Governance & Policy

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Deliverable 4h · AI Governance Enhancements

Governance & Policy

The accountability structure, the updated policy suite, and the Enhanced Traffic-Light Protocol — the connective tissue that makes the framework auditable and durable. Designed to meet-or-exceed OMB M-25-21 while honoring IG independence.

AI Governance Board

Senior leadership body that approves High-Impact use cases, sets risk appetite, and reviews the quarterly posture.

Chief AI Officer (CAIO)

Accountable owner of the AI portfolio — conditional approvals, the inventory, and policy currency.

Independent assurance

Office of Audit can audit the AI program against GAO-21-519SP using the registry and evidence logs.

Policy suite

Data Governance Policy

v3.2 · POL-001
Updated

Establishes lifecycle management standards for all data assets used to train, validate, and operate OIG AI systems, including lineage tracking, retention schedules, and access controls. Aligns with OMB M-25-21 data documentation requirements and NIST AI RMF Data function.

  • All training datasets must have a documented Data Card before model registration.
  • Data lineage must be traceable from ingestion source to model training artifact.
  • PII-bearing datasets require Privacy Impact Assessment (PIA) approval prior to use in model development.
  • Annual data quality audits are mandatory for all Tier 1 (high-stakes) AI systems.
GAO-21-519SP DataNIST AI RMF MANAGEOMB M-25-21 §4USPS OIG Data Management Standard v2.0

Privacy & PII Handling

v2.4 · POL-002
Updated

Defines rules for the identification, classification, masking, and disposal of Personally Identifiable Information encountered in AI training pipelines and model outputs, consistent with the Privacy Act of 1974 and OMB Circular A-130. Prohibits use of unmasked PII in non-production environments.

  • PII fields must be tokenized or pseudonymized before inclusion in any model training dataset.
  • AI-generated outputs that re-identify individuals require mandatory human review before dissemination.
  • Access to PII-containing model artifacts is restricted to personnel with current Privacy Act training certification.
  • Breach response procedures must be initiated within 1 hour of suspected PII exposure in an AI pipeline.
GAO-21-519SP GovernanceNIST AI RMF GOVERN 1.1OMB Circular A-130Privacy Act of 1974

AI Transparency & Disclosure

v2.1 · POL-003
Updated

Requires that all AI-assisted decisions presented to investigators or external stakeholders be clearly labeled as AI-generated, accompanied by confidence levels and explainability outputs, and subject to documented human review before any enforcement action is taken.

  • All AI-generated risk scores must display the contributing model version and inference date.
  • SHAP or LIME feature attribution is mandatory for any output classified as high-stakes.
  • Public-facing reports derived from AI analytics must include a standardized AI disclosure statement.
  • Investigators must complete an attestation log entry before acting on any AI recommendation above the high-risk threshold.
GAO-21-519SP PerformanceNIST AI RMF GOVERN 6.1OMB M-25-21 §3(b)

Enhanced TLP Classification Model

v1.3 · POL-004
Updated

Extends the CISA Traffic Light Protocol with AI-lifecycle overlays covering output provenance, PII/CUI sensitivity layering, role-based access mapping, and temporal reclassification triggers, ensuring consistent information-sharing controls across the OIG's internal and interagency AI workflows.

  • TLP:RED designation applies to raw inference outputs from models trained on CUI datasets.
  • All TLP:AMBER AI outputs must include provenance metadata (model ID, version, inference timestamp).
  • Temporal reclassification review is required at 90-day intervals for any AI artifact tagged TLP:RED or TLP:AMBER.
  • Role-based access matrices are maintained in the AI Inventory and enforced via RBAC controls in the model-serving infrastructure.
FIRST.org TLP v2.0NIST AI RMF GOVERN 2.2GAO-21-519SP GovernanceOMB M-25-21 §6

Human Oversight & Accountability

v3.0 · POL-005
Updated

Establishes mandatory human-in-the-loop checkpoints for all consequential AI-assisted decisions, defines override and escalation authorities, and requires auditable sign-off logs tied to individual investigator credentials for any enforcement referral originating from an AI recommendation.

