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: 27 records · all use cases in the current filter

Reported in placeReported in progressNot applicableNo answer reported

Pre-deployment testing

Pre-deployment testing
Reported in place: 2 (7.4%)Pre-deployment testing
No answer reported: 25 (92.6%)

AI impact assessment

AI impact assessment
Reported in progress: 2 (7.4%)AI impact assessment
No answer reported: 25 (92.6%)

Independent review

Independent review
Reported in progress: 2 (7.4%)Independent review
No answer reported: 25 (92.6%)

Ongoing monitoring

Ongoing monitoring
Reported in place: 1 (3.7%)Ongoing monitoring
Reported in progress: 1 (3.7%)Ongoing monitoring
No answer reported: 25 (92.6%)

Operator training

Operator training
Reported in place: 2 (7.4%)Operator training
No answer reported: 25 (92.6%)

Fail-safe

Fail-safe
Reported in place: 1 (3.7%)Fail-safe
Not applicable: 1 (3.7%)Fail-safe
No answer reported: 25 (92.6%)

Appeal process

Appeal process
Reported in place: 1 (3.7%)Appeal process
Not applicable: 1 (3.7%)Appeal process
No answer reported: 25 (92.6%)

User and public consultation

User and public consultation
Reported in place: 2 (7.4%)User and public consultation
No answer reported: 25 (92.6%)

Practice	In scope	In place	In progress	N/A	No answer	Answered	In place of applicable
Pre-deployment testing	27	2	0	0	25	7%	7% of 27
AI impact assessment	27	0	2	0	25	7%	0% of 27
Independent review	27	0	2	0	25	7%	0% of 27
Ongoing monitoring	27	1	1	0	25	7%	4% of 27
Operator training	27	2	0	0	25	7%	7% of 27
Fail-safe	27	1	0	1	25	7%	4% of 26
Appeal process	27	1	0	1	25	7%	4% of 26
User and public consultation	27	2	0	0	25	7%	7% of 27

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
HHS	–	–	–	–	–	–	–	–	19
STATE	33%	0%	0%	33%	33%	33%	33%	33%	3
HUD	–	–	–	–	–	–	–	–	2
DHS	50%	0%	0%	0%	50%	0%	0%	50%	2
FDIC	–	–	–	–	–	–	–	–	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

27 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
Position Description Generation and Evaluation DHS · DHS-2451	Deployed	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported
Renamed: 356H Machine Learning (ML) Facility Supply Chain Role Classification Previously: 356H ML Facility Supply Chain Role Classification HHS · R0816	Deployed	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported
Annual Report CMC HHS · R0822	Deployed	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported
Renamed: Application References Previously: Application-DMF Reference HHS · R0823	Deployed	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported
Renamed: Extracting DMF Facilities from unstructured documents Previously: DMF (Drug Master File) Facilities HHS · R0824	Deployed	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported
Renamed: Module 3 Facilities Extraction Previously: Module 3 Faculties HHS · R0827	Deployed	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported
Packaging Materials and Suppliers HHS · R0828	Deployed	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported
Real World Data/Evidence HHS · R0830	Deployed	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported
Regulatory Starting Material HHS · R0831	Deployed	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported
Category Subcategory Classification - Safety Reports Bot HHS · R0841	Deployed	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported
Elsa GenAI Chat Tool HHS · R0870	Deployed	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported
DAIT AIDS-Related Research Solution HHS · R0912	Deployed	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported
Federal IT Acquisition Reform Act (FITARA) Tool HHS · R0916	Deployed	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported
SRDMS NLP COI HHS · R0941	Deployed	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported
TB Case Browser Image Text Detection HHS · R0945	Deployed	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported
TB DEPOT (Tuberculosis Data Exploration Portal) HHS · R0974	Deployed	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported
TB Portals Outlier Detection Lambda Function HHS · R0975	Deployed	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported
Counterparty Risk Anomaly Detection HUD · HUD-2024-001	Deployed	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported
Automated Draft Narrative Reports Previously "Automating Draft Counterparty Credit Narrative Reports"; have since expanded to general enterprise use. HUD · HUD-2024-003	Deployed	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-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
AI Research Engine (AIRE) STATE · R3231	Deployed	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported
TIP Report Research Translation STATE · R3264	Deployed	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported	No answer reported
Trust Document Entity Extraction FDIC · FDIC – 52	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
Smart Solution for Docket Management (SSDM) HHS · R0869	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
OSPIDA RPAB Scientific Coding Assistance Tool (CAT) HHS · R0998	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
AWS Exscribo HHS · R0999	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

2 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?
1 high-impact use cases mark an appeal process as not applicable. On what basis was each individual outcome judged not contestable?

These are questions the inventory raises but cannot answer. They are not findings of non-compliance.