Focus area 03 · Governance

Agency AI Governance

A public agency that adopts an AI tool inherits accountability for what the tool does to the people it serves. The screener on this page tests a proposed use against the controls that have to exist first, and names the specific control missing behind each gap.

A clinician reviewing a chart in conversation with a patient

Professional judgment stays with the professional

Proposed AI use

The governance problem

VR agencies hold unusually sensitive records. Disability documentation, medical and psychological evaluations, and earnings history all sit in the case file, and federal rule restricts how that information may be used and disclosed 34 CFR 361.38. Sending that material to a vendor system is a disclosure decision, not merely a software decision, and it is frequently made by staff who were never told they were making one.

Accessibility of the tool itself is the gap agencies overlook most often. An AI interface procured by a state agency is subject to Section 508, so a system that a counselor with a disability or a client with a disability cannot operate with a screen reader is not deployable regardless of how well it performs 29 U.S.C. 794d. The screener below runs twelve items across seven control domains and returns a readiness tier with the required control for every gap it finds.

AI Academy — VR Tracks Back to the project

Answer twelve items about the AI use you are considering. Each is scored fully in place, partially in place, or not in place. The screener returns a readiness tier, every gap it finds, and the control required to close it.

Readiness result

Myth or Fact?

"If the vendor is compliant, the agency is compliant."

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MYTH. A vendor attestation does not transfer the agency's obligations. The agency remains responsible for the confidentiality of personal information in the case record and for the accessibility of the technology it procures. Vendor claims should be tested against an accessibility conformance report and contract terms, not accepted as given.Source: 34 CFR 361.38; Section 508, 29 U.S.C. 794d.

Myth or Fact?

"An AI interface bought by a state VR agency has to be accessible."

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FACT. Information and communication technology developed, procured, maintained, or used by a covered agency must be accessible to people with disabilities. An AI tool with an interface staff or clients operate is squarely inside that scope, and conformance should be evidenced before purchase rather than remediated after.Source: Section 508, 29 U.S.C. 794d; PEAT procurement guidance.

Myth or Fact?

"AI can decide eligibility if a counselor signs off afterward."

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MYTH. Eligibility rests on a determination made by qualified agency staff on the individual's record, and a signature applied to an output the reviewer did not independently evaluate is not review. Where AI assists, the human decision must be documented as substantive, reversible, and traceable to the evidence in the case file.Source: WIOA Title IV, 34 CFR 361.42; DOL AI & Inclusive Hiring Framework.

Myth or Fact?

"An AI screening tool can disadvantage applicants with disabilities even when disability is never an input."

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FACT. Models trained on historical outcomes learn proxies. Employment gaps, non-standard work histories, response timing, and video or voice features all correlate with disability, so a system that never sees a disability field can still produce disparate results. Testing outcomes by subgroup is the only way to detect it.Source: DOL ODEP; PEAT AI & Disability Inclusion Toolkit.

Partner · PEAT

Partnership on Employment & Accessible Technology

AI and disability inclusion toolkit, plus accessible procurement guidance.

Federal · ODEP

Office of Disability Employment Policy

The AI and inclusive hiring framework the screener items are aligned to.

Federal · Section 508

Section508.gov

Accessibility requirements and conformance reporting for procured technology.

Partner · EARN

Employer Assistance and Resource Network

Inclusive workplace policy and practice resources.

Live product

AI Academy — VR Tracks

Staff AI literacy certification for counselors and agency leaders.