GIAG — A ThinkCapital Research Program

Active Research Program • Launched 2026

Government IT/AI Governance Initiative

A comparative research program examining measurement discipline and accountability across six stages of public sector AI governance. Five working papers and four measurement instruments are published. We produce findings practitioners can use.

Phase 2 is recruiting. Interviews with government CIOs, chief AI officers, procurement and audit staff are open now. Target: 15 conversations completed by February 1, 2027.

Research Participation Prospectus: Version 1.0, February 2026

Full details on research design, participation requirements, data handling, privacy rights, and what participants receive.

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Why This Research Is Needed Now

Agencies across federal and state government are operating under formal AI governance requirements. NIST AI Risk Management Framework adoption is accelerating. Agencies document, approve, and file oversight mechanisms. Executive orders and OMB guidance, currently Memorandum M-25-21,9 have created a compliance infrastructure that did not exist three years ago.

What is largely absent from the literature is empirical research on whether any of it is working. Most governance commentary is normative: what agencies should do, what frameworks they should adopt, what policies should require. Empirical research on what is happening in practice is sparse and mostly audit-by-audit. Are existing frameworks producing the accountability outcomes they were designed for?

The documentation exists. In three public reviews, evidence that the controls operated was missing. Each review found an evaluation or implementation step that had not been taken as of the report date. In 2012 GAO found that CBP had not assessed whether an updated set of rules in its Automated Targeting System was more effective.1 GAO described the system in 2006 as a cargo-inspection targeting tool,7 and DHS's 2006 notice and 2012 privacy assessment describe it as covering travelers as well as cargo.6,8 In June 2026 the Treasury Inspector General for Tax Administration found that the IRS had not taken sufficient steps to evaluate the effectiveness of its chat applications, which began as a pilot in 2017.2 In September 2026 the SBA Office of Inspector General found that SBA had not implemented a process to identify high-impact AI uses.3 DHS, the IRS, and SBA agreed with the recommendations.

Vendor disclosures raise the same question. A September 2026 news report described an OpenAI disclosure of six incidents of unexpected or concerning model behavior over the prior six months, and cited a Reuters report that related agent activity at Hugging Face began about two months before it was discovered.5

Looking good on paper does not make a framework function under operational conditions. Measurement discipline separates frameworks that hold from frameworks that only perform.

The Connective Thread: Measurement

Neither governance effectiveness nor oversight quality can be evaluated without agreed measurement criteria. ThinkCapital's contribution is methodological: applying systematic assessment frameworks developed over three decades of government IT research and informed by collaboration with IFPUG, NESMA, and Carnegie Mellon University. The goal is empirical findings that practitioners can use immediately.

The GIAG Governance Pipeline

Working Paper 4 defines six stages where agencies make, review, or record decisions about an AI system. A failure at one stage does not require a failure at another, so the program measures each stage separately. Four stages have a published instrument. Two are open research. GAO's 2021 accountability framework for AI audits is a reference point for the pipeline.14

StageQuestion the stage must answerInstrument or streamStatus
1. Authorization & scopeDoes the system still do only what it was authorized to do, and who would notice if it did not?Stream Three: Authorization & Scope IntegrityForming
2. Technical specificationCould the testing claim have failed?Testing Rigor: four conditions of a rigorous testing claim (Solicitation & Due-Diligence Review)Published
3. Deployment reviewDid review change or stop anything, and did governance scale up when the pilot moved to production?Stream Four: Deployment Review & the Pilot-to-Production GateForming
4. Operational oversightDid the human reviewer have the authority, time, and information to exercise judgment?Human Oversight Quality Index (Stream Two)Published
5. AuditHow long did an unauthorized action run before someone with authority knew?Detection Clock (Working Paper 4)Published
6. Post-decision reconstructionCan a single decision survive scrutiny after the fact?Governance Evidence test (Working Paper 5)Published

Stream One (NIST AI RMF implementation) cuts across all six stages by testing whether framework adoption changes any of these outcomes.

Research Streams

The initiative comprises two active streams and four forming streams. Two of the forming streams open the pipeline stages that have no instrument yet.

Stream One  •  Active

NIST AI RMF Implementation in Government Practice

The NIST AI Risk Management Framework,13 a voluntary framework, is rapidly becoming the default governance reference for federal and state agencies. Yet few empirical studies examine how it performs in practice across different organizational contexts.

