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: 31 records · all use cases in the current filterReported in placeReported in progressReported not in placeNot applicableOther or ambiguous answerNo answer reported
Pre-deployment testing
Pre-deployment testing
Reported in place: 3 (9.7%)Pre-deployment testing
Reported in progress: 3 (9.7%)Pre-deployment testing
Reported not in place: 1 (3.2%)Pre-deployment testing
No answer reported: 24 (77.4%)
31Reported in place: 3 (9.7%)Pre-deployment testing
Reported in progress: 3 (9.7%)Pre-deployment testing
Reported not in place: 1 (3.2%)Pre-deployment testing
No answer reported: 24 (77.4%)
AI impact assessment
AI impact assessment
Reported in place: 1 (3.2%)AI impact assessment
Reported in progress: 4 (12.9%)AI impact assessment
No answer reported: 26 (83.9%)
31Reported in place: 1 (3.2%)AI impact assessment
Reported in progress: 4 (12.9%)AI impact assessment
No answer reported: 26 (83.9%)
Independent review
Independent review
Reported in place: 3 (9.7%)Independent review
Reported in progress: 1 (3.2%)Independent review
Reported not in place: 1 (3.2%)Independent review
No answer reported: 26 (83.9%)
31Reported in place: 3 (9.7%)Independent review
Reported in progress: 1 (3.2%)Independent review
Reported not in place: 1 (3.2%)Independent review
No answer reported: 26 (83.9%)
Ongoing monitoring
Ongoing monitoring
Reported in place: 1 (3.2%)Ongoing monitoring
Reported in progress: 4 (12.9%)Ongoing monitoring
No answer reported: 26 (83.9%)
31Reported in place: 1 (3.2%)Ongoing monitoring
Reported in progress: 4 (12.9%)Ongoing monitoring
No answer reported: 26 (83.9%)
Operator training
Operator training
Reported in place: 2 (6.5%)Operator training
Reported in progress: 3 (9.7%)Operator training
No answer reported: 26 (83.9%)
31Reported in place: 2 (6.5%)Operator training
Reported in progress: 3 (9.7%)Operator training
No answer reported: 26 (83.9%)
| 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 | 31 | 3 | 3 | 1 | 0 | 0 | 0 | 24 | 23% | 10% of 31 |
| AI impact assessment | 31 | 1 | 4 | 0 | 0 | 0 | 0 | 26 | 16% | 3% of 31 |
| Independent review | 31 | 3 | 1 | 1 | 0 | 0 | 0 | 26 | 16% | 10% of 31 |
| Ongoing monitoring | 31 | 1 | 4 | 0 | 0 | 0 | 0 | 26 | 16% | 3% of 31 |
| Operator training | 31 | 2 | 3 | 0 | 0 | 0 | 0 | 26 | 16% | 6% of 31 |
| Fail-safe | 31 | 3 | 0 | 0 | 3 | 0 | 0 | 25 | 19% | 11% of 28 |
| Appeal process | 31 | 0 | 0 | 0 | 6 | 0 | 0 | 25 | 19% | 0% of 25 |
| User and public consultation | 31 | 4 | 1 | 0 | 0 | 0 | 2 | 24 | 23% | 13% of 31 |
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 | 22% | 0% | 22% | 11% | 11% | 33% | 0% | 11% | 9 |
| DOJ | – | – | – | – | – | – | – | – | 4 |
| DOI | – | – | – | – | – | – | – | – | 3 |
| HHS | – | – | – | – | – | – | – | – | 2 |
| USDA | – | – | – | – | – | – | – | – | 2 |
| EPA | – | – | – | – | – | – | – | – | 2 |
| EAC | 0% | – | 0% | – | – | – | – | 100% | 2 |
| SSA | 50% | 50% | 50% | 0% | 50% | 50% | 0% | 50% | 2 |
| STATE | – | – | – | – | – | – | – | – | 2 |
| HUD | – | – | – | – | – | – | – | – | 1 |
| FCC | – | – | – | – | – | – | – | – | 1 |
| FTC | – | – | – | – | – | – | – | – | 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
31 records with at least one practice unanswered or in progressOpen in explorer| Use case | Stage | Test | AIA | Review | Monitor | Train | Fail-safe | Appeal | Consult |
|---|---|---|---|---|---|---|---|---|---|
| Microsoft Azure Quantum Elements DOE · DOE-512 | Pilot | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported |
| 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 |
| 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 |
| GitHub Copilot DOE · DOE-584 | Pilot | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported |
| Microsoft Copilot (Pilot) DOE · DOE-603 | Pilot | Reported in progress | Reported in progress | Reported in place | Reported in progress | Reported in progress | Reported in place | Not applicable | Reported in progress |
| 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 |
| Microsoft AI Builder DOE · DOE-683 | Pilot | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported |
| Microsoft Co-Pilot DOE · DOE-697 | Pilot | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported |
| CoPilot DOE · DOE-734 | Pilot | Reported in progress | Reported in progress | No answer reported | Reported in progress | Reported in progress | Not applicable | Not applicable | No answer reported |
| USGS Azure OpenAI ChatGPT [2024 INV#WO0000000154392] DOI · DOI-0241 | Pilot | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported |
| Non-Generative AI use for Trust Information Analysis and Reporting Tool [2024 INV#WO0000000110516] DOI · DOI-0002 | Pilot | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported |
| Integration of AI, specifically CoPilot for GitHub, for BTFA Software Development Life Cycle Process for DME and O&M applications. DOI · DOI-0001 | Pilot | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported |
| Internal Component-specific chatbot service DOJ · DOJ-0195 | Pilot | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported |
| Knowledge retrieval and synthesis (Azure OpenAI Services) DOJ · DOJ-0283 | Pilot | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported |
| Extracting Data from Receipts to Speed Travel Reimbursement or Provide Logbook Documentation DOJ · DOJ-0297 | Pilot | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported |
| Azure AI Foundry Platform DOJ · DOJ-0325 | Pilot | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported |
| 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 |
| Preparation of Brownfields Success Stories EPA · 29 | Pilot | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported |
| Summarize and draft response to comments EPA · 57 | Pilot | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported |
| AI-Enhanced ULS Reverse Engineering FCC · FCC-0001 | Pilot | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported |
| Microsoft 365 Copilot FTC · FTC-0010 | Pilot | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported |
| NIAMS AI Chatbot Pilot HHS · R0929 | Pilot | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported |
| Leveraging NLP and LLMs to identify and characterize NIH prevention research via 160-topic taxonomy HHS · R1018 | Pilot | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported |
| Microsoft Copilot HUD · HUD-2025-001 | Pilot | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported |
| 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 |
| General Use Chatbot SSA · R3125 | Pilot | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported |
| Live Consular AI Language Augmentation (LCALA) - Visa Interview Pilot STATE · R3267 | Pilot | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported |
| Live Consular AI Language Augmentation (LCALA) - OCS/ACS Pilot STATE · R3270 | Pilot | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported |
| Axon+ Copilot Studio Chatbot USDA · USDA-098 | Pilot | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported |
| GovChat USDA · USDA-107 | Pilot | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported | No answer reported |
Unanswered analytical questions
Generated from the data; for follow-up with agencies- 1 high-impact use cases mark an appeal process as not applicable. On what basis was each individual outcome judged not contestable?
- 2 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.