The National Telecommunications and Information Administration (NTIA) has circulated an Artificial Intelligence (AI) Accountability Policy Request for Comment on what policies can support the development of AI audits, assessments, certifications, and other mechanisms to create earned trust in AI systems. Technical assessments are not intended to support purely technical goals, but also claims regarding the holistic behavior of the system and how a system may technically achieve such claims. It is currently difficult to assess the technical attributes that can foster or impede the implementation of accountability mechanisms given that existing AI-based systems do not follow basic software safety and security best practices (e.g., IEC 61508, NIST 800-154, ODDs).