"Where is NIST AI RMF adoption generating genuine risk reduction, and where is it producing compliance documentation without corresponding accountability?"

This stream examines implementation patterns across agency types, sizes, and mission profiles through structured interviews with government IT leaders who have direct deployment or evaluation experience. Key dimensions include framework adaptation to agency context, measurement of implementation fidelity, and conditions under which RMF adoption produces durable governance versus audit-cycle compliance.

Stream Two  •  Active

Human Oversight Quality in AI-Augmented Government Operations

Most AI governance requirements treat human oversight as binary: present or absent. The more consequential variable is whether oversight mechanisms constitute genuine controls or documented assumptions.

"What does meaningful human oversight require at scale, and how does current government practice compare against any reasonable operational definition of it?"

This stream develops a typology of oversight models observed across government AI deployments, tests them against real operational scenarios, and constructs a measurement framework for evaluating oversight quality. Key dimensions include oversight mechanism design across agentic and assistive AI systems, intervention point architecture, audit trail integrity, and the conditions under which oversight requirements produce functional accountability versus documentation without evidence of operation.

Stream Three  •  Forming  •  Pipeline Stage 1

Authorization & Scope Integrity

Every later stage of the pipeline inherits the authorization decision. A system the agency approved for one purpose can grow into another through contract modifications, new data sources, and new users, while the original approval stays on file. The role responsible for the decision is sometimes vacant or contested.

"When an agency authorizes a system for one purpose, what shows it stayed within that purpose, and who holds the authority when the office is unfilled?"

This stream compares agencies that defined authorization before deployment with agencies that assembled it afterward to cover systems already running. It asks practitioners how a system's actual use compares with its authorized use, and who owns that comparison. It also examines chief AI officer designation and vacancy, the difference between an enforceable directive and a directive that only sits on paper, and the evidence that approval preceded launch. Participation is by structured interview with practitioners who have written, held, or audited authorization authority.

Stream Four  •  Forming  •  Pipeline Stage 3

Deployment Review & the Pilot-to-Production Gate

Governance built for a pilot does not scale to production, and a pilot can run for years without a full production review. Recent reporting also describes pilots that stall in compliance review because testing, bias review, and monitoring arrive as late steps instead of design constraints.

"Where does pre-deployment review change or stop a system, and where does it only approve what was already decided?"

This stream collects cases of deployment review from agencies and tests the Five Intervention Criteria (irreversibility, consequence transfer, distributional novelty, value conflict, and legal or regulatory accountability) and risk tiering against them. Key dimensions include what a review has the power to refuse, what evidence it requires, and how agencies resize governance when a pilot graduates to production.

Additional Streams Under Development

○ Forming

AI Adoption Thresholds & Organizational Tipping Points

Applying Schelling-Granovetter threshold models to explain why identical AI initiatives succeed in some agencies and stall in others, and what moves them past the tipping point.

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○ Forming

AI Productivity Measurement for Government Missions

Developing empirical methods for measuring whether AI tools are delivering measurable improvements in government mission contexts, beyond technology metrics.

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Two Benchmarks You Can Contribute To

Each study takes under an hour. We remove names and agency identifiers from analysis files and do not publish participant identities without written consent. We cannot guarantee anonymity against legal process. Please do not share classified, controlled unclassified, or source-selection-sensitive material, and check your agency's rules first. Contributors receive aggregate findings before publication, not other participants' individual responses.

Detection Clock  •  Pipeline Stage 5

Detection Interval Benchmark

Government practitioners and contracting offices report three facts about one AI-enabled system:

  • Whether the contract defines a maximum interval between an unauthorized action and notice to the agency.
  • Whether the audit log retention window is long enough to reconstruct an event that surfaces months later.
  • Who inside the agency owns escalation once an anomaly is flagged.
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Testing Rigor  •  Pipeline Stage 2

Solicitation & Due-Diligence Review

Procurement and contracting professionals share AI solicitation or contract language after removing identifying detail. GIAG scores each clause against the four conditions of a rigorous testing claim and reports the aggregate pattern: how often agencies require a vendor to state a measurable rate, and how often they accept a general assurance. Federal context includes the FTC's 2024 enforcement against deceptive AI claims11 and GSA's June 2026 request for comments on a proposed clause on large language model data.12 A second pass records whether the solicitation asks the vendor to disclose where it is organized, who certified its product, and any government ownership or funding interest. GIAG records whether such questions appear. It does not assess any vendor or country, and agencies should check with counsel before adding disclosure requirements.

