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: 11 records · all use cases in the current filterReported in place: 2 (18.2%)AI impact assessment
Reported in progress: 6 (54.5%)AI impact assessment
No answer reported: 3 (27.3%)
Reported in place: 3 (27.3%)Independent review
Reported in progress: 7 (63.6%)Independent review
No answer reported: 1 (9.1%)
Reported in place: 5 (45.5%)Fail-safe
Reported in progress: 3 (27.3%)Fail-safe
Not applicable: 3 (27.3%)
Reported in place: 2 (18.2%)Appeal process
Reported in progress: 1 (9.1%)Appeal process
Not applicable: 8 (72.7%)
Reported in place: 8 (72.7%)User and public consultation
Other or ambiguous answer: 3 (27.3%)
| 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 | 11 | 11 | 0 | 0 | 0 | 0 | 0 | 0 | 100% | 100% of 11 |
| AI impact assessment | 11 | 2 | 6 | 0 | 0 | 0 | 0 | 3 | 73% | 18% of 11 |
| Independent review | 11 | 3 | 7 | 0 | 0 | 0 | 0 | 1 | 91% | 27% of 11 |
| Ongoing monitoring | 11 | 0 | 11 | 0 | 0 | 0 | 0 | 0 | 100% | 0% of 11 |
| Operator training | 11 | 4 | 7 | 0 | 0 | 0 | 0 | 0 | 100% | 36% of 11 |
| Fail-safe | 11 | 5 | 3 | 0 | 3 | 0 | 0 | 0 | 100% | 63% of 8 |
| Appeal process | 11 | 2 | 1 | 0 | 8 | 0 | 0 | 0 | 100% | 67% of 3 |
| User and public consultation | 11 | 8 | 0 | 0 | 0 | 0 | 3 | 0 | 100% | 73% of 11 |
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 | 100% | 0% | 40% | 0% | 20% | 100% | 0% | 100% | 5 |
| DHS | 100% | 0% | 0% | 0% | 25% | 0% | 100% | 25% | 4 |
| TREAS | 100% | 100% | 0% | 0% | 100% | 100% | 0% | 100% | 1 |
| SSA | 100% | 100% | 100% | 0% | 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
11 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 |
| CBP Translate DHS · DHS-2388 | Deployed | Reported in place | Reported in progress | Reported in progress | Reported in progress | Reported in place | Not applicable | Not applicable | Reported in place |
| 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 |
| Argo DOE · DOE-499 | Deployed | Reported in place | No answer reported | No answer reported | Reported in progress | Reported in place | Reported in place | Not applicable | Reported in place |
| GitHub Co-Pilot DOE · DOE-571 | Deployed | Reported in place | No answer reported | Reported in place | Reported in progress | Reported in progress | Not applicable | Not applicable | Reported in place |
| Groundwater Modeling DOE · DOE-659 | Deployed | Reported in place | Reported in progress | Reported in progress | Reported in progress | Reported in progress | Reported in place | Not applicable | Reported in place |
| GenAI Productivity Tool TREAS · TREASURY-OCIO-001 | Deployed | Reported in place | Reported in place | Reported in progress | Reported in progress | Reported in place | Reported in place | Reported in progress | Reported in place |
| Microsoft Co-Pilot DOE · DOE-518 | Pilot | Reported in place | No answer reported | Reported in place | Reported in progress | Reported in progress | Not applicable | Not applicable | Reported in place |
| Soil Moisture Modeling DOE · DOE-545 | Pilot | Reported in place | Reported in progress | Reported in progress | Reported in progress | Reported in progress | 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?
- 3 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?
These are questions the inventory raises but cannot answer. They are not findings of non-compliance.