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: 42 records · use cases designated high-impactReported in placeReported in progressNot applicablePrecluded by law or guidanceOther or ambiguous answer
Pre-deployment testing
Pre-deployment testing
Reported in place: 40 (95.2%)Pre-deployment testing
Reported in progress: 2 (4.8%)
42Reported in place: 40 (95.2%)Pre-deployment testing
Reported in progress: 2 (4.8%)
AI impact assessment
AI impact assessment
Reported in place: 36 (85.7%)AI impact assessment
Reported in progress: 6 (14.3%)
42Reported in place: 36 (85.7%)AI impact assessment
Reported in progress: 6 (14.3%)
Independent review42
Ongoing monitoring42
| 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 | 42 | 40 | 2 | 0 | 0 | 0 | 0 | 0 | 100% | 95% of 42 |
| AI impact assessment | 42 | 36 | 6 | 0 | 0 | 0 | 0 | 0 | 100% | 86% of 42 |
| Independent review | 42 | 36 | 6 | 0 | 0 | 0 | 0 | 0 | 100% | 86% of 42 |
| Ongoing monitoring | 42 | 38 | 4 | 0 | 0 | 0 | 0 | 0 | 100% | 90% of 42 |
| Operator training | 42 | 42 | 0 | 0 | 0 | 0 | 0 | 0 | 100% | 100% of 42 |
| Fail-safe | 42 | 34 | 0 | 0 | 8 | 0 | 0 | 0 | 100% | 100% of 34 |
| Appeal process | 42 | 11 | 0 | 0 | 28 | 3 | 0 | 0 | 100% | 100% of 11 |
| User and public consultation | 42 | 22 | 1 | 0 | 0 | 0 | 19 | 0 | 100% | 52% of 42 |
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% | 96% | 100% | 100% | 100% | 64% | 28 |
| SSA | 100% | 100% | 100% | 88% | 100% | 100% | 100% | 25% | 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 |
| 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
9 records with at least one practice unanswered or in progressOpen in explorer| Use case | Stage | Test | AIA | Review | Monitor | Train | Fail-safe | Appeal | Consult |
|---|---|---|---|---|---|---|---|---|---|
| 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 |
| 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 |
| 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 |
| 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 |
| 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?
- 28 high-impact use cases mark an appeal process as not applicable. On what basis was each individual outcome judged not contestable?
- 10 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.