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Methodology

The program applies comparative assessment methodology developed through three decades of government IT research. The approach is empirical and practitioner-oriented, grounded in systematic assessment disciplines pioneered at Software Productivity Research and refined through advisory engagements with federal agencies, defense organizations, and state governments.

Evidence Base: Two Phases

Phase 1, complete. Instrument development on documented public cases, together with informal conversations with IT and AI governance practitioners. The conversations shaped the questions and scoring criteria. They are not a sample, and GIAG draws no prevalence claims from them.

Phase 2, recruiting now. Structured interviews with government CIOs, chief AI officers, procurement leads, and audit staff. The target is 15 conversations completed by February 1, 2027. Findings from Phase 2 will state who was interviewed, how they were recruited, and what the sample can and cannot show. Until then, read the instruments as tested on public cases and not yet validated in the field.

Structured Practitioner Interviews (Phase 2)

Primary data collection through 30–45 minute structured interviews with government IT leaders, AI governance practitioners, and policy implementers with direct deployment or evaluation experience within the past 18 months.

Comparative Framework Analysis

Cross-agency analysis of governance documentation, implementation records, and self-reported outcomes using standardized assessment criteria drawn from international measurement standards work.

Public-Case Instrument Testing

ThinkCapital applies each measurement instrument to documented public cases before practitioners use it. We applied Testing Rigor to publicly available documentation about a state criminal sentencing tool10, the Governance Evidence test to litigation records, and the Detection Clock to publicly reported vendor disclosures. Scores describe documentation, not a product's accuracy or fairness. ThinkCapital publishes the results and scoring criteria with each working paper. These are tests on public cases, not field validation.

Pattern Identification and Framework Development

Synthesis of documentary findings and practitioner input into actionable decision frameworks for practitioners. The frameworks distinguish conditions that produce durable governance from those that produce documentation without evidence of operation.

This research builds on measurement frameworks developed through collaboration with IFPUG, NESMA, and Carnegie Mellon University, and is informed by ongoing collaboration with researchers in the software measurement and AI governance communities. The sizing methods are described in technical paper D-1. ThinkCapital is an independent research organization; this program is not commissioned by or affiliated with any AI vendor, platform provider, or government agency. See Research Integrity for how ThinkCapital separates research from advisory work, and Sources and Citations for the documents cited on this page.

Research Timeline

1
Q1 2026: Complete

Research Design and Participant Recruitment

ThinkCapital designed the interview instruments, began outreach to practitioners across both active streams, and established comparative assessment criteria and baseline documentation protocols. It released Working Paper 1.

2
Q2 2026: Complete

Documentary Analysis and Practitioner Conversations

ThinkCapital held exploratory conversations with practitioners, collected and coded documentary evidence from public cases, and developed frameworks alongside the analysis. It released Working Papers 2 and 3.

3
Q3 2026: Complete

Analysis and Draft Findings

Cross-case analysis produced the six-stage governance pipeline and four measurement instruments. ThinkCapital released Working Papers 4 and 5.

4
Q4 2026: Current

Publication, Dissemination, and New Streams

ThinkCapital publishes first findings and submits them to relevant practitioner and academic venues. Sector briefings are available on request. Phase 2 interviews with government practitioners (target: 15 conversations completed by February 1, 2027), Streams Three and Four, and the two participation studies are open for recruitment.

Get Involved

Participate in This Research

We are conducting structured interviews and running two benchmarks with government IT leaders, AI governance practitioners, contracting professionals, and policy implementers who have direct experience deploying AI or implementing governance frameworks in federal, state, or local government.

We aim to complete 15 conversations by February 1, 2027. Participation involves a single 30–45 minute structured interview. Participants receive aggregate preliminary findings and may be acknowledged by name or participate with identifiers removed. Anonymity cannot be guaranteed against legal process.

Take part: 30–45 minute interview or benchmark Download Full Prospectus

We are particularly interested in practitioners with direct experience implementing or evaluating AI governance frameworks in the past 18 months. Accounts of difficulty or partial implementation are as valuable as accounts of success.