  • No enforcement referral may be submitted based solely on an AI recommendation without documented human review.
  • Override decisions must be logged with a rationale code within 24 hours of the review action.
  • Senior investigator countersign is required for any high-risk (≥0.80 score) fraud flag before case opening.
  • Quarterly human-review audits assess calibration between model recommendations and investigator override patterns.
GAO-21-519SP GovernanceNIST AI RMF MANAGE 2.4OMB M-25-21 §4(c)USPS OIG Investigations SOP-INV-07

Acceptable Use of Generative AI

v1.0 · POL-006
In Review

Defines permitted and prohibited use cases for large language models and generative AI tools within OIG operations, establishes output-validation requirements for any generative AI content entering official records, and prohibits the submission of CUI or PII to external generative AI services without an approved data-processing agreement.

  • Generative AI tools may be used for draft summarization and report structuring only; final products require human authorship attestation.
  • Submission of CUI, PII, or law-enforcement sensitive data to non-FedRAMP-authorized generative AI services is prohibited.
  • All generative AI outputs used in official reports must be flagged with a standard disclosure tag and retained in the case record.
  • An approved tool registry will be maintained listing generative AI services that meet OIG data-handling standards.
OMB M-25-21 §7NIST AI RMF GOVERN 4.1GAO-21-519SP Governance

Enhanced Traffic-Light Protocol

Data classification, extended for the AI lifecycle

We start from the FIRST.org TLP v2.0 standard the OIG’s security teams already know — then layer it for AI: provenance tagging, sensitivity layering, role-based enforcement, and temporal reclassification.

TLP:RED

Information restricted to named recipients only; not for further disclosure without explicit originator authorization. Highest sensitivity; includes active law-enforcement intelligence, unredacted whistleblower identities, and raw model outputs derived from CUI training data.

Example

Real-time fraud model inference scores tied to a named postal contractor under active OIG investigation, shared only with the lead Special Agent and OIG Counsel.

Handling

Transmitted only via encrypted, authenticated channels; stored exclusively in FIPS 140-2 validated environments; must not be shared across agency boundaries without originator sign-off; subject to mandatory 90-day temporal reclassification review.

TLP:AMBER

Information limited to the recipient organization and its direct operational partners on a need-to-know basis. May include sensitive analytical outputs, draft audit findings, and AI-generated risk summaries prior to final investigative determination.

Example

Hotline complaint prioritization scores for a regional mail-theft cluster shared with the USPS Postal Inspection Service for joint operational coordination — not for public release or press.

Handling

Shared only with vetted interagency partners under active information-sharing agreements; recipients may not forward without originator approval; AI provenance metadata must accompany all TLP:AMBER AI outputs; access logged in the AI Inventory.

TLP:GREEN

Information cleared for broad sharing within the postal and federal oversight community but not intended for public release. Includes aggregated trend analyses, de-identified model performance benchmarks, and policy guidance shared across the federal Inspector General community.

Example

Aggregated quarterly fraud-detection KPI benchmarks shared with the Council of Inspectors General on Integrity and Efficiency (CIGIE) AI working group for cross-agency benchmarking.

Handling

May be shared freely within federal government and oversight community networks; must not be posted to public-facing websites or shared with media; recipients are responsible for ensuring onward distribution remains within the cleared community.

TLP:CLEAR

Information approved for unrestricted public distribution. Includes published OIG reports, anonymized case statistics, AI framework documentation cleared for public release, and approved transparency disclosures about OIG AI use.

Example

OIG Semiannual Report to Congress statistics on mail-theft complaint volumes and AI-assisted investigation outcomes, posted to the public OIG website.

Handling

No handling restrictions; may be freely shared with the public, media, and Congressional stakeholders; all PII, CUI, and law-enforcement sensitive content must be removed or redacted before TLP:CLEAR designation is applied.

What makes it “enhanced”

1

Output provenance tagging: every AI-generated artifact is stamped with model ID, version, inference timestamp, and training data vintage before TLP classification is applied, enabling full auditability of how sensitive outputs were produced.

2

PII/CUI sensitivity layering: TLP tier assignments are augmented with a secondary sensitivity tag (PII, CUI-Basic, CUI-Specified, or NONE) so recipients understand both sharing scope and data-handling obligations in a single label.

3

Role-based access mapping: TLP tiers are cross-referenced with the OIG RBAC matrix in the AI Inventory, ensuring automated access controls enforce TLP restrictions at the system level rather than relying solely on recipient discretion.

4

Temporal reclassification triggers: TLP:RED and TLP:AMBER AI artifacts are automatically flagged for reclassification review at 90-day intervals or upon case closure, allowing sensitive outputs to be downgraded to TLP:GREEN or TLP:CLEAR as investigations conclude and public-interest value increases.