AI assurance · 2026-08-20

OMB M-25-21: what high-impact AI actually requires

High-impact determinations, impact assessments, monitoring plans, and human oversight are recurring work—not a one-time checklist.

Acceleration with guardrails

OMB M-25-21 tells agencies to accelerate AI use while maintaining public trust. For primes, that means the solicitation language around high-impact AI is no longer optional color—it is a scope driver.

The recurring work package

High-impact determinations are not a one-time memo. Each new high-impact deployment can reopen:

  • Use-case inventory and determination rationale
  • AI impact assessment
  • Pre-deployment testing (including bias and hallucination where relevant)
  • Monitoring plans and drift detection
  • Human oversight, appeal, and feedback processes

That is why our High-Impact AI Determination and Impact Assessment offering is scoped as a 4–6 week package that can recur as the agency deploys.

What evaluators look for

Evaluators mark down vague "we follow AI RMF" claims. They look for named deliverables, control mapping, and evidence that the people writing the volume have operated these processes in federal environments—not only read the memorandum.

Where we fit

We write the determination package, stand up the test harness, and leave the prime with artifacts they can reuse. We do not market around you to the customer.

Related work package

Need this mapped into a scoped subcontract?

We usually price by work package after a short no-cost scoping call.

Experience described reflects work performed by Legate Solutions principals while employed by other organizations. It is provided to show individual qualifications and is not represented as corporate past performance of Legate Solutions LLC or as an endorsement by any agency named. Corporate past performance and references are available where applicable; where no relevant corporate record exists, Legate requests evaluation consistent with FAR 15.305(a)(2)(iv).