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

Reported in placeReported in progressReported not in placeNot applicablePrecluded by law or guidanceOther or ambiguous answerNo answer reported

Pre-deployment testing

Pre-deployment testing
Reported in place: 3 (15.0%)Pre-deployment testing
Reported in progress: 10 (50.0%)Pre-deployment testing
Reported not in place: 1 (5.0%)Pre-deployment testing
No answer reported: 6 (30.0%)

AI impact assessment

AI impact assessment
Reported in place: 3 (15.0%)AI impact assessment
Reported in progress: 12 (60.0%)AI impact assessment
No answer reported: 5 (25.0%)

Independent review

Independent review
Reported in place: 3 (15.0%)Independent review
Reported not in place: 2 (10.0%)Independent review
No answer reported: 15 (75.0%)

Ongoing monitoring

Ongoing monitoring
No answer reported: 20 (100.0%)

Operator training

Operator training
No answer reported: 20 (100.0%)

Fail-safe

Fail-safe
Reported in place: 1 (5.0%)Fail-safe
Not applicable: 9 (45.0%)Fail-safe
No answer reported: 10 (50.0%)

Appeal process

Appeal process
Not applicable: 12 (60.0%)Appeal process
Precluded by law or guidance: 1 (5.0%)Appeal process
No answer reported: 7 (35.0%)

User and public consultation

User and public consultation
Reported in place: 5 (25.0%)User and public consultation
Other or ambiguous answer: 9 (45.0%)User and public consultation
No answer reported: 6 (30.0%)

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	20	3	10	1	0	0	0	6	70%	15% of 20
AI impact assessment	20	3	12	0	0	0	0	5	75%	15% of 20
Independent review	20	3	0	2	0	0	0	15	25%	15% of 20
Ongoing monitoring	20	0	0	0	0	0	0	20	0%	0% of 20
Operator training	20	0	0	0	0	0	0	20	0%	0% of 20
Fail-safe	20	1	0	0	9	0	0	10	50%	9% of 11
Appeal process	20	0	0	0	12	1	0	7	65%	0% of 7
User and public consultation	20	5	0	0	0	0	9	6	70%	25% of 20

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	9%	0%	–	–	–	0%	0%	0%	11
EAC	25%	–	0%	–	–	–	–	100%	4
FERC	–	100%	100%	–	–	–	0%	–	3
SSA	50%	0%	–	–	–	50%	0%	50%	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

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

Use case	Stage	Test	AIA	Review	Monitor	Train	Fail-safe	Appeal	Consult
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
NA-CI Salesforce DOE · DOE-747	Deployed	Reported in progress	Reported in progress	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported
Grants Lifecycle Application System EAC · EAC-3	Deployed	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported	Reported in place
SSA 800# Public Question & Answer Bot and OIG Hotline recording of fraud, waste and abuse. SSA · R3106	Deployed	Reported in place	Reported in progress	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported
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 Chat Bot for IT User Services DOE · DOE-463	Pilot	Reported in progress	Reported in progress	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported
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
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
AI Answers in Clearinghouse Network EAC · EAC-1	Pilot	Reported in place	No answer reported	Reported not in place	No answer reported	No answer reported	No answer reported	No answer reported	Reported in place
Internal Generative AI Tools for Staff Productivity EAC · EAC-2	Pilot	Reported not in place	No answer reported	Reported not in place	No answer reported	No answer reported	No answer reported	No answer reported	Reported in place
Routing emails from shared inboxes EAC · EAC-4	Pilot	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported	Reported in place
Improve Safety Inspections Use Case FERC · FERC-0002	Pre-deployment	No answer reported	Reported in place	Reported in place	No answer reported	No answer reported	No answer reported	Not applicable	No answer reported
Enhance Market Surveillance and Fraud Detection Use Case FERC · FERC-0003	Pre-deployment	No answer reported	Reported in place	Reported in place	No answer reported	No answer reported	No answer reported	Not applicable	No answer reported
Support Interconnection Request Responses Use Case FERC · FERC-0004	Pre-deployment	No answer reported	Reported in place	Reported in place	No answer reported	No answer reported	No answer reported	Not applicable	No answer reported

Unanswered analytical questions

Generated from the data; for follow-up with agencies

VA designated 215 use cases high-impact but answered none of the minimum-practice questions for any of them. Were the practices assessed, and where is that recorded?
DOJ designated 41 use cases high-impact but answered none of the minimum-practice questions for any of them. Were the practices assessed, and where is that recorded?
DOE designated 27 use cases high-impact but answered none of the minimum-practice questions for any of them. Were the practices assessed, and where is that recorded?
DHS designated 16 use cases high-impact but answered none of the minimum-practice questions for any of them. Were the practices assessed, and where is that recorded?
NCUA designated 5 use cases high-impact but answered none of the minimum-practice questions for any of them. Were the practices assessed, and where is that recorded?
TREAS designated 4 use cases high-impact but answered none of the minimum-practice questions for any of them. Were the practices assessed, and where is that recorded?
USDA designated 3 use cases high-impact but answered none of the minimum-practice questions for any of them. Were the practices assessed, and where is that recorded?
1 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?
7 high-impact use cases report using PII but give no link to a Privacy Impact Assessment. Is a PIA published elsewhere?
4 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.