Your policy commits to scheduled fairness testing the estate does not show
AI policy (3.3) commits to testing fairness or disparate impact on a set schedule. MDL-001 Claims triage does not meet it, because no test is on record at all. A reviewer who reads the policy first expects a test result from the last ninety days to be in the file, and its absence tells them the schedule exists on paper. Once they have found one control that exists only on paper, they check the others the same way.
To fix: Run the test the policy already requires and record the date, or amend the policy to the cadence you actually keep. A commitment you do not meet costs more than one you never made.