | 0 | 100% | 56% of 78 |
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% | 93% | 93% | 100% | 96% | 100% | 100% | 61% | 28 |
| DOE | 100% | 47% | 78% | 100% | 95% | 100% | 70% | 58% | 19 |
| SBA | 100% | 100% | 100% | 100% | 100% | 100% | 100% | 65% | 17 |
| SSA | 100% | 100% | 100% | 100% | 100% | 100% | 100% | 14% | 7 |
| FERC | 100% | 100% | 100% | 100% | 100% | 100% | 0% | 100% | 2 |
| STATE | 100% | 0% | 0% | 100% | 100% | 100% | 100% | 100% | 2 |
| DOL | 100% | 100% | 100% | 100% | 0% | 0% | 100% | 0% | 1 |
| USDA | 100% | 0% | 0% | 100% | 100% | 100% | 100% | 0% | 1 |
| EPA | 100% | 0% | 0% | 100% | 100% | 0% | 0% | 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 |
|---|---|---|---|---|---|---|---|---|---|
| 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 |
| AI for Operations Center DOE · DOE-10 | Deployed | Reported in place | No answer reported | No answer reported | Reported in place | Reported in place | Reported in place | No answer reported | Reported in place |
| ServiceNow Predictive Intelligence DOE · DOE-430 | Deployed | Reported in place | Reported in progress | Reported in place | Reported in place | Reported in place | Not applicable | Not applicable | Reported in place |
| Hanford Ai Liaison (HAL) 1.1 DOE · DOE-469 | Deployed | Reported in place | No answer reported | Reported in place | Reported in place | Reported in place | Not applicable | Not applicable | Reported in place |
| OPQ-AI DOE · DOE-477 | Deployed | Reported in place | No answer reported | No answer reported | Reported in place | Reported in place | Reported in place | No answer reported | Reported in place |
| LANL AI Portal DOE · DOE-495 | Deployed | Reported in place | Reported in progress | Reported in place | Reported in place | Reported in place | Not applicable | Not applicable | Reported in place |
| ChatGPT Enterprise DOE · DOE-498 | Deployed | Reported in place | Reported in progress | Reported in place | Reported in place | Reported in place | Not applicable | Not applicable | Reported in place |
| GitHub Copilot DOE · DOE-586 | Deployed | Reported in place | Reported in place | Reported in place | Reported in place | Reported in progress | Reported in place | Not applicable | Reported in place |
| Invoice Scanning System DOE · DOE-632 | Deployed | Reported in place | No answer reported | Reported in place | Reported in place | Reported in place | Not applicable | Not applicable | Reported in place |
| pComply-AI-High Risk DOE · DOE-658 | Deployed | Reported in place | No answer reported | No answer reported | Reported in place | Reported in place | Reported in place | No answer reported | Reported in place |
| RCRA PA EPA · 78 | Deployed | Reported in place | Reported in progress | Reported in progress | Reported in place | Reported in place | Not applicable | Not applicable | Reported in progress |
| 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 |
| 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 |
| Hanford Ai Liaison (HAL) 2.0 DOE · DOE-653 | Pre-deployment | Reported in place | No answer reported | Reported in place | Reported in place | Reported in place | Not applicable | 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?
- 24 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?
- 20 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.